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Chipotle quietly filed FEC paperwork to form a political action committee. Illustration by Igor Golovniov/SOPA Images/LightRocket via Getty Images

2026-01-22T11:43:02.396Z

• Chipotle has filed to form a PAC, allowing the company to donate directly to federal candidates.
• The move is a departure from the Mexican Grill’s prior "Government Affairs Engagement Policy."
• The move comes ahead of the midterms, which are expected to be hotly contested.

Chipotle Mexican Grill has filed paperwork to form a political action committee, marking a shift in how the burrito chain engages in US politics.

The filing, a Statement of Organization submitted to the Federal Election Commission early this month, establishes a corporate PAC, a vehicle that allows companies to collect voluntary political donations from employees and executives and give that money to federal candidates.

Two corporate governance and political campaign finance experts said that, for a consumer-facing brand that has previously kept its distance from direct campaign giving, the move signals a more formal and proactive approach to federal politics — just as the 2026 midterm elections are heating up.

The decision also represents a departure from Chipotle’s prior stance. In versions of its Government Affairs Engagement Policy dating from 2021 and 2024, the company said it did not operate a PAC, though it noted that it could form one in the future.

"As Congress debates critical issues in 2026, the PAC is a meaningful way to give our 130,000 employees a voice in the political process that impacts their lives, communities, and our business, on a day-to-day basis," Laurie Schalow, Chipotle’s Chief Corporate Affairs Officer, told Business Insider.

Why now?

The timing of Chipotle’s move is notable. The 2026 midterm elections are expected to be exceptionally competitive, in part because several states have undertaken mid-decade redistricting — a move that can make races more unpredictable and more expensive.

"When elections are heavily contested, they tend to cost more money," Ciara Torres-Spelliscy, a professor of law at Stetson University College of Law and a Brennan Center fellow, told Business Insider. "Candidates for Congress are subject to hard money limits, so they may want money from corporate PACs to run their campaigns."

Corporate PACs can also serve longer-term strategic goals. Companies may give to lawmakers with influence over issues that affect their business, or to candidates they believe will appoint regulators aligned with their interests.

"Rather than just lobbying, a PAC allows a company to directly influence the election of officials, ensuring that legislators understand the company’s specific business interests," Anat Alon-Beck, an assistant professor at Case Western Reserve University School of Law, whose research focuses on corporate law and governance, said.

While corporate PACs are common across many sectors, restaurants have historically been smaller players in federal campaign finance. Trade groups like the National Beer Wholesalers Association and companies like American Crystal Sugar have been among the more active PACs in the food and drink space, but restaurant brands themselves have not ranked among the top corporate PAC spenders.

That context makes Chipotle’s filing less about joining a dominant political force and more about signaling a shift in posture.

By forming a PAC, Chipotle’s strategy is a more direct and structured way to engage with federal candidates at a moment when control of Congress is likely to be up for grabs. What remains to be seen is how active the PAC will become — and which candidates it ultimately supports.

Some clues can be found in Chipotle’s previous government affairs contribution reports, which outline the company’s contributions to political organizations and in support of state and local ballot measures.

In 2023 and 2024, Chipotle as a company gave $50,000 each to both the Democratic and Republican Governors Associations and $25,000 to the Democratic Mayors Association. It also made annual contributions of $150,000 to the National Restaurant Association, in addition to $625,000 in 2024 and $408,000 in 2023 to Save Local Restaurants, a coalition led by the National Restaurant Association to lobby for pro-restaurant legislation.

The National Restaurant Association has its own PAC that has historically donated primarily to Republican candidates, according to OpenSecrets data.

How corporate PACs work

Corporate PACs — formally known under federal law as "separate segregated funds" — exist because corporations are barred from donating money from their own treasuries directly to federal candidates.

"That ban comes from the Tillman Act of 1907," Torres-Spelliscy said. "To avoid that ban, corporations ask people who are associated with the company, typically executives, to donate up to $5,000 to the corporate PAC."

Those funds can then be donated directly to candidates within federal contribution limits — $5,000 per candidate per election if the PAC contributes to at least five candidates, or a maximum of $3,500 if the PAC supports fewer than five candidates.

One advantage of corporate PACs, Torres-Spelliscy said, is transparency. "Everyone who donates knows that the money is going into politics," she said. "And the public can see who has given to the corporate PAC and who the corporate PAC has donated money to."

Since 2010, corporations have also been able to spend money through Super PACs, which can accept unlimited funds — including corporate treasury money — as long as they operate independently of candidates. Creating a Super PAC requires a separate filing with the FEC, which Chipotle had not submitted at the time of publication.

"The catch is a Super PAC spends money independently of a candidate," Torres-Spelliscy said.

That independence can be a drawback for companies that want a more direct relationship with lawmakers. While Super PACs allow for far larger sums, they can’t coordinate with campaigns or give directly to candidates.

In practice, the biggest corporate donors to Super PACs in recent election cycles have come from industries like cryptocurrency and fossil fuels — not restaurants or food companies, according to data from OpenSecrets.

"A corporation may still want to have a corporate PAC if it wants to make donations directly to federal candidates," Torres-Spelliscy said.

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