Digital imprints were introduced for the whole of the UK in the Elections Act 2022, coming into force in November 2023, but digital imprints have been required in Scotland since the 2014 Independence referendum and in all devolved Scottish elections since 2020.[1]

ERS has long advocated for the extension of the imprint regime to digital election material. Digital imprints, stating who has paid for and promoted content, are aimed at enhancing transparency about who is behind online campaign material. Recognition of the need for voters to know who is trying to influence their vote online, and to be able to hold those seeking to persuade them to account after the election was a key driver of the imprint scheme. Imprints were also considered useful for the Electoral Commission in its monitoring and enforcement work.

Imprints are designed to inform the public about who is behind a campaign ad that they see online, such as on social media, websites and videos. The current rules apply to paid-for political material and some ‘organic’ content (if it is produced by a regulated participant such as a political party, candidate or third-party campaigner). ‘Political material’ is material ‘whose sole or primary purpose can reasonably be regarded as intended to influence the public, or any section of the public, to give support to or withhold support’[2] from political parties, candidates or referendum outcomes amongst others. The rules do not apply to private individuals posting content.

The Representation of the People Bill seeks to extend the imprint rules to organic material produced by third-party campaigns that are not registered with the Electoral Commission (because they are spending under the threshold for registration) but that are still producing campaigning material.

The UK-wide imprints regime applied first to the 2024 local elections and subsequent 2024 General Election. Having been in place for these elections we have initial data on how the scheme operates in practice.

Compliance

The imprint rules are enforced by the Electoral Commission and police. Failing to comply is an offence under section 48(1) of the Elections Act 2022.

Research looking at compliance with the statutory guidance on digital imprints during the 2024 General Election finds that there is significant variety in application.[3] The research finds that 68.9% of campaign material which required an imprint carried some form of imprint, but only 5.7% of material met all of the requirements as set out by the Electoral Commission (that it was present within the material, visible and legible). Half of the material which had some form of imprint, had one that was accessible (if you click through) but not included within the main material, and 37.7% of imprints were not legible (mostly due to tiny text).

What imprints can do… and what they cannot

Imprints can provide voters with basic information about the source of what they see and an indication of whether what they are viewing is campaign advertising. This can be useful in helping voters identify ‘native advertising’ techniques where ads are made to look like journalism or individual posts providing voters with a way to spot content designed to sway their opinion.[4] As currently designed, imprints enable voters to know if the material is designed and promoted to influence the outcome of an election. 

However, there are limitations to what imprints reveal to voters about the source of the content they see. Campaign material may have partisan or financial links which are not revealed by the imprint (even if it complies with the rules). For imprints, the ‘source’ is the organisation or person directly responsible for placing/distributing the material, but this source information does not necessarily reveal other affiliations, partisan goals or financial backers.

A lack of clarity on the ‘true’ source of material in this way can be used to gain advantage. Studies of the effect of badging and imprints on campaign material show that material which is labelled as non-partisan but nevertheless is making partisan claims (what the researchers term ‘clandestine campaigning’), can gain an advantage because it by-passes viewers partisan cues.[5] Whilst these observed effects are smaller when comparing ‘clandestine campaigning’ material to those with an imprint, than when it is compared to material ‘badged’ with party labels, it does suggest that the effects of the imprint regime should be monitored closely.

Comprehensive source information would ideally enable voters to establish the independence of the campaign to understand its motivations and therefore credibility.

Likewise, imprints cannot tell voters about the veracity of the claims they see online and nor can they prove the trustworthiness of the campaigner – only that the campaigner has complied with the electoral law in this area. For third parties who are registered with the Electoral Commission, the imprint would signify that the organisation is subject to further disclosure requirements on donations and spending, and would also provide voters with a route to finding out more about those campaigns via the Electoral Commission. This further monitoring may provide a shortcut to establishing a level of trustworthiness for voters (though this would require voters to have knowledge of campaign regulations) but would not apply in the case of unregistered campaigns.

Imprints cannot deal with wider issues of disinformation and the potential for electoral information incidents for which much wider measures are needed.[6]

Ad libraries

An online ad repository or ‘library’ would assist with improving transparency around digital campaigning. This would allow both the public and regulators to view ads across all platforms and help to identify campaigns that are designed to mislead the audience about their source.

The Committee on Standards in Public Life, Committee on Democracy and Digital Technology, and many campaigners have called for a comprehensive advert repository.[7] Whilst some platforms have provided ad libraries voluntarily, the information is of varying accuracy, and not all platforms provide this information.

A comprehensive public repository should capture at a minimum: the material, who has paid for the ads, exactly how much was spent, the target audience and methods for targeting. This could draw upon EU regulations which established a public ad library (Regulation (EU) 2024/900) or the Latvian model which requires platform companies to submit contract information, make prices public and keep a record of all adverts.[8]

 

End Notes

[1] The original Scottish imprint regime differed from the UK Elections Act provisions but was replaced in The Scottish Elections (Representation and Reform) Act 2025 with rules that mirror the UK-wide ones in all but one aspect. The new Scottish regulations extend imprint requirements to unpaid for (organic) digital material that is promoted by third-party campaign groups that are not regulated non-party campaigners (e.g. campaigners not registered with the Electoral Commission).

[2] Electoral Commission, Statutory Guidance: https://www.electoralcommission.org.uk/statutory-guidance-digital-imprints/what-sort-material-requires-imprint/political-material

[3] Dommett, K., Luke, S., Gordon, H., (2025) Making elections more transparent? Lessons from the Implementation of digital imprints at the 2024 UK General Election, Policy Studies, published online: 03 April 2025. https://www.tandfonline.com/doi/full/10.1080/01442872.2025.2482869

[4] Electoral Reform Society, Gordon, H., Digital imprints: what are they and why are they useful? https://electoral-reform.org.uk/digital-imprints-what-are-they-and-why-are-they-useful/

[5] Stafford, T., Gordon, H., Zhu, J., & Dommett, K. (2025). Online political adverts: The effect of disclosures and opportunities for clandestine campaigning. Political Psychology, 46, 722–748. https://doi.org/10.1111/pops.13034

[6] See for example Electoral Reform Society, Democracy in the Dark: Digital Campaigning in the 2019 General Election and Beyond, 2020. Available at: https://electoral-reform.org.uk/latest-news-and-research/publications/democracy-in-the-dark-digital-campaigning-in-the-2019-general-election-and-beyond/#sub-section-5 and, DEMOS, Epistemic Security Briefing, 2026. Available at: https://demos.co.uk/wp-content/uploads/2026/01/Epistemic-Security-Brieifing_The-Elections-bill_2026.pdf

[7] See for example Full Fact House of Lords Select Committee on Democracy and Digital Technologies, Report of Session 2019–21, ‘Digital Technology and the Resurrection of Trust https://committees.parliament.uk/publications/1634/documents/17731/default/

[8] International IDEA, Regulating Online Campaign Finance: Case Study on Latvia 2022. Available at: https://www.idea.int/news/how-successfully-regulate-online-campaign-finance-some-lessons-latvia

The Representation of the People Bill will bring in once-in-a-generation changes to our democracy – but misses a big opportunity to live up to its name and replace Westminster’s outdated and distorting voting system with fair and proportional elections.

The last general election was the most disproportional in British history. That situation could get worse at the next general election as our two-party system struggles to cope with the new reality of five and six-party politics.

We welcome the government’s move to scrap First Past the Post for mayoral elections, but the same rationale should apply to Westminster elections.

Disproportionality

The General Election in 2024 was not only the most disproportional election in British electoral history but one of the most disproportional seen anywhere in the world. 

Disproportionality is measured by a DV (Deviation from Proportionality) score. On the Loosemore-Hanby measure,[1] the 2024 General Election scored 30.1. This beats the previous high score, at the 2015 general election, of 24. But 2024 was also the most disproportional across a range of DV measures.

Multi-party voting

The 2024 General Election was the first in which four parties gained over ten percent of votes and five parties over five percent of votes. Labour and the Conservatives recorded their lowest combined vote share (57.4%) in the era of universal suffrage, with other parties and independents taking over 40 percent of the votes.

Yet First Past the Post is an electoral system designed for a two-party system. When more parties are in contention, as is the case when voters spread their choices across multiple parties, the winner’s share of the vote is often reduced. As a result, winning candidates regularly get across the line with less than a majority of votes and occasionally, less than a third of constituency support.

Chart shows the percentage of the vote won by the winning candidate in each constituency, by party. All the dots to the left of the middle line are constituencies won on less than 50% of the vote.

Many more seats are seeing more than two parties get sizable vote shares, which, under FPTP, reduces the eventual mandate for the winning candidate.

Unrepresented voters

Some parties will find their votes piling up in safe seats (surplus votes) and some parties will see more of their vote going to candidates who aren’t elected (unrepresented). This is because under First Past the Post, geography plays an outsized role in determining results, rewarding an efficient geographical vote spread over vote share.

In the 2024 General Election, 57.8 percent of voters (16.6 million) were unrepresented, and 15.9 percent of votes (4.6 million) were surplus. That’s a total of 73.7 percent of votes disregarded in 2024: 21.2 million votes. The last time we saw a similar percentage of votes ignored in this way was in 2015 – another election characterised by significant multi-party voting.

Importantly, not all electoral systems treat votes in this way. Some systems take a second or third preference into account if a voter’s first preference isn’t elected, and others ensure that more preferences count in the first place, sharing seats out proportionally over a larger area.

Developments since the 2024 General Election

Multi-party politics is showing no sign of retreat. The Projected National Share (PNS) calculations from the May 2025 English local elections showed five parties getting over 10% of the vote – another first.[2]

Sitting alongside this is an increase in, and increased likelihood of representatives being elected with fewer than 30% of votes, under FPTP. In May 2025, two out of four Strategic Authority mayors up for election were returned with the support of fewer than 30% of those who voted. A YouGov MRP in June 2025 predicted a General Election in which record numbers of seats return winners with small proportions of the vote – 143 constituencies are won on less than 30% in their analysis.[3]

Multi-party politics under FPTP – a system designed for two party competition – is always going to lead to warped electoral outcomes. As the electoral landscape continues to shift, we are likely to see ever more disproportional results. The case for changing the voting system at Westminster has never been clearer – people deserve a parliament that reflects how they have voted.

Electoral Reform Society, ‘A System Out of Step’, General Election 2024 analysis: https://electoral-reform.org.uk/latest-news-and-research/publications/a-system-out-of-step-the-2024-general-election

Public Support

According to the most recent British Social Attitudes survey, released in February 2026, the majority of people (53%) in Britain want to change the voting system for general elections and this majority support for change has been seen in every BSA survey since 2021.

A National Commission on Electoral Reform

The All-Party Parliamentary Group for Fair Elections has called for a National Commission on Electoral Reform.[4]

The National Commission is a proposal for a time-limited independent review, informed by the evidence of experts and the values of the voting public to consider the criteria for a suitable voting system for Westminster. The Commission would then present Parliament with a set of carefully evidenced recommendations.

This proposal sets out a way to bring in both broad and independent expertise and the views of voters to the question of what type of electoral system we should be using for UK general elections. This is an urgent question given the unprecedented degree to which multi-party politics now exists in our country.

 

End Notes

[1] The Loosemore-Hanby (L-H) index looks at the deviation between each party’s vote share and its seat share. If a party obtains 25% of the votes and 20% of the seats, the deviation is 5. The index adds up the absolute values of these deviations across all parties running in the election and divides the total by two. The higher the number the greater disproportionality.

[2] BBC https://www.bbc.co.uk/news/articles/cd925jk27k0o

[3] YouGov, June 2025, MRP. https://yougov.co.uk/politics/articles/52437-first-yougov-mrp-since-2024-election-shows-a-hung-parliament-with-reform-uk-as-largest-party

[4] APPG for Fair Elections, ‘National Commission on Electoral Reform: Terms of Reference’, 2025

https://www.fairelections.uk/national-commission/

The Representation of the People Bill is a major step forward for our democracy. It will give more young people a say, modernise our outdated registration system and strengthen rules around campaign finance. These are reforms the Electoral Reform Society has campaigned for over many years – important changes that will help make our elections fairer and remove barriers to voters participating.

It is important that the ambitions of this bill are secured in practice by ensuring that votes at 16 and a modernised registration system are delivered in time for the next General Election; that changes to the voter ID scheme help those most impacted and ensure that no eligible voter is prevented from voting in future; that political finance measures are robust enough; and that our elections regulator is independent of government and equipped to enforce the rules.

Part 1 – Young Voters

Extending the franchise is an opportunity to nurture more active citizens for the future. By giving 16- and 17-year-olds a vote we can engage the next generation in politics and improve the future health of our democracy.

Research has shown that the younger people are engaged in voting, the more likely they are to carry on voting later in their lives and that enfranchised 16- and 17-year-olds also tend to turnout to vote in greater numbers than those voting for the first time aged 18 and over.[1] This is likely because younger voters are better supported through their first experience of voting whilst they are at home and in education.

There is also some evidence to suggest that inequalities in participation are reduced. In Scotland, newly enfranchised young people of all social groups were equally likely to be politically engaged.[2] In Wales, gender gaps in perceived political knowledge (seen in all other age groups) were not present amongst 16- and 17-year-olds.[3]

Votes at 16 has potential to improve democratic participation for the future.

To ensure votes at 16 realises these positive democratic impacts it is vital that younger people are supported through democratic education. Democratic education can provide younger voters with the confidence, efficacy and interest to get involved at the same time as gaining the right to vote increases young people’s desire to learn about political issues.

It is also vital that modernisations to voter registration are made to ensure that young people (who are the least likely to be registered) do not miss out, and that they are supported with early awareness and information campaigns. Lessons from the introduction of votes at 16 in Wales show the importance of early interventions on awareness, registration and mobilisation.[4]

Automatic voter registration, improved voter engagement and democratic education can help make votes at 16 a major moment of democratic change and renewal in the UK.

Enfranchising 16- and 17-year-olds would not drastically change the electoral landscape[5] (evidence from around the world shows that young people have diverse attitudes, do not vote as a uniform bloc and do not change the broader political landscape) but it would allow young people to have a voice in the decisions that are made for them every day at local, regional and national level.

For more information on Votes at 16: https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/briefing-on-votes-at-16-2026/

 

Part 2 – Registration of Voters

Comprehensive and accurate electoral registration is central to democratic participation. It is vital therefore that all possible steps should be taken to ensure everyone who is eligible to vote is registered. Registration without application, a more automatic form of registration, is a much-needed improvement to our outdated voter registration system.

The Electoral Commission’s most recent analysis of electoral registers estimated that between 7 and 8 million people are missing from the electoral rolls.[6] ERS constituency estimates based on these findings suggest that, in some places, as much as 20% of the total eligible population is likely to be missing from the register.[7] [For our interactive constituency map visit: https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/automatic-voter-registration-avr-briefing/]

Completeness has remained fairly static over time and the Electoral Commission has stated that, ‘there is little evidence to suggest that levels of accuracy and completeness are likely to significantly improve without major changes to the current electoral registration system.’[8]

81% of British people support automatically registering voters with 48% strongly supporting this change.[9]

Not only are millions missing from the electoral rolls but those missing are unequally distributed across society. Research suggests that the current system of registration is proving a barrier, particularly to young people and people in privately rented accommodation. In 2022, 65% of private renters were registered compared to 95% of owner occupiers and 88% of those with a mortgage; only 60% of 18- and 19-year-olds were registered compared to 96% of those aged 65 and over and only 16% of attainers (those aged 16 and 17 in England) were registered.[10]

Most countries use a form of automatic registration[11] and pilots of automatic registration in Wales have shown how much it can improve completeness of the registers (even when restricted to local data).[12] Changes to the annual canvass have already moved the UK’s system closer to automatic registration with EROs using data-matching as an integral part of the registration process and re-registering those who can be reliably matched.

Registration without application has great potential to improve voter registration and ensure that every eligible voter can participate. But it is essential that progress is made quickly to establish pilots and move to registration without application so that at the next General Election millions do not miss out.

For more information on modernising registration: https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/briefing-on-modernising-electoral-registration/

 

Part 3 – Conduct of Elections

s47 – Voter identification requirements

The introduction of photographic ID in the Elections Act 2022 has, to date, prevented over 42,000 people casting their vote. Despite little evidence to suggest voter ID was needed, the current scheme is highly restrictive with only a handful of IDs accepted (many of which need to be paid for). Expanding the types of IDs that will be accepted is a welcome move.

Out of all alleged cases of electoral fraud in the 2019 elections, only 33 related to personation fraud at the polling station[13] – this comprises 0.000057% of the over 58 million votes cast in all the elections that took place that year. Only one of those allegations resulted in a conviction, and one a caution.[14] Despite this, the voter ID scheme introduced in the Elections Act 2022 is highly restrictive (compared to other countries that do not have a national ID card) with only a limited number of photographic IDs deemed acceptable and no alternatives for voters who turn up without ID.

The Electoral Commission reported that in the 2024 General Election around 16,000 electors attempted, but were unable to vote due to the Voter ID requirement; this equates to 1 in every 1,200 voters.[15] Similarly, the May 2024 local and mayoral elections reported around 13,000 electors attempted to vote but were turned away because they lacked accepted ID and did not return; in the May 2023 local elections this figure was around 14,000.[16]

Across the first three sets of elections using Voter ID, at least 42,368 voters were denied their right to vote.*[17] [18]

In addition, many voters appear to have been put off by the new requirement. According to the Electoral Commission, when given a list of options, 10% of non-voters gave voter ID as the reason that they did not vote in the 2024 General Election, this figure was 4% when unprompted. Ipsos polling also found that 8% of people said that voter ID made them less likely to want to vote in the May 2023 local elections.[19]

Only 25,000 Voter Authority Certificates were used as ID in local elections in 2023, 22,749 at the local and mayoral elections in 2024 and 72,497 in 2024 General Election. This is far fewer than the number of registered voters who are estimated to need one (around 750,000).[20]

Increasing the range of acceptable identity documents, including non-photographic ID, would make the scheme more proportional. The Cabinet Office report ‘Securing the ballot’, which first suggested introducing ID, recommended that: ‘There is no need to be over elaborate; measures should enhance public confidence and be proportional.’[21] When voter ID was first introduced in Northern Ireland it was not solely photographic ID and elections took place for almost 20 years with this less stringent requirement.

Allowing IDs like bank cards and digital ID, which voters are likely to be carrying on them, will help voters who do not have access to the more restricted forms of ID and make it easier for all voters on the day.

Improvements to prevent any more eligible voters losing their right to vote are essential, but we will only know if these improvements are working if we have records of who is turned away at the polling station. It is critical that the impact of voter ID is monitored and reported to ensure that we have a full picture of how this policy is affecting voters and whether further changes, such as vouching or statutory declarations, are needed.

For more information on Voter ID: https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/briefing-on-voter-id-2026/

Part 4 – Campaigns and Political Donations

s58-s62 – Control of political donations

The role of money in politics is fundamental to the quality of our democracy. Today in our democracy, voters can readily see that those with deeper pockets have more of a say, and this corrodes public confidence. It is vital that we provide greater protection from foreign interference and corruption, and importantly, provide voters with more reason to feel confident that their voices matter.

S60 – donations by companies: The risk of shell companies being used to funnel foreign funds into UK politics was first identified as a risk prior to PPERA.[22] It is very welcome therefore that this bill seeks to address this vulnerability by requiring donor companies to demonstrate they have made sufficient funds in the UK and have a UK connection. However, a UK profit test (instead of revenue) would provide stronger protection in this regard.

s62 – Unincorporated Associations: Donations from Unincorporated Associations (UAs) present a well-documented gap in the UK’s political finance transparency requirements. A lack of transparency around the source of UAs’ political donations undermines efforts to have an open and transparent political finance regime and with few safeguards to prevent impermissible donations, UAs are a potential conduit for foreign funding entering UK politics. It is therefore welcome that this bill seeks to address these issues by introducing permissibility checks, increasing reporting requirements and lowering the contribution thresholds for triggering reporting, as well as extending the rules to candidate donations. However, at £11,180, the threshold for reporting is still high – especially if this same threshold applies to candidate donations.

Donations cap

Over time, both the total amount of donations and the number of very large donations (those over £1 million) from private sources have increased. The extent to which parties are reliant on a handful of very wealthy donors is recognised by the public and is a cause for concern. YouGov finds that 60% of people think that wealthy donors give money to gain influence compared to the 6% who this it is driven by support for the party. [23] Only 13% of people think that there should be no limits on how much people can give in political donations.[24]

In 2011 the Committee on Standards in Public Life produced a report addressing the problems of an increased reliance on significant donations. In their report the Committee said, ‘Over the last few decades all three main parties have instead become dependent on a small number of relatively large donations from individuals, trade unions (for the Labour Party) or other organisations. This dependency has inevitably created a risk that favours will be asked or given in return.’ The CSPL recommended a cap of £10,000 for donations from a single source in a year and for trade union donations to be treated as an aggregation of individual donations subject to opt-in rules.[25]

Since that report, the key problems identified have intensified. Our politics is too reliant on too few, and the sums involved are simply too large. Reducing the amount that single private sources can give to parties not only helps create a fair democratic contest but also protects parties and their representatives.

A donations cap would prevent a small number of wealthy donors dominating political finance, would reduce corruption risk, and is popular with the public.[26]

For more information on political finance: https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/briefing-on-political-finance/

s63-s64 – Information to be included with electronic material

The Electoral Reform Society has long advocated for the extension of the imprint regime to digital election material. Digital imprints, stating who has paid for and promoted content, are aimed at enhancing transparency about who is behind online campaign material. Voters should know who is trying to influence their vote so they are able to make an informed decision at the ballot box, and to hold those seeking to persuade them to account after the election.

Whilst an extension of the current regime is welcome, imprints alone do not provide voters with the full picture. An online ad repository or ‘library’ would assist with improving transparency around digital campaigning. This would allow both the public and regulators to view ads across all platforms and help to identify campaigns that are designed to mislead the audience about their source.

Part 5 – Enforcement and the Electoral Commission

s67 Abolition of maximum penalties in respect of offences triable summarily

An increase to the maximum fine that the Electoral Commission can impose is a welcome step. Currently limited to a maximum individual fine of £20,000, these fines can simply be seen as the ‘cost of doing business’. Multiple parliamentary committees, civil society organisations and campaigners have called for the Commission’s fines to be increased in recent years to provide an effective deterrent.[27] For comparison, the ICO is able to fine organisations up to four percent of global turnover, or £17 million.[28]

Electoral Commission independence

The 2022 Elections Act introduced a requirement for the Electoral Commission to ‘have regard to’ a strategy and policy statement set by ministers which reflects the government’s policy priorities and set out the ‘roles and responsibilities’ of the Commission in achieving those priorities. The Commission must now report annually against that statement to the Speaker’s Committee. A significant imposition on regulatory autonomy.

Electoral management body independence is set out under international law and in a range of international guidelines (such as the OSCE’s Office for Democratic Institutions and Human Rights guidance and the Council of Europe Venice Commission code of practice).

The change brought in under the 2022 Act was criticised by two different international electoral observer missions during the 2024 General Elections.[29] The Electoral Commission have themselves been highly critical of the change noting that allowing government to guide its work, ‘is inconsistent with the role that an independent electoral commission plays in a healthy democracy.’[30] In addition, there is nothing to prevent a government majority on the Speaker’s Committee through which the Electoral Commission is directly accountable to parliament.

The Strategy and Policy Statement and lack of safeguards create a very dangerous set of instruments that could seriously damage electoral integrity.

It is critical that the Electoral Commission’s independence is restored by removing the strategy and policy statement provisions in part 3 of the Elections Act 2022. It is also important to ensure that the Speaker’s Committee remains cross-party, and this could be strengthened by inviting ordinary ‘lay’ members of the public to join the committee (much like Parliament’s Standards Committee) and putting in place measures to prevent any party having a majority on the committee.

 

For more information on any of the issues in the briefing please contact ERS@electoral-reform.org.uk

 

 

[1] Huebner, C., and Eichhorn, J., ‘Evidence and Good Practice on Lowering the Voting Age to 16’. https://www.jrrt.org.uk/wp-content/uploads/2025/01/Votes-at-16-report-FINAL.pdf

[2] Huebner, C. & Eichhorn, J. (2022). The Tide Raising all Boats? Social Class Differences in Political Participation among Young People in Scotland. Scottish Affairs, 31(2), 165-189.

[3] Griffiths, J. D., Larner, J., Wyn Jones, R., & Poole, E. G., (2025) ‘A False Start: Votes-at-16 in Wales in the 2021 Senedd Cymru election’, Wales Governance Centre.

[4] Huebner, C., Smith, K. A., Mycock, A., Loughran, T., & Eichhorn, J. (2021). ‘Making Votes-at-16 Work in Wales. Lessons for the Future’ (pp. 1–34). Nottingham: Nottingham Trent University. https://www.ntu.ac.uk/media/documents/nce/Huebner-et-al_2021_Making-Votes-at-16-work-in-Wales.pdf

[5] ONS Research in 2017 showed there was around 1.5 million 16- and 17-year-olds in the UK (the current figure stands at 1.6 million). If enfranchised this group would make up around 3% of the voting age population. The small size of this cohort would have little impact on vote shares even if they achieved 100% turnout and all voted the same way. https://www.ons.gov.uk/peoplepopulationandcommunity/elections/electoralregistration/articles/whatimpactcouldloweringtheukvotingageto16haveontheshapeoftheelectorate/2017-07-14

[6]  The Electoral Commission, “2023 report: Electoral registers in the UK”, 2023. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/accuracy-and-completeness-electoral-registers/2023-report-electoral-registers-uk

[7] (Cities of London and Westminster (20.3%), Leeds Central and Headingley (20.2%), Bristol Central (19.6%), Sheffield Central (19.5%)).[7] Estimates are based on ONS 2021 Census and Scottish Census 2022 population figures and Electoral Commission data on registration levels by housing tenure. https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/automatic-voter-registration-avr-briefing/

[8] Electoral Commission ‘2023 report: Electoral registers in the UK’, 2023

Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/2023-report-electoral-registers-uk

[9] https://yougov.co.uk/politics/articles/49960-what-electoral-reform-proposals-would-britons-support

[10] Electoral Commission, ‘Who is and isn’t registered to vote’, 2022. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/explore-data-who-and-isnt-registered-vote

[11] Toby. S. James and Paul Bernal (2020) Is it time for Automatic Voter Registration in the UK? Joseph Rowntree Reform Trust: York. https://www.jrrt.org.uk/wp-content/uploads/2020/04/Is_it_time_for_AVR_in_the_UK.pdf

[12] Electoral Commission, ‘Automatic registration pilots evaluation’, 2025. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/automatic-registration-pilots-evaluation

[13] Uberoi and Johnstone, “Political disengagement in the UK: Who is disengaged?”, House of Commons Library, 2022. Available at: https://researchbriefings.files.parliament.uk/documents/CBP-7501/CBP-7501.pdf

[14] Electoral Commission, “2019 Electoral Fraud Data”, 2020. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-fraud-data/2019-electoral-fraud-data

[15] Electoral Commission, “Voter ID at the 2024 UK general election”, 2024. Available at:  https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-2024-uk-general-election

[16] Electoral Commission, “Voter ID at the May 2023 local elections in England: interim analysis”, 2023. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-may-2023-local-elections-england-interim-analysis

[17] Ibid.

* Those recorded as having been turned away and did not return at the 2023 local elections, 2024 local and mayoral elections and 2024 General Election combined. The 2024 General Election was the last election in which returning officers were legally required to collect these statistics.

[18] Electoral Commission, “Voter ID at the 2024 UK general election”, 2024. Available at:  https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-2024-uk-general-election

[19] Ipsos UK, “Written evidence (VID0010) House of Lords Constitution Committee inquiry into voter ID”, 2023. Available at: https://committees.parliament.uk/writtenevidence/126939/pdf/

[20] The Electoral Commission, “Voter ID at the May 2023 local elections in England: interim analysis”, 2023. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/report-may-2023-local-elections-england

[21] Cabinet Office, ‘Securing the Ballot: review into electoral fraud’, 2016. https://www.gov.uk/government/publications/securing-the-ballot-review-into-electoral-fraud

[22] Committee on Standards in Public Life, fifth report, ‘The Funding of Political Parties in the United Kingdom’, 1998. Available at: https://assets.publishing.service.gov.uk/media/5a7daa32e5274a5eaea6596a/5thInquiry_FullReport.pdf

[23] YouGov, 23 September 2024, 4046 GB adults: ‘Do you think that wealthy people make donations to individual politicians more because they support them and want them and their party to succeed, or more because they are trying to gain influence?’ https://yougov.co.uk/topics/politics/survey-results/daily/2024/09/23/a132c/1

[24] YouGov, biannual tracker at 29 December 2025, 1668 – 1804 GB Adults: ‘Should there be a limit of donations made to political parties by individuals?’

https://yougov.co.uk/topics/politics/trackers/should-there-be-a-limit-of-donations-made-to-political-parties-by-individuals

[25] Committee on Standards in Public Life, thirteenth report, ‘Political Party Finance: ending the big donor culture’, 2011. Available at: https://www.gov.uk/government/publications/political-party-finance-ending-the-big-donor-culture

[26] For example: Poll by Survation on behalf of 38degrees, cited in PoliticsHome, ‘Strong Support For Bringing In A Cap On Political Donations’, 23 Dec 2025. https://www.politicshome.com/news/article/strong-support-for-cap-on-political-party-donations-poll-shows; Electoral Reform Society, ‘Deal or No Deal’, https://www.electoral-reform.org.uk/wp-content/uploads/2017/06/Deal-or-no-deal-Party-Funding.pdf

[27] See, for example,  Electoral Reform Society, ‘Reining in the Political ‘Wild West’: Campaign Rules for the 21st Century’, 2019. https://www.electoral-reform.org.uk/latest-news-and-research/publications/reining-in-the-political-wild-west-campaign-rules-for-the-21st-century/#sub-section-9

[28]See, for example,  Electoral Reform Society, ‘Reining in the Political ‘Wild West’: Campaign Rules for the 21st Century’, 2019. https://www.electoral-reform.org.uk/latest-news-and-research/publications/reining-in-the-political-wild-west-campaign-rules-for-the-21st-century/#sub-section-9

[29] Commonwealth Parliamentary Association, ‘Final Report CPA BIMR Election Assessment Mission’ (pages 8/9) https://www.uk-cpa.org/media/gyskl0w3/final-report-cpa-bimr-election-assessment-mission-uk-general-election-2024.pdf

OSCE office for Democratic Institutions and Human Rights, ‘United Kingdom, General Election, 4 July 2024: Final Report’, 2025 (Page 10) https://www.osce.org/odihr/elections/uk/592972

[30] Electoral Commission, Letter from Commissioners: Strategy and Policy Statement measures in the Elections Bill, February 2022. Available at: https://www.electoralcommission.org.uk/news-and-views/key-correspondence/letter-commissioners-strategy-and-policy-statement-measures-elections-bill

The role of money in politics is fundamental to the quality of our democracy. Parties need money to function, but the greater the influence of the wealthy few funding politics, the smaller the voice of ordinary voters. Today in our democracy, voters can readily see that those with deeper pockets have more of a say, and this corrodes public confidence. A more robust political finance framework would provide greater protection from foreign interference and corruption, and importantly, provide voters with more reason to feel confident that their voices matter.

Political finance regulations are based around three fundamental principles: Transparency, Fairness and Accountability. This briefing considers each of these principles and how well the current UK regulations meet them, with recommendations for building a more secure political finance framework.

Transparency

Principle: The public should know where money comes from and how it is spent in connection with electoral events.

Transparency is a fundamental principle of political finance regulation. Firstly it provides voters with information on who is backing political parties and candidates, and what parties and candidates are spending the funding on; How, for instance, those funds are being used to win their vote. If provided in a timely manner this can help voters decide how they will cast their vote. Secondly, it enables the regulator to ensure that the rules are being met, providing essential information for compliance and accountability. And thirdly, an open and transparent political funding environment provides a strong deterrent to corruption.

Transparency in political finance is recognised internationally through the United Nations Convention against Corruption (UNODC 2005, Article 7.3) and the OSCE-ODIHR / Venice Commission guidelines on political party regulation.[1]

Most countries have reporting and transparency requirements and these can help build trust in democratic institutions. Strong measures to prevent wealthy interests unduly influencing electoral outcomes is essential in creating a democracy where all voters are valued not just those with the deepest pockets.

Public perceptions of transparency in the system have, until recently, been in decline. By 2022, only 13% of the public agreed that ‘the spending and funding of political parties, candidates and other campaigning organisations at elections are open and transparent’. This figure has since increased, to 18% in 2025, but is still far lower than the 37% who felt the system was open and transparent in 2011.[2]

Recommended regulatory methods to achieve transparency

• Identifying and making public all funding sources including donations, donors, loans and gifts, with their amounts and dates.
• Requiring reporting and supporting documentation for expenditures (political parties, candidates and non-party campaigners).
• Timely and accessible public disclosure of information.

Gaps in the UK regulatory framework

Unincorporated Associations

Donations from Unincorporated Associations (UAs) present a well-documented gap in the UK’s political finance transparency requirements. A lack of transparency around the source of UAs’ political donations undermines efforts to have an open and transparent political finance regime and with few safeguards to prevent impermissible donations, UAs are a potential conduit for foreign funding entering UK politics.

Unincorporated Associations are small, non-profit organisations such as voluntary groups or sports clubs that sit outside of the formal registrations processes that companies and charities must follow. Whilst UAs can donate to political parties, the rules governing these donations differ from other political donations.

Currently, Unincorporated Associations must register with the Electoral Commission if they make political donations totalling more than £37,270 in a calendar year and report gifts they receive over £11,180 (these thresholds were, prior to 2023, set at £25,000 and £7,500 respectively). Like other donations, contributions only count towards that total if they are over £500.

Unincorporated Associations are considered permissible donors and are allowed to donate to political parties if they have more than one member, have their main office in the UK and are carrying out activity in the UK. However, there are currently no requirements for those who give money to UAs to themselves be permissible donors. This opens-up the possibility of UAs being used to channel funds from impermissible sources such as overseas donors. Whilst UAs are required to disclose ‘whatever details you know of the individual or organisation that gave you each gift of more than £11,180’,[3] there is nothing to prevent the donation being made.*

* Different rules apply for UAs that are also members associations (such as groups of party members) which are considered regulated donors and must check the permissibility of their funds.

The Committee on Standards in Public Life (CSPL) considered this one of two key vulnerabilities in the donations regime: ‘That UAs are not required even to report (or, by implication, establish) full details of those who give them funds, is a significant weakness’[4]

It is clear from the lack of information provided by UAs that a considerable amount of funding is passing below the reporting requirements. Transparency International UK have found that of the £40.4 million in donations made by Unincorporated Associations since 2010 only £127,500 has been reported in the gifts register and only £1.7 million has come from UAs that are also member associations.[5] This leaves £38.6 million in party funding coming from unknown sources. Moreover, donations to candidates, rather than political parties, from Unincorporated Association are not covered by any transparency requirements.

Given that many UAs appear to be set up specifically for the purpose of making political donations, identifying and checking political funds is unlikely to present an administrative hurdle as transparency requirements would apply to all donations, but it is essential in ensuring UAs are not used to channel impermissible funds. Greater transparency around donors to UAs will however only work if the thresholds for disclosure are set at an appropriate level. Threshold for disclosure were raised by 50% prior to the 2024 General Elections.

The Committee on Standards in Public Life, Electoral Commission, and Public Administration and Constitutional Affairs Committee have all identified the need for greater checks and more transparency on political donations from Unincorporated Associations.[6] [7] [8] The CSPL has recommended addressing these gaps alongside simplifying the reporting regime by requiring UAs to conduct permissibility checks on funds that are intended for political donations, providing greater transparency around political gifts, and extending these rules to candidate donations.

Closing the transparency gap for UAs is essential for protecting political finance from overseas funding but also from vested interests. Transparency on the source of funds is essential for knowing who is funding political parties and who is seeking access and influence.

Reporting spending

Whilst donations are reported weekly during the short campaign, spending during election campaigns is only reported several months after the election. For accountability it is important that spending is monitored and checked to ensure that spending limits are being followed and that appropriate action is taken afterwards. However, for transparency, what matters is informing the public about the impact of finance on the campaign – who is paying, what is being paid for – and the timing of this information is crucial.

Party spending returns must include details of spending, invoices and receipts for payments over £200. If a party’s expenditure is £250,000 or below, the party must report within three months of the election. If a party spends over that amount, the deadline is six months. Rules for candidates are different with spending reports due within 35 days of the result. Spending in the 2024 General Election (4^th July 2024) for parties under £250,000 was reported in February 2025. Details on parties spending over £250,000 (six of the largest parties) was not reported until July 2025 – a full year later.

The Committee on Standards in Public Life report concluded in 2021 that the timescales for reporting expenditure, particularly for those spending over £250,000 are too long, and, “the delay built into the system risks reducing public confidence in the integrity of the electoral process and impacts on the timeliness with which the Electoral Commission or the police are able to take enforcement action in cases where an offence has been committed”.[9]

The CSPL recommended an initial reduction in the reporting time from six to four months for parties and campaigners spending over £250,000 and for the Electoral Commission to publish within two months of receiving a completed spending return. But also argued for the timeframes to be kept under review with the aim of reducing gradually until level with the rules for candidates (35 days after the election).

Whilst the UK’s political finance database has been ahead of the curve in terms of how much data it provides and searchability, compared to other countries, the timelines for reporting are slow. Many countries have moved to reporting either in real time or much more directly. This is important as it is during the election campaign itself that the need to inform the public is at its greatest, enabling voters to make informed decisions.  If financial information is only made available many months, even a year, after the electoral event it’s value decreases and with it, the ability to hold parties to account.

Examples of alternative approaches to financial disclosure from around the world are in Appendix A. For public information, the speed of disclosure and accessibility of online information is a priority. For accountability and oversight, speed is also relevant but internal checking might take priority over accessibility. There is usually a trade-off between accuracy and speed, however, developments in technology open up new possibilities to speed up the process, improve the information available, and provide greater transparency.

Thresholds for donation disclosure and reporting

The UK is an outlier amongst European countries (and most anglophone democracies) when it comes to thresholds for financial disclosure. Already significantly higher than the average, in 2023 the thresholds for disclosing donations were raised by 50%. The amount of money that an individual is allowed to donate to a party whilst remaining publicly anonymous rose from £7,500 to £11,180. The same rules were also changed for unincorporated associations (see above).

In the UK, only gifts to parties over £500 count as donations so any money below this amount is not subjected to the same rules (including those preventing foreign donations). Once over £500 parties must ‘take all reasonable steps to make sure you know the true identity of the donor [and] check that the donation is from a permissible source’[10] (candidates must apply these checks to donations over £50). Many have suggested that, in an age of online transactions, this threshold should be revised to prevent the splitting of larger donations into smaller amounts to avoid transparency. It has been suggested that the threshold at which a gift becomes a donation should be reduced to 1p.[11] [12]

Some countries have the same thresholds for reporting donations to the oversight body and for making those donations public, others have a two-tier system where the reporting threshold is lower than the public disclosure threshold. By international standards however, the UK’s thresholds for disclosure are high. Compared to EU member states, only Spain has a higher donation disclosure threshold of 25,000 Euros.[13] Across EU member states the average threshold for reporting is 385 Euros and for disclosure 2,400 Euros.[14]

The UK has also the highest disclosure threshold of anglosphere countries. In Canada donations over $20 need to be reported and are disclosed over $200 (or once they reach a total of $200 CAD).[15] The USA bans anonymous donations over $50 USD and discloses all donations. New Zealand requires donations over $5,000 NZD to be reported and made public.[16] Australia has a higher disclosure threshold ($17,300 AUD for 2025/26, indexed annually) but this is still lower than the UK equivalent.[17]

Typically reporting thresholds are required where there is a donation limit to ensure that the limits are not being circumvented by multiple separate donations. For instance, in Ireland, the limit for individual donations is 2,500 Euros per year and the reporting and disclosure threshold for donation to political parties is 1,500 Euros.[18]

Like the UK, Denmark does not currently have a donation limit, but does set the reporting and disclosure limit at 20,000 DKK (less than £2,500). Single or cumulative donation(s) over this amount requires disclosure of the name and address of the doner (though not the amount of the donation).[19]

Whilst there are still potential flaws in these approaches, comparatively the UK’s disclosure requirements are weak and there is little justification for the recent increase in threshold. There is significant scope to improve transparency in this area as online systems facilitate easier uploading and access, making better reporting less onerous.

Digital campaigns

The reporting of digital spend is another area where the goal of transparency is undermined by the nature of reporting. The amount spent on digital communications has grown exponentially over the last three General Elections creating new problems for transparency in political spending.[20] Research has found that spending on digital platforms increased by 50% between 2017 and 2019[21] and that over half of advertising spend in the 2019 General Election was spent on social media. However, online advertising does not constitute a separate category of spending, and supplier invoices often lack information on what the money was spent on.[22] In addition, researchers have found that in the 2019 General Election, around 14 per cent of campaign expenditure (£6.6 million) could not be categorised because the invoices were unclear.[23] A lack of detailed information means voters are unaware of the how they are being influenced.

In its 2021 report on political finance, the CSPL recommended including more information on digital spend and the Electoral Commission have also called for the change.[24]

Ad libraries

The CSPL, Committee on Democracy and Digital Technology, and many campaigners have called for a comprehensive advert repository or ‘ad library’ to allow for better scrutiny and transparency of digital campaigns.[25] Whilst some platforms have provided ad libraries voluntarily, the information is of varying accuracy, and not all platforms provide this information. A comprehensive public repository should capture at a minimum: the material, who has paid for the ads, exactly how much was spent, the target audience and methods for targeting. This could draw upon EU regulations which established a public ad library (Regulation (EU) 2024/900) or the Latvian model which requires platform companies to submit contract information, make prices public and keep a record of all adverts.[26]

Transparency on digital spend is also connected to preventing foreign interference and information security in our elections. Whilst the Elections Act 2022 reduced the scope for foreign interference through paid online ads (s89a, PPERA) the restrictions only apply to regulated periods. There is no outright ban on foreign actors buying ads but rather a restriction on the amount that can be paid under the non-party campaigner rules, with foreign campaigns not meeting any of the permitted types of non-party campaign set out in section 88 of PPERA.

Advances in technology create new opportunities to improve political finance transparency. The UK’s system has long been considered ‘world leading’ but without updates to keep pace, there is a risk of falling behind and undermining the fundamental goal of transparency.

Fairness

Principle: There should be equality of opportunity – a ‘level playing field’ – for electoral participants with the electorate enabled to vote for their preferred candidates and policies.

Unequal distribution of political funding can create skewed electoral outcomes reducing competition and limiting voter choice. Unrestricted use of financial and other resources mean unequal distributions of wealth are transferred to the political system and this threatens the principle of equal votes. For these reasons, trying to ensure a reasonably level playing field is a condition of electoral fairness and an important component of political finance regulation.

Recommended regulatory methods to achieve fairness

• Prevent distortion caused by foreign interference (either by foreign donations or election expenditure financed by foreign sources).
• Ensuring that donation and spending rules don’t unduly allow deep pockets to dominate policy formation and/or electoral campaigns. Safeguarding against undue influence and corruption by limiting size of donations or setting spending limits.

Regulations may limit campaign spending and/or limit donations to ensure that those with the deepest pockets cannot unduly dominate policy formation or electoral campaigns, as well as safeguarding against undue influence and corruption.

Over 40% of countries put a limit on how much eligible donors can contribute and around 30% limit spending by political parties (40% limit spending by candidates).[27]

Another aspect of financial controls are outright bans on donations from certain groups. Outright bans on donations or election expenditure from foreign sources are common to prevent external influence and most countries ban foreign donations as well as anonymous donations (which ensures other donation bans can be enforced). Some countries also ban donations from corporations (around one in five) and other bodies. Bans on public bodies donating to political parties are also common to avoid abuse of state resources and many countries ban donations from companies with government contracts for the same reason.

The principle of banning foreign donations applies in the UK however, in regulations, rather than a ban on certain types of donations, the legislation instead states which sources are ‘permissible’.

Gaps in the UK regulatory framework

Limits on donations

Political donations are not necessarily corrupt or made on a quid pro quo basis. Where they become problematic is if parties become reliant on a narrow range of large donors, or if they create significant financial imbalances between parties. Where this occurs, the principle of fairness is breached and the potential for corruption increases.

Over time both the total amount of donations and the number of very large donations (those over £1 million) from private sources have increased. Transparency International found that in 2023, 66% of the total £85 million in donations came from 19 ‘mega donors’ with one donor contributing one in every eight pounds donated.[28]

These trends have continued since. In the year prior to the 2024 General Election, political parties received 18 separate donations of £1 million or more. Totalling almost £41 million this represents 32% of the total party donations within that period. Of those donations, thirteen were from companies, four from individuals and only one from a trade union, but seven of the company donations (£15 million in total) came from the same company, a further four from another company, and one individual was responsible for a single donation of £10 million. In total, nearly a third of donations to political parties in the pre-election regulated period came from just nine sources.[29]

Looking at the pre-poll donations for the 2024 General Election campaign reveals that money mostly flows towards success. In the first three weeks of the 2024 short campaign the Labour party received 72% of all donations. In 2019, the Conservatives received 63% of all donations reported in the run up to polling day.[30] Another way of understanding this shift is to consider the types of donations received. In the first three weeks of the 2019 General Election campaign, 95% of Labour donations were from Trade Unions, and 4% from individuals and companies. In the same period of the 2024 campaign, 77% of donations to Labour were from individuals and companies.[31]

The extent to which parties are reliant on a handful of very wealthy donors is recognised by the public and is a cause for concern. YouGov find that 60% of people think that wealthy donors give money to gain influence compared to the 6% who this it is driven by support for the party. [32] Only 13% of people think that there should be no limits on how much people can give in political donations.[33]

Even potential wealthy donors themselves think that money buys too much influence. In a survey of G20 millionaires, 81% agreed that ‘extremely wealthy individuals can gain access to politicians via their wealth’ and 82% agreed that ‘there should be a limit on how much money politicians and political parties can receive from individuals’.[34]

Donations cap

In 2011 the CSPL produced a report addressing the problems of an increased reliance on significant donations. In their report the Committee said, ‘Over the last few decades all three main parties have instead become dependent on a small number of relatively large donations from individuals, trade unions (for the Labour Party) or other organisations. This dependency has inevitably created a risk that favours will be asked or given in return.’ The CSPL recommended a cap of £10,000 for donations from a single source in a year and for trade union donations to be treated as an aggregation of individual donations subject to opt-in rules.[35]

Since that report, the size and balance of donations has shifted and the main problem remains. Parties are too reliant on too few, and the sums involved are simply too large. Reducing the amount that single private sources can give to parties not only helps create a fair democratic contest but protects parties and their representatives from engaging in risky fundraising behaviours.

A donations cap would prevent a small number of wealthy donors dominating political finance as well as reducing the corruption risk. A poll, conducted in December 2025 found that 57% of people support the introduction of a cap on the amount of money individuals or companies can donate to parties, while just 7% were against.[36]

A high cap could prevent the worst cases of party capture – where one or two significant donors could have major undue influence on a party. However, setting a cap too high risks it having too little impact, whilst too low, too soon, could encourage splitting donations rather than diversifying and democratising donations. Moving towards a cap that could be seen as legitimate might call for a staged approach allowing parties to adjust their funding models to accommodate any change. In either case, ensuring that money can not be channelled through ‘straw donors’ is important in making donations caps work in practice (see ‘enforcement gaps’ section).

The Electoral Legislation Amendment (Electoral Reform) Act 2025 in Australia has recently introduced donations caps ($50,000 AUS per year)[37] and in South Australia, the government has banned all donations and loans to parties, candidates, MPs and third parties, supported by a new system of state funding.[38]

Spending and donations

Another way to release the pressure on fundraising is to limit spending and there are a number of additional reasons for changing the nature of spending limits.

Spending limits have been in place for elections since the Corruption and Illegal Practices (Prevention) Act 1883 introduced candidate spending limits for the first time. But it wasn’t until PPERA in 2000 that national party spending limits were introduced, reflecting the growing importance of the national campaign. Different spending limits apply to parties, candidates and non-party campaigners.

In 2023 the government increased the maximum spending limit by 80% from £19 million to £35 million.[39] Following this, the 2024 General Election was the most expensive to date (even adjusting for inflation) with £94.5 million spent across all categories of campaigner, compared to £72.6 million in 2019 and £55.9 million in 2017.[40] But not all parties spent near the top end of the spending limit – only Labour (89% of the maximum) and the Conservatives (70% of the maximum) came close in 2024.[41]

Spending limits currently only apply to the regulated period which covers the year prior to a UK General Election. Recent concerns over the use of databases for online campaigning have highlighted the risk of campaigning tools being paid for outside of regulated periods. The move towards year-round campaigning has also brought into question whether applying spending limits only to the regulated period is still appropriate.

Yearly spending caps have been recommended to address these changes in the campaigning environment.[42]

Corporate donations

A company is a permissible donor in the UK if it meets three criteria: that it is registered at Companies House, is incorporated in the UK and it is carrying out business in the UK. This however leaves the possibility of a foreign company setting up a shell company in the UK with the purpose of using it for funnelling funds to a political party.

The 1998 CSPL report ‘The Funding of Political Parties in the United Kingdom’, prior to PPERA, identified the risk that UK based subsidiaries could be used to channel foreign funds from a foreign corporation. Suggesting: ‘This would clearly be an abuse of the system and could be met by provisions designed to ensure that, in the case of a donation from a UK subsidiary of a foreign company, that subsidiary was carrying on a genuine business within the United Kingdom and was generating income here sufficient to fund any donation made to a UK political party.’[43]

To address this issue the CSPL in its 2021 report recommended that company donations should not exceed net profits after tax generated in the UK within the preceding two years.[44] However, it has been suggested that this provision would not go far enough to prevent foreign influence where many significant foreign companies would still be generating enough income via UK subsidiaries to make substantial donations and the rules may need to consider who the beneficial owner of the company is and whether they are an impermissible donor. A two-step test including both a UK connection test and financial test is likely to provide better cover.

However, whilst dealing with the issue of foreign funding, this does not address other potential conflicts of interest arising from company donations to political parties. Investigations have highlighted how many companies that donate to political parties are also benefitting, to a much greater extent, through government contracts. Research into UK donations suggests that 373 companies have both made donations and received public contracts; 35 of these companies had received a public contract within two years of making a donation to the governing party.[45]

These potential conflicts of interest lead some political finance regimes to ban corporate donations outright. Around a quarter of countries worldwide ban corporate donations to political parties; this rises to over half of all OECD countries and over half of EU countries.[46]

Cryptocurrency

Cryptocurrency presents a new risk to political finance rules, creating a challenge for both fairness and transparency. The nature of cryptocurrency exacerbates many of the problems already present in political finance including obscuring the true source(s) of a donation, increasing the risk of impermissible donations from foreign sources and the increased ability to split large donations into smaller ones to avoid transparency rules.

Whilst the Electoral Commission has produced guidance for political parties,[47] putting the responsibility on parties to satisfy themselves that the rules have not been broken, this is unlikely to be sufficient to meet the challenge. Resourcing the Commission to ensure compliance within the fast-changing world of cryptoassets would be a significant investment. In the face of this challenge, other countries including Ireland and Brazil have moved to ban cryptocurrency donations altogether.

Accountability

Principle: Political parties, candidates and campaigners who fail to comply with the law should be held accountable through impartial and proportional enforcement. The law needs to minimise foreseeable loopholes and avenues for circumvention. 

Gaps in the UK regulatory framework

Electoral Commission independence

The 2022 Elections Act introduced a requirement for the Electoral Commission to ‘have regard to’ a strategy and policy statement set by ministers which reflects the government’s policy priorities and set out the ‘roles and responsibilities’ of the Commission in achieving those priorities. The Commission must now report annually against that statement to the Speaker’s Committee. A significant imposition on regulatory autonomy.

Electoral management body independence is set out under international law and in a range of international guidelines (such as the OSCE’s Office for Democratic Institutions and Human Rights guidance and the Council of Europe Venice Commission code of practice). Commission independence is vital to electoral integrity: effective enforcement relies on having a body with the resources, the will, and the independence to take on political finance issues.

The change brought in under the 2022 Act was criticised by two different international electoral observer missions during the 2024 General Elections[48] and analysis by Spotlight on Corruption highlights how since the Act, the UK has dropped down international ratings for electoral body autonomy, from 30^th to 52^nd in 2023.[49]

The Electoral Commission have themselves been highly critical of the change noting that allowing government to guide its work, ‘is inconsistent with the role that an independent electoral commission plays in a healthy democracy.’[50]

The Speaker’s Committee of the House of Commons, a cross-party committee of MPs, through which the Electoral Commission is directly accountable to parliament, from its establishment (2003) until the 2019 parliament, did not include a majority of members from the same party.^[51] However, during later sessions, the Committee not only had a majority of MPs from the same party, but a majority of members from the governing party.

The Strategy and Policy Statement and lack of safeguards create a very dangerous set of instruments that could be exploited by future governments and seriously damage electoral integrity.

It is critical that Electoral Commission independence is restored by removing the strategy and policy statement provisions in part 3 of the Elections Act 2022. It is also important to ensure that the Speaker’s Committee remains cross-party, and this could be strengthened by inviting ordinary ‘lay’ members of the public to join the committee (much like parliament’s Standards Committee has done), preventing any party having a majority on the committee and reducing the number of ministers sitting on the committee.

Enforcement gaps

A robust regulatory framework can still fail if it is not supported by robust practical enforcement.

Political finance and election law in the UK is highly fragmented with rules split between different pieces of legislation and with differing and sometimes overlapping responsibilities for enforcement. The responsibility for regulating political finance in relation to political parties and third-party campaigners sits with the Electoral Commission as established by PPERA (2000). The regulation of candidate finance law falls under the Representation of the People Act (RPA) 1983 and is enforced by the police. The Electoral Commission does not investigate or sanction breaches which fall under the RPA 1983 but has some civil sanctioning powers (under Political Parties and Elections Act 2009 (PPEA)) for PPERA breaches. The Elections Act 2022 explicitly removed the Electoral Commission’s ability to bring criminal proceedings. Criminal offences under PPERA therefore also fall to the police, though to date, only one criminal case under PPERA has reached the courts.[52]

The problem with this approach is two-fold: minor ‘administrative’ breaches under the RPA can only be dealt with by criminal sanctions and serious breaches under PPERA risk not being pursued. Many breaches are not investigated or sanctioned because it is not deemed to be in the public interest or the evidence does not meet the burden of proof required for criminal cases. Notably, most PPERA offences require proof of intent of the person who committed the offence which is difficult to prove. Only the Metropolitan Police have a specialist team with experience in election law. As Spotlight on Corruption note, whilst PPERA contains a number of criminal offences, the enforcement gap creates, “a grave risk that there is no effective criminal deterrence against rogue actors who may seek to undermine the UK’s electoral processes.”[53]

Additionally, the current civil sanctions the Electoral Commission can impose are limited to a maximum individual fine of £20,000; a sum, in relation to spending typically in the millions, that can simply be seen as the ‘cost of doing business’. Multiple parliamentary committees, civil society organisations and others have called for the Commission’s fines to be increased in recent years to provide an effective deterrent.[54] The House of Lords Democracy and Digital Technologies committee recommended increasing the Electoral Commission’s maximum fine to £500,000 or four percent of a campaign’s total spend, whichever is greater.^[55] For comparison, the ICO is able to fine organisations up to four percent of global turnover, or £17 million, and grant them the powers of compulsory audit, no notice inspections, and demands for access.[56]

With only the most serious cases being taken forward by the police and prosecution authorities, more minor infringements can also fall through the gaps. Allowing the Electoral Commission to regulate candidate finance and, where appropriate, impose civil sanctions would allow for a more consistent and proportionate approach, preventing an inappropriate escalation where this could be avoided.

It is also essential that criminal offences do not fall through the enforcement gap. Ways to address this could be to restore the ability to bring criminal prosecutions to the Electoral Commission, with greater support to take this forward, or to keep criminal prosecutions across all offences with the police, but provide resources for a specialist unit.

Information gaps

Whilst there are a number of rules set out under PPERA to ensure that donations are transparent and that funds are not accepted from impermissible donors (s.54-s.57), it is widely felt that these provisions are not sufficient to prevent illicit donations, particularly from foreign sources.[57]

At present, parties are required to take ‘all reasonable steps’ to verify the identity of the donor and whether they qualify as a permissible donor. They must also report both accepted and rejected donations to the Electoral Commission and are legally required to refuse the donation if they cannot confirm who the donation is from and whether it is from a permissible source.

Whilst these rules are intended to prevent impermissible donations, there are concerns that they do not work in practice and that they are in fact quite minimal when compared to anti-money laundering practices in other areas.[58] [59] There are concerns that only requiring parties to check the status of the donor but not to establish the source of their funds, creates a significant loophole.[60]

Provisions exist in PPERA (s.54A) requiring donors to make a declaration confirming if they have received a benefit in connection with the donation from another source, but have not been commenced.

Providing an effective deterrent and increasing the responsibilities on parties to conduct due diligence on donations are important steps but it is also important to consider what actions should be taken in light of greater information such as whether there is a legal duty to reject the donation.

 

Thank you to the academics, international election observers and campaigners who contributed to the ERS Expert Forum on Political Finance on which this briefing is based.

 

Appendix A: reporting case studies

USA: pre-election reporting

The USA has one of the speediest systems with reports filed online either monthly or quarterly and published immediately by the Federal Election Commission. The reports are published on a searchable public database within 48 hours of receipt and are published without review by the FEC.[61]

In addition, many States require candidates to report contributions to campaigns within 48 hours of receiving the donation in the 30 days leading up to an election, and similar reporting of expenditures from campaigns. This is in addition to post-election reports of contribution and spend.[62]

Czech Republic: transparent bank accounts

In the Czech Republic, prior to an election, parties need to establish four types of transparent bank account (a ‘special account’ for contributions from the state budget and private donations; an election account for election campaign expense; another for payroll, and one for all other income and spending). Donations can only be accepted into the special account and this account is fully open to the public (and must remain so for three years). Web addresses for these accounts are published on a central website. All transactions must be labelled with the name of the sender/recipient and the purpose of the payment.[63]

Estonia: open data

In Estonia, political parties and candidates must submit a report of election expenditure including donations, loans, in-kind contributions and itemised spending one month from the date of the election as well as providing quarterly reports. The data must be in a standardised format and is uploaded on the Political Parties Financing Surveillance Committee website which provides all the data in a searchable format.[64]

Australia, Queensland: ‘real-time’ disclosure

In Australia, candidates and Senate groups have 15 weeks from polling day in which to file their election returns however in Queensland, local government candidates must disclose all gifts, loans and expenditure over $500 within 7 days of the loan or gift being received. In the last 7 days before an election, the disclosure period is 24 hours.[65] A recent bill attempted to move to real-time disclosure at the national level in Australia.

 

 

End Notes

[1] European Commission for Democracy Through Law (Venice Commission), guidelines on political party regulation, https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2010)024-e

[2] Electoral Commission, Public Attitudes 2025, https://www.electoralcommission.org.uk/research-reports-and-data/public-attitudes/public-attitudes-2025

[3] Electoral Commission, Form UA2 ‘Report of gifts received by an unincorporated association before a political contribution was made’ page 2.

[4] Committee on Standards in Public Life, ‘Regulating Election Finance’, 2021. Available at: https://www.gov.uk/government/publications/regulating-election-finance-report

[5] Transparency International UK, ‘Cheques and Balances: Countering the Influence of Big Money in Politics’, 2024. Available at: https://www.transparency.org.uk/publications/cheques-and-balances-countering-influence-big-money-uk-politics

[6] ibid

[7] Electoral Commission, written evidence to the National Security Strategy Joint Committee, Defending Democracy inquiry 2024 session. https://committees.parliament.uk/writtenevidence/128808/pdf/

[8] Public Administration and Constitutional Affairs Committee, The Work of the Electoral Commission, Second Report of Session 2022–23. Available at: https://committees.parliament.uk/publications/30380/documents/175485/default/

[9] Committee on Standards in Public Life, ‘Regulating Election Finance’, 2021. Available at: https://www.gov.uk/government/publications/regulating-election-finance-report

[10] Electoral Commission guidance What do you need to do when you receive a donation? | Electoral Commission

[11] Electoral Reform Society, ‘Democracy in the Dark: Digital Campaigning in the 2019 General Election and Beyond’, 2020. Available at: https://electoral-reform.org.uk/latest-news-and-research/publications/democracy-in-the-dark-digital-campaigning-in-the-2019-general-election-and-beyond/#sub-section-5

[12] Fair Vote, ‘Defending Our Democracy in the Digital Age’, 2020. Available at: https://www.fairvote.uk/work/defending-our-democracy-in-the-digital-age

[13] Legislation: Organic Law 8/2007, of July 4, on the financing of political parties

BOE-A-2007-13022 Ley Orgánica 8/2007, de 4 de julio, sobre financiación de los partidos políticos.

[14] European Parliament, Directorate General for Finance, ‘Financing of political structures in EU Member States report’, 2021. https://www.europarl.europa.eu/meetdocs/2014_2019/plmrep/COMMITTEES/AFCO/DV/2021/10-27/2021-JUNE_PE694.836_Financingpoliticalstructures_withAnnex3_EN.pdf

[15] Elections Canada: ‘Understanding contributions’ Available at: https://www.elections.ca/content.aspx?section=fin&dir=cont&document=index&lang=e

[16] Electoral Commission, New Zealand, ‘Party donations and loans by year’. Available at:

https://elections.nz/democracy-in-nz/political-parties-in-new-zealand/party-donations-and-loans-by-year/

[17] Australian Electoral Commission, Disclosure threshold. Available at:

https://www.aec.gov.au/parties_and_representatives/public_funding/threshold.htm

[18] Standards in Public Life Commission, Information for political parties. Available at:

https://www.sipo.ie/en/publication/7511c-information-for-political-parties/

[19] The Ministry of Social Affairs and the Interior, April 2020, Act on Private Contributions to Political Parties and the Publication of Annual Accounts of Political Parties (Annual Accounts of Political Parties (Consolidation) Act) https://www.elections.im.dk/media/37953/annual-accounts-of-political-parties-act.pdf

[20] Electoral Reform Society, ‘Democracy in the Dark: Digital Campaigning in the 2019 General Election and Beyond’, 2020. Available at: Democracy in the Dark: Digital Campaigning in the 2019 General Election and Beyond – Electoral Reform Society – ERS

[21] ibid

[22] Electoral Commission ‘Digital Campaigning – increasing transparency for voters’, 2018. Available at: Report: Digital campaigning – increasing transparency for voters | Electoral Commission

[23] International IDEA, ‘Regulation the Business of Election Campaigns: Financial transparency in the influence ecosystem in the United Kingdom’, 2022. Available at: Regulating the Business of Election Campaigns: Financial transparency in the influence ecosystem in the United Kingdom

[24] Electoral Commission, ‘Report on campaign spending at the 2024 UK Parliamentary general election’, 2025. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/report-campaign-spending-2024-uk-parliamentary-general-election

[25] See for example Full Fact ‘House of Lords Select Committee on Democracy and Digital Technologies, Report of Session 2019–21, ‘Digital Technology and the Resurrection of Trust’ https://committees.parliament.uk/publications/1634/documents/17731/default/

[26] International IDEA, ‘Regulating Online Campaign Finance: Case Study on Latvia’ 2022. Available at: https://www.idea.int/news/how-successfully-regulate-online-campaign-finance-some-lessons-latvia

[27] International IDEA, ‘Funding of Political Parties and Election Campaigns: A Handbook on Political Finance’

https://www.idea.int/sites/default/files/publications/funding-of-political-parties-and-election-campaigns.pdf

[28] Transparency International UK, ‘Cheques and Balances: Countering the Influence of Big Money in Politics’, 2024. Available at: https://www.transparency.org.uk/publications/cheques-and-balances-countering-influence-big-money-uk-politics

[29] Data from the Electoral Commission donations dashboard.

[30] Electoral Reform Society, ‘First three weeks of donation data show that money is attracted to power’, 2024. Available at: https://electoral-reform.org.uk/first-three-weeks-of-donation-data-show-that-money-is-attracted-to-power/

[31] ibid

[32] YouGov, 23 September 2024, 4046 GB adults: ‘Do you think that wealthy people make donations to individual politicians more because they support them and want them and their party to succeed, or more because they are trying to gain influence?’ https://yougov.co.uk/topics/politics/survey-results/daily/2024/09/23/a132c/1

[33] YouGov, biannual tracker at 29 December 2025, 1668 – 1804 GB Adults: ‘Should there be a limit of donations made to political parties by individuals?’

https://yougov.co.uk/topics/politics/trackers/should-there-be-a-limit-of-donations-made-to-political-parties-by-individuals

[34] Patriotic Millionaires, survey by Survation, 23rd December 2025 – 13th January 2026, 3,900 Millionaires living in G20 countries. Finding at: https://static1.squarespace.com/static/69134ac127c9a443603567c6/t/69692c8637b98820b3d48ded/1768500358592/Patriotic+Millionaires+G20+January+2026+Survey+Summary.pdf

[35] Committee on Standards in Public Life, thirteenth report, ‘Political Party Finance: ending the big donor culture’, 2011. Available at: https://www.gov.uk/government/publications/political-party-finance-ending-the-big-donor-culture

[36] Poll by Survation on behalf of 38degrees, cited in PoliticsHome, ‘Strong Support For Bringing In A Cap On Political Donations’, 23 Dec 2025. https://www.politicshome.com/news/article/strong-support-for-cap-on-political-party-donations-poll-shows

[37] Parliament of Australia, policy note, ‘Electoral Finance Reform’ https://www.aph.gov.au/About_Parliament/Parliamentary_departments/Parliamentary_Library/Research/Policy_Briefs/2025-26/Electoralfinance

[38] Electoral Commission South Australia, Reforms overview’. Available at:

https://www.ecsa.sa.gov.au/parties-and-candidates/electoral-funding-donations-reform/reforms-overview

[39] Electoral Reform Society ‘New Political Funding Rules Sneak In’, November 2023. Available at: https://electoral-reform.org.uk/new-political-funding-rules-sneak-in/

[40] Electoral Commission, ‘Report on campaign spending at the 2024 UK Parliamentary general election’, 2025. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/report-campaign-spending-2024-uk-parliamentary-general-election

[41] Ibid.

[42] Fair Vote, ‘Defending Our Democracy in the Digital Age’, 2020. Available at: https://www.fairvote.uk/work/defending-our-democracy-in-the-digital-age

[43] Committee on Standards in Public Life, fifth report, ‘The Funding of Political Parties in the United Kingdom’, 1998, section 5.29. Available at: https://assets.publishing.service.gov.uk/media/5a7daa32e5274a5eaea6596a/5thInquiry_FullReport.pdf

[44] Committee on Standards in Public Life, ‘Regulating Election Finance’, 2021. Available at: https://www.gov.uk/government/publications/regulating-election-finance-report

[45] Autonomy Institute, ‘Givers and Takers: uncovering the donor-contractor nexus at the heart of government’ 2025. Available at: https://autonomy.work/portfolio/givers-and-takers-uncovering-the-donor-contractor-nexus-at-the-heart-of-government/

[46] International IDEA political finance database https://www.idea.int/data-tools/data/political-finance-database

[47] Electoral Commission, ‘Political party donations and loans in Great Britain: Cryptoassets’. Available at: https://www.electoralcommission.org.uk/political-party-donations-and-loans-great-britain/cryptoassets

[48] Commonwealth Parliamentary Association, ‘Final Report CPA BIMR Election Assessment Mission’ (pages 8/9) https://www.uk-cpa.org/media/gyskl0w3/final-report-cpa-bimr-election-assessment-mission-uk-general-election-2024.pdf

OSCE office for Democratic Institutions and Human Rights, ‘United Kingdom, General Election, 4 July 2024: Final Report’, 2025 (Page 10) https://www.osce.org/odihr/elections/uk/592972

[49] Spotlight on Corruption, ‘Democracy in Danger’, 2025. Available at: https://www.spotlightcorruption.org/wp-content/uploads/2025/10/Spotlight-Democracy-in-Danger.pdf

[50] Electoral Commission, Letter from Commissioners: Strategy and Policy Statement measures in the Elections Bill, February 2022. Available at: https://www.electoralcommission.org.uk/news-and-views/key-correspondence/letter-commissioners-strategy-and-policy-statement-measures-elections-bill

^[51] Renwick, Alan and Kincaid, Charlotte (2020). Why we need an independent Electoral Commission. UCL Constitution Unit Blog, 7 October. https://constitution-unit.com/2020/10/07/why-we-need-an-independent-electoral-commission/

[52] Transparency International UK, ‘How is Our Electoral Law Enforced’. Available at:https://www.transparency.org.uk/news/how-our-electoral-law-enforced

[53] Spotlight on Corruption, ‘The integrity of the UK’s next election is at serious risk from rogue actors overseas’, 2023. Available at: https://www.spotlightcorruption.org/enforcement-electoral-finance-laws/

[54] See, for example,  Electoral Reform Society, ‘Reining in the Political ‘Wild West’: Campaign Rules for the 21st Century’, 2019. https://www.electoral-reform.org.uk/latest-news-and-research/publications/reining-in-the-political-wild-west-campaign-rules-for-the-21st-century/#sub-section-9

^[55] House of Lords Select Committee on Democracy and Digital Technologies, Report of Session 2019-21 ‘Digital Technology and the Resurrection of Trust’ https://committees.parliament.uk/publications/1634/documents/17731/default/

[56]See, for example,  Electoral Reform Society, ‘Reining in the Political ‘Wild West’: Campaign Rules for the 21st Century’, 2019. https://www.electoral-reform.org.uk/latest-news-and-research/publications/reining-in-the-political-wild-west-campaign-rules-for-the-21st-century/#sub-section-9

[57] Spotlight on Corruption, ‘Time for a ‘Know Your Donor’ Policy’, 2023. Available at: https://www.spotlightcorruption.org/time-for-a-know-your-donor-policy/

[58] Electoral Commission, ‘Digital campaigning – increasing transparency for voters’, 2018. Available at:

https://www.electoralcommission.org.uk/news-and-views/our-priorities-reforming-elections/transparent-digital-campaigning/report-digital-campaigning-increasing-transparency-voters

[59] Spotlight on Corruption, ‘Could ‘Know Your Donor’ rules for political parties help stop the endless scandals about dodgy donors?’, 2022. Available at: https://www.spotlightcorruption.org/know-your-donor-rules-for-parties/

[60] Spotlight on Corruption, ‘Time for a ‘Know Your Donor’ Policy’, 2023. Available at: https://www.spotlightcorruption.org/time-for-a-know-your-donor-policy/

[61] Federal Election Commission, USA, ‘Filing frequency by type of filer (2024)’

https://www.fec.gov/help-candidates-and-committees/dates-and-deadlines/2024-reporting-dates/filing-frequency-type-filer-2024/

[62] Coalition for Integrity, ‘The State Campaign Finance Index 2022’

https://www.c4integrity.org/state-campaign-finance/#report

[63] UDHPSH ‘Průvodce pravidly financování politiky’ https://pruvodce.udhpsh.cz/pruvodce/jake-ucty-musi-strana-vest/

[64] ERJK ‘Financial activities of political parties’ https://www.erjk.ee/en

[65] Electoral Commission Queensland https://www.ecq.qld.gov.au/election-participants/local-election-participants/candidates/real-time-disclosure-requirements

In 2024, turnout in the General Election was 59.9%. This narrowly avoided the 2001 historic low of 59.4%. Not only are voters not turning out, but there is evidence of a widening turnout gap between younger and older voters. The British Electoral Study finds that (in reported turnout which tends to over-estimate) 65.4% of 18- to 24-year-olds voted in 2024, compared to 88.6% of those aged 66 and over.[1]

From the 1990s onwards, the turnout gap has been expanding[2] and we see lower levels of turnout in constituencies which have larger proportions of young people.[3]

Lowering the franchise is an opportunity to nurture more active citizens for the future. By giving 16- and 17-year-olds a vote we can engage the next generation in politics and improve the future health of our democracy.

Democratic habits

Research has shown that the younger people are engaged in voting, the more likely they are to carry on voting later in their lives. In Austria, Scotland and Germany, those who were enfranchised at 16 or 17 were more likely to turn out to vote into their twenties compared to those who first voted at 18.[4]

Enfranchised 16- and 17-year-olds also tend to turnout to vote in greater numbers than those voting for the first time aged 18 and over.[5] This is likely because younger voters are better supported through their first experience of voting whilst they are at home and in education.

When 18-year-olds (or 19, 20, 21 year olds) are first entitled to vote, many have already left home or are at university where they are likely to be moving home more frequently and will find it harder to register to vote or to know where to vote. Registration levels for 18- and 19-year-olds are just 60% compared to 96% of those aged 65 and over.[6]

Engaging younger voters in the process of voting creates positive voting habits for the future.

Trust in politics

The 2024 British Social Attitudes survey, conducted after the general election of that year, recorded a new low in level of trust, with only 12% of people saying they trust governments to put the interests of the nation above their own party.[7]

Research from countries around the world suggests that enfranchising 16- and 17-year-olds has an impact on their trust in politics and satisfaction with democracy.

In Austria, those who were enfranchised at 16 and 17 had consistently higher levels of external efficacy (lower cynicism) and were more satisfied with democracy compared to older voters.[8] In Latin American countries that have adopted votes at 16, research found that early enfranchisement is strongly associated with higher levels of trust in parliament and political parties and, though to a lesser degree, satisfaction with democracy.[9]

Wider impacts

Support for Votes at 16 increased considerably after its introduction in Scotland. From two-thirds of adults opposing votes at 16 (in line with the rest of the UK) up to 60% in favour after being introduced.[10]

There is also evidence, from Germany, of younger voters having an impact on family discussion on politics – a form of reverse socialisation. And when 16- and 17-year-olds are given the vote, they are more likely to seek information on the election, discuss political issues with family and friends and to use voting advice applications which consequently led them to feeling better informed.[11] The enfranchisement itself causing younger voters to become more engaged.

Evidence from Scotland suggests that lowering the voting age can help to address democratic inequalities initially. Differences in political participation by social background within young cohorts were less pronounced in Scotland after the introduction of votes at 16 than in the rest of the UK; newly enfranchised young people of all social groups in Scotland were equally likely to be politically engaged.[12]

Votes at 16 in the UK and the world

Across the world many countries allow 16- and 17-year-olds to vote in elections but it is also the norm for many voters in the UK. Both Scottish and Welsh 16- and 17-year-olds are already enfranchised to vote in devolved and local elections.

This creates an inequality where Scottish and Welsh 16 & 17-year-olds can vote in elections, but their English and Northern Irish counterparts are barred from voting entirely. Lowering voting to 16 years old across the UK is not  extending the franchise but rather equalising the rights of 16- and 17-year-olds across the UK.

The voting age is 16 for all elections in Austria, Malta, Argentina, Brazil, Cuba, Ecuador, Nicaragua, Jersey, Guernsey and the Isle of Man and for local elections in Estonia, European elections in Belgium, and in Germany, for European elections and some State and local elections.

Electoral impact

Enfranchising 16- and 17-year-olds is highly unlikely to have a direct impact on electoral outcomes. Research in 2017 showed there was around 1.5 million 16- and 17-year-olds in the UK (the current figure stands at 1.6 million[13]). If enfranchised this group would make up around 3% of the voting age population. The small size of this cohort would have little impact on vote shares even if they achieved 100% turnout and all voted the same way.[14] ONS research from 2017 showed that with only 1.5 million extra voters UK-wide, there were only 88 constituencies in which the proportion of newly enfranchised 16 and 17 year olds was greater than the winning margin, at the 2017 general election.[15]  This is not to say that in those constituencies the election outcome would change however, as we do not know whether all these new voters would turn out to vote nor their party preference.[16] Evidence from around the world shows that young people have diverse attitudes, do not vote as a uniform bloc and do not change the broader political landscape.[17]

Enfranchising 16- and 17-year-olds would not drastically change the electoral landscape, but it would allow young people to have a voice in the decisions that are made for them every day at local, regional and national level.

Implementation is key to making votes at 16 a success

Democratic education

Votes at 16 creates an opportunity to improve democratic education, providing a seamless transition from learning about and discussing politics in the classroom to engaging in elections. Democratic education can provide younger voters with the confidence, efficacy and interest to get involved whilst gaining the right to vote increases young people’s desire to learn about political issues.

Registering to Vote

Introducing Automatic Voter Registration alongside the enfranchisement of 16- and 17-year-olds would enable new voters to be moved onto the register whilst they are still attending school or college. The Department of Education and local authorities hold information on pupils including name, date of birth and address making it an ideal point in which to utilise both data sources to bring onto the register millions of students. This is also the moment at which young people will be given their National Insurance number creating another opportunity to use national data to help get people registered to vote.

Voter information

It is vital that young people are supported with early awareness and information campaigns. Lessons from the introduction of votes at 16 in Wales show the importance of timely interventions on awareness, registration and mobilisation that need to start earlier with young people, not least because they are often in exams during the election period.[18]

Automatic voter registration, improved voter engagement and democratic education can help make votes at 16 a major moment of democratic change and renewal in the UK.

 

End Notes

[1] British Election Study data, 2024 (N=31,091). https://www.britishelectionstudy.com/graph/?id=38404

[2] House of Commons Library research briefing, ‘Turnout at Elections’, 2023. https://researchbriefings.files.parliament.uk/documents/CBP-8060/CBP-8060.pdf

[3] IPPR, ‘Half of Us: Turnout Patterns at the 2024 general election’, 2024. https://www.ippr.org/articles/half-of-us

[4] Huebner, C., and Eichhorn, J., ‘Evidence and Good Practice on Lowering the Voting Age to 16’. https://www.jrrt.org.uk/wp-content/uploads/2025/01/Votes-at-16-report-FINAL.pdf

[5] ibid

[6] Electoral Commission, ‘Who is and isn’t registered to vote’. https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/explore-data-who-and-isnt-registered-vote

[7] Clery, E., Curtice, J. and Jessop, C. (eds.) (2025) British Social Attitudes: The 42nd Report.
London: National Centre for Social Research. https://natcen.ac.uk/publications/bsa-42-britains-democracy

[8] Aichholzer, J & Kritzinger, S., (2020). Voting at 16 in Practice: A Review of the Austrian Case. In J. Eichhorn & J. Bergh (Eds.), Lowering the Voting Age to 16: Learning from Real Experiences Worldwide (pp. 81–101). Cham: Palgrave Macmillan

[9] Sanhueza Petrarca, C., (2020). Does Voting at a Younger Age Have an Effect on Satisfaction with Democracy and Political Trust? Evidence from Latin America. In J. Eichhorn & J. Bergh (Eds.), Lowering the Voting Age to 16: Learning from Real Experiences Worldwide (pp. 103–119). Cham: Palgrave Macmillan.

[10] Eichhorn, J., & Huebner, C. (2023a). Votes at 16 in Scotland 2014-2021. Edinburgh: The University of Edinburgh. https://www.sps.ed.ac.uk/sites/default/files/assets/doc/Votes%20at%2016%20in%20Scotland.pdf

[11] Leininger, Arndt & Schäfer, Armin & Faas, Thorsten & Roßteutscher, Sigrid. (2024). Coming of voting age. Evidence from a natural experiment on the effects of electoral eligibility. Electoral Studies. 88.

[12] Huebner, C. & Eichhorn, J. (2022). The Tide Raising all Boats? Social Class Differences in Political Participation among Young People in Scotland. Scottish Affairs, 31(2), 165-189.

[13] Office for National Statistics, Census data 2021, 16 -17 year old population

https://www.ons.gov.uk/employmentandlabourmarket/peopleinwork/employmentandemployeetypes/timeseries/jn5p/lms

[14] Huebner, C., and Eichhorn, J., ‘Evidence and Good Practice on Lowering the Voting Age to 16’. https://www.jrrt.org.uk/wp-content/uploads/2025/01/Votes-at-16-report-FINAL.pdf

[15] Office for National Statistics, ‘What impact could lowering the UK voting age to 16 have on the shape of the electorate?’, 2017

https://www.ons.gov.uk/peoplepopulationandcommunity/elections/electoralregistration/articles/whatimpactcouldloweringtheukvotingageto16haveontheshapeoftheelectorate/2017-07-14

[16] ibid.

[17] Huebner, C., and Eichhorn, J., ‘Evidence and Good Practice on Lowering the Voting Age to 16’. https://www.jrrt.org.uk/wp-content/uploads/2025/01/Votes-at-16-report-FINAL.pdf

[18] Huebner, C., Smith, K. A., Mycock, A., Loughran, T., & Eichhorn, J. (2021). ‘Making Votes-at-16 Work in Wales. Lessons for the Future’ (pp. 1–34). Nottingham: Nottingham Trent University. https://www.ntu.ac.uk/media/documents/nce/Huebner-et-al_2021_Making-Votes-at-16-work-in-Wales.pdf

Mandatory photographic ID for voters was introduced via the Election Act 2022 and required for the first time in the local elections in 2023. Voters were asked to show photographic ID at the local elections, mayoral elections and General Election in 2024 and all subsequent English local and Westminster by-elections.

What do we know about the impact so far?

The Electoral Commission reported that in the 2024 General Election around 16,000 electors attempted, but were unable to vote due to the Voter ID requirement; this equates to 1 in every 1,200 voters.[1] Similarly, the May 2024 local and mayoral elections reported around 13,000 electors attempted to vote but were turned away because they lacked accepted ID and did not return; in the May 2023 local elections this figure was around 14,000.[2] However, as recognised by the Electoral Commission, this is likely to be an underestimate as many voters were turned away by ‘greeters’ outside the polling station and were not recorded in the official figures.

Across the first three sets of elections using Voter ID, at least 42,368 voters were denied their right to vote.*[3] [4]

According to the Electoral Commission, when given a list of options, 10% of non-voters gave voter ID as the reason that they did not vote in the 2024 General Election, this figure was 4% when unprompted. Similarly, 7% of non-voters in the 2023 local elections gave voter ID as the reason that they did not vote when given a list of options.[5] Ipsos polling also found that 8% of people said that voter ID made them less likely to want to vote in the May 2023 local elections.[6]

Analysis of British Election Study Internet Panel data indicates that at the 2024 general election, 1% of people did not attempt to vote due to lacking ID and 0.3% reported being turned away. This represents a small but meaningful population of voters (over half a million people) who were unable to vote due to the new legislation.[7]

Together these findings suggest that voter ID has had a chilling effect on turnout.

Evidence from the Electoral Commission suggests that some groups were more likely to have a problem voting due to the voter ID requirement than others at the 2024 General Election. Specifically, those in the C2DE social grade – 8% of C2DE non-voters when prompted said they didn’t vote because they didn’t have required ID in comparison to 3% of ABC1 voters. The same research also showed that in comparison to the general population, voter ID created more of a barrier to voting for disabled people and unemployed people.[8] This is echoed in the 2023 Electoral Commission survey which showed that unemployed and disabled non-voters were more likely to say that they didn’t vote because they didn’t have ID, and that young people and people from black and minority ethnic communities were more likely to have not been able to vote because they turned up without ID.

Democracy Volunteers (an organisation authorised by the Electoral Commission to provide electoral observers) found that in the May 2023 English local elections, of the people turned away from polling stations because they lacked relevant ID or were judged not to have it, 53% were identified by observers as being ‘non-white passing’.[9] In addition, Electoral Commission evidence indicates that more deprived areas had a higher proportion of voters turned away compared to less deprived areas.[10]

Research into the impact on electoral services by the LGIU found that voter ID has added to existing pressures on electoral administrators, increasing stress, adding complexity, and making it harder to find staff for polling stations.[11] They also found that electoral administrators were ‘unconvinced’ that the introduction of voter ID had reduced public concerns about fraud and noted that voters had raised complaints that voter ID had been introduced for political reasons. The report warns that this perception is a risk to public confidence in elections.

Following the 2023 local elections, the cross-party Democracy and the Constitution APPG inquiry concluded that Voter ID is a “poisoned cure” in that it disenfranchises more electors than it protects.[12] The inquiry found that voter ID brings with it a risk of injustice and discrimination, highlighting that the standard that ID documents need to meet is unclear, that the approved list of ID ‘appears arbitrary’, and that there is significant scope for unequal application of the rules. The report also highlights that there is no immediate right to appeal for those who have been denied a ballot.

The APPG inquiry also heard evidence from academic experts in face recognition. They indicated that “face matching” exercises, such as matching a photo-ID to the person who presents it, carry a high likelihood of error and point to research into the effectiveness of passport checks, which indicate an error rate of between 20% and 35%. Moreover, where the document shows the person when they were substantially younger (such as UK passports, which may depict the holder up to ten years ago) the error rate increases to 75%. [13]

Two areas that don’t appear to have been impacted are voters’ perception of how secure in-person voting is (which remains at the same level after the introduction of voter ID),[14] and the instances of personation fraud. The government’s 2023 report concluded that the evidence is ‘inconclusive’ on whether the scheme has reduced personation or made it more easily identifiable. Two cases of personation fraud were reported to the police at the May 2023 local elections – consistent with previous years. The same government report notes that ‘all groups’ in their research ‘held the perception that fraud was more likely to be conducted via postal or proxy voting’.[15]

What are the main issues?

Voter ID creates a barrier to voting for many.

Unlike most countries which require ID to vote, there is no universal ID card in the UK, leaving many people without the ID needed. Whilst a voter authority certificate has been made available, 56% of respondents to the government commissioned survey said they would be unlikely or very unlikely to apply for an ID document, and 42% of those with no photo ID said they would be unlikely or very unlikely to apply.[16] Only 25,000 Voter Authority Certificates were used as ID in local elections 2023, 22,749 at the local and mayoral elections in 2024 and 72,497 in 2024 General Election. This is far fewer than the number of registered voters who are estimated to need one (around 750,000).[17]

The government’s own research finds that older voters (aged 85+) are less likely to have ID that is recognisable (91% compared to 95%–98% for those in younger age groups) and that those with severely limiting disabilities, the unemployed, people without qualifications, and those who had never voted before, were all less likely to hold any form of photo ID.[18] Post-election research in 2023 confirms that these groups were more likely not to have voted because they didn’t have ID.[19]

Analysis of British Election Study Internet Panel data indicates that at the time of the 2023 and 2024 local elections, approximately one in 20 electors did not own any recognised voter identification and that this lack of ID was more concentrated amongst poorer households and voters without educational qualifications. [20]

Voter ID is putting up another barrier to people who are already likely to be less engaged in democracy and may already find it harder to participate.

Confidence in the voting system could be undermined.

As it stands, confidence in our elections is high. The last Electoral Commission tracker, prior to the introduction of voter ID (2022), found that 87% of the had confidence that voting at polling stations is safe from fraud and abuse.[21]  At the same time there does not appear to be an increase in public perception of the security of voting after the introduction of ID. The Electoral Commission found that 87% of respondents to their 2024 post poll survey rated voting at the polling station as safe from fraud or abuse, the results “are consistent with the long-term average”.[22]

However, research findings suggest that there has been some public concern around the introduction of the voter ID scheme[23] and some people have chosen not to vote because of it.[24] The potential for the rules to be applied unevenly creates a problem for perceptions of electoral integrity.

The voter ID scheme is a solution looking for a problem.

Out of all alleged cases of electoral fraud in the 2019 elections, only 33 related to personation fraud at the polling station[25] – this comprises 0.000057% of the over 58 million votes cast in all the elections that took place that year. Only one of those allegations resulted in a conviction, and one a caution.[26] Despite this, the voter ID scheme introduced in the Elections Act is one of the most restrictive with only a limited number of photographic IDs deemed acceptable and no alternatives for voters who turn up without ID.

The government assessment in 2023 notes that there were just two allegations of personation at the May 2023 elections which is ‘consistent’ with previous elections – before the introduction of the ID scheme. The government report also concluded that the evidence is ‘inconclusive’ on whether the scheme has reduced personation or made it more easily identifiable.[27]

What can be done about it?

Given the problems with the scheme to date and the lack of evidence of a need for strict photo ID laws in the UK, the ERS believes voter ID should be scrapped. However, there are also several ways to improve the scheme.

Expand the list of acceptable identity documents

Increasing the range of acceptable identity documents, including non-photographic ID, and IDs that voters are likely to be carrying on them (such as bank cards), would make the scheme more proportional. The Pickles report ‘Securing the ballot’, which first suggested introducing ID, recommended that: “There is no need to be over elaborate; measures should enhance public confidence and be proportional.”

Many of the pilots of voter ID included poll cards and/or non-photographic identification. When it introduced voter ID, Northern Ireland did not initially require solely photographic ID – elections took place for almost 20 years with a less stringent ID requirement.

The Electoral Commission have also recommended expanding the list of acceptable IDs with a particular focus on identifying forms of ID which would support people who currently are least likely to have the correct identification documents such as people from a lower social grade (C2DE), disabled people, and those who are unemployed.[28]

Include poll cards

In the 2018 Voter ID pilots, areas which allowed poll cards to be used as identification along with other forms of photo ID recorded the lowest percentages of voters not returning with correct ID (Swindon 0.06% and 0.2% Watford). In Swindon, 95% of voters produced their poll card instead of another form of ID, 87% in Watford.

 

Similarly, the poll card pilots in 2019 recorded lower percentages of voters being turned away than the photo ID or mixed ID models. In the poll card pilots (Mid Sussex, NW Leicestershire, Watford) 93% of voters produced a poll card instead of an alternative form of ID.

 

Introduce vouching

Vouching is used in some US states and in Canada. The vouching system allows for another voter, who has ID, to vouch for someone who doesn’t. The person vouching for someone else signs an affidavit which means there is a paper trail should any irregularities need to be investigated. The House of Lords Constitution Committee recommended vouching (attestation) in their recent inquiry.[29] The Electoral Commission has also recommended the introduction of vouching.[30]

Allow for statutory declarations

Measures to allow voters to cast provisional ballots or sign an affidavit attesting to their identity are common in countries requiring voter ID. Even the US states with the strictest photo ID laws allow for provisional ballots to be cast and later verified.[31] The Democracy and the Constitution APPG report recommends allowing voters to ‘cure’ any failure to produce the required documentation by making a statutory declaration on the day of the poll.

Continue to collect data and improve data collection

It is essential that the impact of voter ID is monitored and that data collection is detailed and robust to ensure that we have a full picture of how this policy is affecting voters.

 

End Notes

[1] Electoral Commission, “Voter ID at the 2024 UK general election”, 2024. Available at:  https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-2024-uk-general-election

[2] Electoral Commission, “Voter ID at the May 2023 local elections in England: interim analysis”, 2023. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-may-2023-local-elections-england-interim-analysis

[3] Ibid.

* Those recorded as having been turned away and did not return at the 2023 local elections, 2024 local and mayoral elections and 2024 General Election combined. The 2024 General Election was the last election in which returning officers were legally required to collect these statistics. As it stands, the next General Election will be the final time monitoring is required by law.

[4] Electoral Commission, “Voter ID at the 2024 UK general election”, 2024. Available at:  https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-2024-uk-general-election

[5] Electoral Commission, “Voter ID at the May 2023 local elections in England: interim analysis”, 2023. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-may-2023-local-elections-england-interim-analysis

[6] Ipsos UK, “Written evidence (VID0010) House of Lords Constitution Committee inquiry into voter ID”, 2023. Available at: https://committees.parliament.uk/writtenevidence/126939/pdf/

[7] Scott. R and Fieldhouse. E, “How have voter ID requirements affected British Elections?”, 2025. The Constitution Unit Blog. Available at: https://constitution-unit.com/2025/02/21/how-have-voter-id-requirements-affected-british-elections/

[8] Electoral Commission, “Voter ID at the 2024 UK general election”, 2024. Available at:  https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-2024-uk-general-election

[9] Democracy Volunteers, “Final Report: English Local Elections 2023”, 2023. Available at: https://democracyvolunteers.org/final-report-english-local-elections-2023/

[10] Electoral Commission, ‘Report on the May 2023 local elections in England”, 2023 Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/report-may-2023-local-elections-england

[11] Local Government Information Unit, “The Impact of Voter ID: the view from administrators”, 2023. Available at: https://lgiu.org/wp-content/uploads/2023/09/The-impact-of-voter-ID-the-views-of-administrators.pdf

[12] Institute for Constitutional and Democratic Research, “VOTER ID – WHAT WENT WRONG AND HOW TO FIX IT An Inquiry into the impact of photographic identification requirements at the 2023 local elections”, 2023. Available at: https://www.icdr.co.uk/voter-id-inquiry

[13] Ibid

[14] The Electoral Commission, “Voter ID at the 2024 UK general election”, 2024. Available at:  https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-2024-uk-general-election

[15] Dept for Levelling Up, Housing and Communities, “Electoral Integrity Programme evaluation: year 1 report”, 2023. Available at: https://www.gov.uk/government/publications/evaluation-of-the-electoral-integrity-programme-year-1-report

[16] IFF Research, “Photographic ID Research – headline findings”, 2021. Available at: https://assets.publishing.service.gov.uk/media/609a5105d3bf7f2886e29f44/Photographic_ID_research-_headline_findings_report.pdf

[17] The Electoral Commission, “Voter ID at the May 2023 local elections in England: interim analysis”, 2023. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/report-may-2023-local-elections-england

[18] Ibid

[19] Electoral Commission, ‘Report on the May 2023 local elections in England”, 2023 Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/report-may-2023-local-elections-england

[20] Scott. R and Fieldhouse. E, “How have voter ID requirements affected British Elections?”, 2025. The Constitution Unit Blog. Available at: https://constitution-unit.com/2025/02/21/how-have-voter-id-requirements-affected-british-elections/

[21] Electoral Commission, “Public attitudes 2022”, 2022. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/public-attitudes/public-attitudes-2022

[22] Electoral Commission, “Public attitudes 2024”, 2024. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/public-attitudes/public-attitudes-2024

[23] Local Government Information Unit, “The Impact of Voter ID: the view from administrators”, 2023. Available at: https://lgiu.org/wp-content/uploads/2023/09/The-impact-of-voter-ID-the-views-of-administrators.pdf

[24] Electoral Commission, “Voter ID at the May 2023 local elections in England: interim analysis”, 2023. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/report-may-2023-local-elections-england

[25] Uberoi and Johnstone, “Political disengagement in the UK: Who is disengaged?”, House of Commons Library, 2022. Available at: https://researchbriefings.files.parliament.uk/documents/CBP-7501/CBP-7501.pdf

[26] Electoral Commission, “2019 Electoral Fraud Data”, 2020. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-fraud-data/2019-electoral-fraud-data

[27] Dept for Levelling Up, Housing and Communities, “Electoral Integrity Programme evaluation: year 1 report”, 2023. Available at: https://www.gov.uk/government/publications/evaluation-of-the-electoral-integrity-programme-year-1-report

[28] Electoral Commission, “Voter ID at the 2024 UK general election”, 2024. Available at:  https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-2024-uk-general-election

[29] House of Lords Constitution Committee, “Voter ID requirements should be made more accessible ahead of elections, says Lords committee”, 19 December 2023. Available at: https://www.parliament.uk/business/lords/media-centre/house-of-lords-media-notices/2023/december-2023/voter-id-requirements-should-be-made-more-accessible-ahead-of-elections-says-lords-committee/

[30] Electoral Commission, “Voter ID at the 2024 UK general election”, 2024. Available at:  https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-2024-uk-general-election

[31] National Conference of State Legislatures,  “Voter ID laws”, 2024. Available at: https://www.ncsl.org/elections-and-campaigns/voter-id#Table%201

The Electoral Commission’s most recent analysis of electoral registers estimated that between 7 and 8 million people are missing from the electoral rolls.[1] ERS constituency estimates based on these findings suggest that, in some places, as much as 20% of the total eligible population is likely to be missing from the register.[2]

In the 2024 General Election, voter turnout was just 59.9%, narrowly beating the previous historically low turnout of 59.4% in 2001. However, what the turnout figure fails to show is how many people were unable to vote because they weren’t registered to vote in the first place. With around 19 million people not turning out to vote and 8 million likely missing from the register – a total 27.5 million people did not participate in the election: Nearly as many people didn’t vote as did in 2024.[3]

Eligible citizens missing from the register is a democratic problem. Not only are these potential voters not able individually to exercise their right to vote, but collectively their voices are not being heard by decision makers. This is particularly a problem when missing eligible voters are not evenly distributed within the population.

81% of British people support automatically registering voters with 48% strongly supporting this change.[4]

Comprehensive and accurate electoral registration which reaches as many eligible voters as possible, is critical to our democracy. It is vital therefore that all possible steps should be taken to ensure everyone who is eligible to vote is registered.

In this briefing:

• How the registration system currently works
• Problems with the current system
• Automatic Voter Registration (AVR)
• Pilots of AVR in Wales
• International examples
• Assisted/integrated registration

How the UK’s electoral registration system works

In 2014, the UK moved away from a model of household registration where one person (the ‘head of household’) would apply on behalf of all residents, to a system of Individual Electoral Registration (IER). Under IER, Electoral Registration Officers (EROs) were given powers to match names and addresses on current electoral registers against data held by the Department for Work and Pensions. This process of registration ‘confirmation’ allowed EROs to transfer existing electors, who had been confirmed in the data matching process, onto the IER register.

The annual canvass (required under section 9D of the Representation of the People Act 1983) which is used to identify changes to the register, continued under IER via the Household Enquiry Form (HEF) and house to house inquiries. However, the Electoral Registration and Administration Act 2013 which introduced IER also contained powers to amend or abolish the canvass via secondary legislation.

At the same time, a system of online registration was introduced and a requirement for date of birth and National Insurance numbers to be provided as identifiers. However, despite being able to register via an online national portal, under the current system, each application is determined locally and there is no centralised database.

In 2019, changes to the annual canvass were made introducing automatic re-registration.[5] The annual canvass now begins with a data-matching step (against both national (DWP) and local data). If a registration can be reliably matched, the ERO will communicate with the resident but, if that information is correct, a response from the resident is not necessary in order for them to remain on the register (it remains an offence to fail to notify of a change or provide false information). The ERO does not need to send a reminder or chase a response (this is called ‘route one’). If the registration cannot be matched, a process similar to the previous canvass takes place with a minimum of three attempts to contact the property/residents (route two). A third route to registration is available for properties such as care homes and student accommodation where one person can be responsible for registering all residents.

These updates to registration have already moved the UK’s system closer to automatic registration with EROs using data-mining as an integral part of the registration process and re-registering those who can be reliably matched. However, there remain problems with the system as it stands.

Problems with the current system

Missing millions

Across Great Britain, between 7 and 8 million people are missing from the electoral rolls according to the Electoral Commission’s analysis. Completeness of the electoral registers stands at 86% across Great Britain (86% in England, 81% Scotland, 87% Wales, 83% Northern Ireland).[6]

Completeness has remained fairly static over time. Between 2011 and 2023, completeness of the registers across Great Britain has been between 82 and 86 percent. Only in Northern Ireland has there been a marked improvement, with registration increasing from 71% in 2012 to 83% in 2023.

This means that for the last four General Elections, millions of eligible voters have missed out.

In its latest report on registration, the Electoral Commission states that, “there is little evidence to suggest that levels of accuracy and completeness are likely to significantly improve without major changes to the current electoral registration system.”[7]

This points to the reality that without change to the UK’s electoral registration processes, millions of eligible voters will continue to miss out on having a say in our democracy.

The UK currently ranks in the bottom half of European countries on electoral integrity scoring which includes measurements of accessibility and registration. The Electoral Integrity Project global report in 2025 noted that electoral registration in the UK, “has been a long-term area of weakness in electoral integrity scores”.[8]

Unequal registration

Not only are millions missing from the electoral rolls but those missing are unequally distributed across society. Research suggests that the current system of registration is proving a barrier, particularly to young people and people in privately rented accommodation.

In 2022, 65% of private renters were registered compared to 95% of owner occupiers and 88% of those with a mortgage; only 60% of 18- and 19-year-olds were registered compared to 96% of those aged 65 and over and only 16% of attainers (those aged 16 and 17 in England) were registered.[9]

People who move home more frequently are particularly affected: only 39% of those who have been at their address for a year or less are registered to vote compared to 91% who have been at their address for 5-10 years.[10] The English Housing Survey (2024-25) finds that the average length of time households spent in their current home was 13.9 years but for private renters this reduces to 4.7 years. In 2024-25, approximately 1.8 million households moved home in the previous 12 months and around half of these were moves into or out of private rented dwellings.[11]

Failure to register does not necessarily indicate an apathy towards voting. Surveys of poll workers consistently find that the most common problem on polling day is people turning up to vote and not being registered. Half of poll workers in the 2018 local elections in England experienced at least one person turning up to vote who was not on the electoral register, some had experienced turning away more than 10 potential voters.[12]

Duplicate registrations and resources

The introduction of an online portal for registration has seen an increase in event-led registration in which large numbers of applications are received in the run up to elections (often immediately before the registration deadline) putting extra pressure on EROs. Often these applications are duplicates of existing applications as there is no way for voters to check if they are already registered online.

In the run up to the 2024 General Election, just under 2.9 million applications to register to vote were made between when the election was called and the registration deadline (May 22^nd – June 18^th).[13] Despite a huge surge of 632,901 applications on the last day, the overall number of applications was still well short of the estimated 8.2 million people missing. A similar effort to increase registration was seen in 2019, with more than 3 million people registering to vote between the 29^th Oct 2019 and the 26^th Nov 2019.[14] In the run up to general elections, EROs are under huge pressure dealing with sometimes upwards of 100,000 registration applications per day, putting enormous strain on electoral services. In 2017, duplicate applications during the election period ranged from 30% to 70% of applications by area.[15]

Automatic Voter Registration (AVR)

A system of automatic registration would see voters added to the electoral rolls using existing data without the need to initiate the registration process themselves (this is not far from the ‘route 1’ process of the reformed annual canvass that currently takes place as described above). Once the electoral rolls have been populated, voters are contacted and given the opportunity to apply for anonymous registration.[16] Most countries use a form of automatic registration.[17]

Automatic voter registration is different from assisted registration in which voters are prompted to apply for registration during other interactions with government offices – such as when applying for driver’s licence (see final section).

In a feasibility study into the use of automatic, more automated and assisted registration, the Electoral Commission found that “all the reforms were feasible from a technical and operational perspective and could be implemented without radically altering the structure of the electoral registration system in the UK.”[18]

In 2023, the Electoral Commission highlighted how AVR could be implemented with Passport Office data. The Passport Office already undertakes rigorous checks on the information provided, collects the data needed for electoral registration and is already sharing this data with government departments to undertake around 25 million identity checks per year.[19]

There is widespread and longstanding cross-party parliamentary support for automatic voter registration including from the Political and Constitutional Reform Committee in its 2014 report on Voter Engagement, the All-Party Parliamentary Group on Democratic Participation’s report on the Missing Millions, and the Levelling Up, Housing and Communities Committee report on Electoral Registration in 2024.[20] [21] [22]

Devolved elections

Electoral registration for local registers is devolved in Scotland and Wales and the Welsh government has recently legislated via the Elections and Elected Bodies (Wales) Act (2024) to pilot AVR.[23] In Scotland there have been cross-party calls for the introduction of AVR, with an amendment to the Scottish Elections (Representation and Reform) Act which enables AVR to be pursued at local authority level.[24] Glasgow may be the first place to trial AVR.[25]

Wales AVR pilots

In 2025 three Welsh councils piloted automatic voter registration (a fourth council tested just data-matching to see whether the electoral register could be re-created from local data).

The pilots identified and automatically registered 14,500 new electors. This represents between 2% and 8% of the registers in these areas (Gwynedd 8%, Powys 5%, Newport 2%). The pilots were particularly successful in registering attainers. Between 16% and 37% of attainers were added in Gwynedd and Powys.[26]

The pilots were able to utilise local data such as council tax and housing records to match residents. However, the pilots could not access UK level datasets (such as the DWP) and as a result, despite very positive results, there were limits to how effective the pilots could be. The Carmarthenshire pilot, which looked at re-creating electoral rolls, found that 60% of existing electors can be matched on local data. A UK-wide system of AVR with national data therefore has the potential to have an even greater impact.

The Electoral Commission review of the pilots found in initial assessments, that AVR did not negatively affect the accuracy of the registers and there were few concerns raised from those in the pilot areas.[27]

Important considerations

Edited/open register

The UK currently has two versions of the electoral register: the full electoral register and the open register (sometimes called the edited register). The full electoral register contains the name and address of everyone who has registered, it is restricted and is only accessible for certain purposes including electoral administration, campaigning activities, preventing and detecting crime, checking applications for loans or credit, and jury summoning in England, Wales and Northern Ireland.

Whilst the responsibility for registration (whether initiating or confirming) currently lays with the individual, registration is still compulsory and citizens can be fined for not registering.

EROs are also required to create an open register. The open register contains the names and addresses of anybody who has not opted out (those under 16 are automatically removed). At present around 60% of those registered have opted out of the open register.[28] The open register is available for purchase by private individuals, companies or organisations and there are no restrictions on its sale.

The open register would need reviewing under a system of automatic registration and our recommendation would be that automatically enrolled citizens do not have their data shared on the open register, effectively removing this register.

Anonymous registration

Anonymous registration would still be possible under AVR. If AVR is introduced, it is paramount that those currently registered anonymously are contacted and informed of the changes to the system. They should then be supported by local authorities to ensure that they remain anonymous. For this reason, there should be a designated period of time in which it is the responsibility of the local authority to contact all anonymous voters and assist them with entering the register. The Welsh pilots allowed for 60 days in which to respond to request anonymous registration. Once an anonymous registration is in place it should remain so for a longer period of time than the current 12 months.

 

Lessons from overseas

Many countries register their voters automatically. Some examples are:

Sweden

All persons who qualify to be included on the Swedish Tax Agency’s population register 30 days before the election day are automatically registered and mailed a polling card. In 2022, the voting age population of Sweden was 8.15 million and 7.78 million people were registered to vote.[29]

Germany

Germany has a system of automatic voter registration which uses their national population register. Every resident in Germany is required to register with their municipal authority when they move home and the municipal authorities utilise this data to create the electoral roll. In 2025 the voting age population was 61.5 million and 60.5 million people were registered to vote.[30]

Australia

Australia has a system of direct enrolment which uses data from other government agencies to identify and verify people to add to or update the register.[31]  The Australian system is an ‘opt out’ rather than ‘opt in’ system in which voters are automatically added if they don’t respond to the notification (similar to ‘route one’ in the UK described above). 97.6% of Australian electors are on the register compared to 90.9% in 2010 before the introduction of automatic registration.[32]

Australia moved to automated registration from a system of continuous registration (self-enrolment) within 18 months. The enabling legislation was passed in June 2012, pilots ran in late 2012 and then was rolled out across the rest of the country by the September 2013 elections. Further improvements were made subsequently, enabling voters to self-register online and further outreach activities. [33]

 

Assisted/integrated registration

Often termed “motor-voter” registration after the initiative in the US, assisted registration would nudge people to register to vote when they interact with other government services. The USA’s National Voter Registration Act of 1993 (NVRA) required that states offer voters the opportunity to register to vote at motor vehicle agencies and specific state and local offices.  Any application for a driver’s license (including a renewal) serves as a voter registration application unless the applicant does not sign the application. It may also be used to update an existing registration.[34] In 2022, over half of US electoral registrations came via this route.[35]

A similar system could be implemented in the UK when a potential voter interacts with a government agency, such as the DVLA. This could be done via a tick box on paperwork required to obtain a driver’s licence which would give the DVLA permission to pass on the information necessary to register to vote to the local Electoral Registration Officer. In 2024-2025 the DVLA issued 12.5 million driving licenses. An assisted registration system would allow these 12.5 million applications to be checked and updated against the electoral role helping to maintain the accuracy and completeness of the register.[36]

Researchers have highlighted several other touchpoints with government services where potential voters could be nudged to update their details or register to vote:[37]

• Applying for a passport: 7,800,233 people applied for a passport in 2024[38]
• Registering for council tax: 24,926,000 dwellings were liable for council tax in 2024[39]
• Updating driving licence details: 12,500,000 driving licences were issued in 2024/2025[40]
• Registering at university: 2,904,425 undergraduates and 847,905 postgraduates enrolled in higher education in 2023/2024[41]
• Claiming benefits: 23,200,000 people claimed some form of DWP benefit in February 2025.[42] [43]

This equates to over 72 million points of contact between government bodies and potential voters per year, all of which could be used to update and enrol people on the register through assisted registration. There will undoubtedly be crossover between these groups, however, these points of contact could, especially in conjunction with AVR, help to keep the electoral registers up to date.

 

 

 End Notes

[1]  The Electoral Commission, “2023 report: Electoral registers in the UK”, 2023. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/accuracy-and-completeness-electoral-registers/2023-report-electoral-registers-uk

[2] (Cities of London and Westminster (20.3%), Leeds Central and Headingley (20.2%), Bristol Central (19.6%), Sheffield Central (19.5%)).[2] Estimates are based on ONS 2021 Census and Scottish Census 2022 population figures and Electoral Commission data on registration levels by housing tenure. https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/automatic-voter-registration-avr-briefing/

[3] Electoral Reform Society, ‘A System Out of Step: The 2024 General Election’, 2024. Available at: https://electoral-reform.org.uk/a-system-out-of-step-the-2024-general-election/

[4] https://yougov.co.uk/politics/articles/49960-what-electoral-reform-proposals-would-britons-support

[5] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/833308/Reform-of-the-Annual-Canvass-Statement-of-Policy.pdf

[6] Figures based on the December 2022 electoral rolls. https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/2023-report-electoral-registers-uk

[7] Electoral Commission ‘2023 report: Electoral registers in the UK’, 2023

Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/2023-report-electoral-registers-uk

[8] Garnett, Holly Ann, Toby S. James, and Sofia Caal-Lam. 2025. Year in Elections Global Report 2025. The Electoral Integrity Project. https://www.electoralintegrityproject.com/reports

[9] Electoral Commission, ‘Who is and isn’t registered to vote’, 2022. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/explore-data-who-and-isnt-registered-vote

[10] Ibid.

[11] https://www.gov.uk/government/statistics/chapters-for-english-housing-survey-2024-to-2025-headline-findings-on-demographics-and-household-resilience/chapter-3-housing-history-and-future-housing

[12] James, T. S., & Clark, A. (2019). Electoral integrity, voter fraud and voter ID in polling stations: lessons from English local elections. Policy Studies, 41(2–3), 190–209. https://doi.org/10.1080/01442872.2019.1694656

[13] GOV.uk, “Register To Vote Performance. Applications breakdown 22/05/24 to 16/06/24”. Available at:  https://www.registertovote.service.gov.uk/performance/applications_breakdown/with_dates?fromDay=22&fromMonth=05&fromYear=2024&toDay=18&toMonth=06&toYear=2024

[14] Rowena Mason, “Voter registration rise boosts Labour’s election hopes”, The Guardian, 2019. Available at:  https://www.theguardian.com/politics/2019/nov/26/voter-registration-rise-boosts-labours-election-hopes

[15] The Electoral Commission, “Urgent reforms needed to get millions of people registered to vote”, September 2023. Available at: https://www.electoralcommission.org.uk/who-we-are-and-what-we-do/changing-electoral-law/a-modern-electoral-register/modernising-electoral-registration-feasibility-studies/electoral-registration-need-reform

[16] Anonymous registration is available for anyone who feels that being on the register could impact their safety or the safety of anyone in their household. https://www.electoralcommission.org.uk/voting-and-elections/register-vote/register-vote-anonymously

[17] Toby. S. James and Paul Bernal (2020) Is it time for Automatic Voter Registration in the UK? Joseph Rowntree Reform Trust: York. https://www.jrrt.org.uk/wp-content/uploads/2020/04/Is_it_time_for_AVR_in_the_UK.pdf

[18] Electoral Commission, ‘Modernising electoral registration: feasibility studies’, 2019

https://www.electoralcommission.org.uk/news-and-views/our-priorities-reforming-elections/a-modern-electoral-register/modernising-electoral-registration-feasibility-studies

[19] Electoral Commission, “2023 report: Electoral registers in the UK”, 2023. Available at:

https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/accuracy-and-completeness-electoral-registers/2023-report-electoral-registers-uk

[20] House of Commons Political and Constitutional Reform Committee, “Voter engagement in the UK”, Fourth Report of Session 2014-2015, 2014. Available at: https://publications.parliament.uk/pa/cm201415/cmselect/cmpolcon/232/232.pdf

[21] Toby James, Bite the Ballot and Alistair Clark, “Missing Millions Still Missing: A Vision for Electoral Modernisation in the UK”. All Party Parliamentary Group on Democratic Participation, 2019. Available at: https://tobysjames.com/wp-content/uploads/2019/08/missing-millions-still-missing-1.pdf

[22] House of Commons Levelling Up, Housing and Communities Committee, “Electoral Registration” Fourth Report of Session 2023-2024, 2024. Available at: https://committees.parliament.uk/publications/43968/documents/217860/default/

[23] https://www.gov.wales/wales-passes-landmark-bill-introduce-automatic-registration-electors-and-modernise-electoral

[24] https://www.legislation.gov.uk/asp/2025/4/part/7

[25] https://www.glasgowlive.co.uk/news/glasgow-automatic-voter-registration-pilot-31321525

[26] Electoral Commission, ‘Automatic registration pilots evaluation’, 2025. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/automatic-registration-pilots-evaluation

[27] Ibid.

[28] House of Commons library, ‘Electoral registers and access to them’, 2026. Available at:

https://commonslibrary.parliament.uk/research-briefings/sn01020/

[29] International IDEA voter turnout database https://www.idea.int/data-tools/data/voter-turnout-database

[30] ibid

[31] Australian Electoral Commission website, https://www.aec.gov.au/Enrolling_to_vote/About_Electoral_Roll/direct.htm

[32] https://www.jrrt.org.uk/wp-content/uploads/2026/01/Towards-Automatic-Voter-Registration-Lessons-from-Canada-and-Australia-FINAL.pdf

[33] Sonali Campion, Professor Toby S. James & Professor Holly Ann Garnett ‘Towards Automatic Voter Registration: Lessons from Canada and Australia’. Available at: https://www.jrrt.org.uk/wp-content/uploads/2026/01/Towards-Automatic-Voter-Registration-Lessons-from-Canada-and-Australia-FINAL.pdf

[34] https://www.justice.gov/crt/national-voter-registration-act-1993-nvra

[35] Professor Toby S. James and Professor Paul Bernal, ‘Improving Voter Registration: A GUIDE TO INTRODUCING AUTOMATIC VOTER REGISTRATION’. Available at: https://ueaeprints.uea.ac.uk/id/eprint/98707/1/A-Guide-to-Improving-Voter-Registration-Report-Final.pdf

[36]  DVLA, Annual Report & Accounts 24/25 https://assets.publishing.service.gov.uk/media/687e00805f0f5104b9806beb/DVLA_annual_report_and_accounts_2024_to_2025.pdf

[37] Professor Toby S. James and Professor Paul Bernal, ‘Improving Voter Registration: A GUIDE TO INTRODUCING AUTOMATIC VOTER REGISTRATION’. Available at: https://ueaeprints.uea.ac.uk/id/eprint/98707/1/A-Guide-to-Improving-Voter-Registration-Report-Final.pdf

[38] Government statistics, passport and citizenship data https://www.gov.uk/government/publications/passports-and-citizenship-data-q4-2024

[39] Government statistics https://www.gov.uk/government/statistics/council-taxbase-2024-in-england/local-authority-council-taxbase-in-england-2024

[40] DVLA, Annual Report & Accounts 24/25 https://assets.publishing.service.gov.uk/media/687e00805f0f5104b9806beb/DVLA_annual_report_and_accounts_2024_to_2025.pdf

[41]  Higher Education Statistics Agency https://www.hesa.ac.uk/data-and-analysis/sb271/figure-3

[42] These include: Attendance Allowance, Benefit combinations, Bereavement benefits, Bereavement Support Payment, Carer’s Allowance, Disability Living Allowance, Employment and Support Allowance, Housing Benefit, HB flows, Incapacity Benefit, Income Support, Industrial Injuries Disablement Benefit, Jobseeker’s Allowance, Pension Credit, Personal Independence Payment, Severe Disablement Allowance, State Pension, Universal Credit, Widow’s Benefit

[43] Government statistics https://www.gov.uk/government/statistics/dwp-benefits-statistics-august-2025/dwp-benefits-statistics-august-2025#:~:text=24%20million%20people%20claimed%20some,million%20were%20of%20Working%20Age

First reading in House of Commons: 10 July 2025

Second reading in House of Commons: scheduled for 2 September 2025

Guidance from Ministry of Housing, Communities and Local Government on the English Devolution & Community Empowerment Bill →

Voting system for Mayors and PCCs

We welcome the reversal of the previous government’s decision to move to First Past The Post (FPTP) for Mayoral and Police & Crime Commissioner (PCC) elections.

Ever since the move to FPTP was announced, we have made the case that there is a high risk of powerful (increasingly powerful in the case of Strategic Authority Mayors) figures being elected with weak mandates and the consequent danger that their legitimacy is called into question when they need to make important decisions affecting their areas.

On 1 May 2025, under FPTP, two Strategic Authority mayors were elected with the support of fewer than 30% of those who voted. Around three-quarters of people who cast a vote in these elections did not vote for the winning candidate.

Prior to the introduction of FPTP, across twenty-one Strategic Authority mayoral elections (including elections for the Greater London Mayor) held under the preferential, Supplementary Vote (SV) electoral system, in all but one contest, the winning candidate received the support of at least 44% of those who voted, either via a first or second preference vote. This level of support represents a much more solid mandate for mayors to take up their positions.

Although SV, where voters can express a first and second preference, is much better than FPTP, an even better system for the election of Mayors and PCCs would be Alternative Vote (AV).

While AV is not a proportional system, it is the best option when it comes to the election of individual office holders such as mayors. In these scenarios it is the closest match to our preferred Single Transferable Vote (STV) electoral system, as seen in Scottish local elections. Standard Scottish local authority elections are contested in multi-member wards, under STV. For local authority by-elections, however, where just one candidate is to be elected, AV is used.

Under AV, voters can express a preference for as many or as few as the candidates as they wish, simply by marking ‘1; 2; 3 etc’ on their ballot paper.

If a candidate obtains more than 50% of first preference votes, they are elected. If no candidate reaches this threshold, the person with the fewest votes is eliminated and the second preferences of the voters who supported the eliminated candidate are transferred to the relevant remaining candidates. This process is repeated until one candidate reaches the threshold and is declared the winner.

AV is superior to SV in that it allows voters to express a wider range of preferences; it reduces the need for voters to consider tactical voting; it reduces the likelihood of wasted votes; and it would mean mayors being elected with as strong a mandate as possible from the local electorate.

English local government voting system

The government’s planned reorganisation of English local authorities, with unitary authorities set to be rolled out across the country, provides an excellent opportunity to examine how councillors are elected in England.

The use of First Past The Post at local authority level often results in councils that do not reflect voters’ preferences, particularly in this age of multi-party politics. At the local elections held on 1 May 2025, Reform UK won overall control of numerous local authorities without securing the backing of the majority of local voters. In West Northamptonshire, for example, Reform UK won a majority of council seats (55.3%) from just 28.3% of votes cast across the area. It cannot be right for one party to have full control of a council and the important responsibilities that come with this, when almost three-quarters of voters have not shown any backing for that party.

The Single Transferable Vote (STV) is a voting system very well suited to ensuring that voters preferences are properly reflected on local councils and it is already in use for local elections in Scotland and Northern Ireland. As with AV, the system is very simple for voters, allowing them to express a preference for as many or as few as the candidates as they wish, simply by marking ‘1; 2; 3 etc’ on their ballot paper.

Rather than one person representing everyone in an area, a number of representatives are elected. This situation already applies across much of English local government, with many wards electing three councillors.

Under STV, the persons elected to represent a ward are much more likely to represent the diversity of opinion within a ward than is the case under FPTP. At council level, STV makes it far less likely that single parties will earn underserved majorities based on as little as a third of votes.

The introduction of STV for English local council elections should be included in the English Devolution & Community Empowerment Bill, in a similar way that the Labour-led Scottish government legislated for the use of STV for Scottish local elections in the mid-2000s.

Neighbourhood governance

The Guidance notes to the Bill indicate that the government ‘will introduce a requirement on all local authorities, in England, to establish effective neighbourhood governance’, with the ‘main goal…to move decision-making closer to residents, so decisions are made by people who understand local needs’.

The details of the obligations on local authorities will be set out in regulations that will be made after the Bill is in force, following a government review that will ‘include speaking to the sector to ensure they have the opportunity to contribute and share existing good practice’.

Given that local authority unitarisation will create new councils covering much larger areas than many current district councils, there is a danger that some voters may come to feel further away from local democracy. It is therefore vital that neighbourhood governance is treated as an important part of this legislation and not merely an after-thought.

Local people should have the opportunity to genuinely engage with how neighbourhood governance will work in their communities.

Awareness

The Committee considers a key part of transparency and trust is ensuring that the right information is available.  We would be keen to know: 

• Whether you would know how to access the information on what donations Politicians have received? If so, which sources do you use? 
• Whether you think that information is sufficient about donations and what information you would expect to be available about donations? 

Transparency is a fundamental principle of political finance regulation. Appropriate transparency measures can ensure that voters are aware of who is funding campaigns and that regulators have the tools to ensure that political finance rules are being met. Transparency is also fundamental to deterring corruption.

The UK Electoral Commission political finance database is considered world leading in the accessibility and breadth of information available.[1] Donations and loans (that meet the thresholds for disclosure) are searchable for parties and for candidates.

For Senedd elections, spending returns and total donations received are reported, for parties and candidates, in a searchable format online. Having both publicly available information and online searchability is considered best practice for transparency. However, details of donations below the national disclosure threshold are not reported, and full individual candidate spending returns are only available to the public on request from the Returning Officer.

The thresholds for reporting donations to the Electoral Commission have increased in recent years. Now only donations to candidates over £2,230 from a single source need to be registered with the Electoral Commission, and only donations over £11,180 to parties. These limits (even before the increase) are, by international standards, quite high, meaning many donors and donations do not meet the threshold for transparency. The average threshold for donation disclosure across EU Member states in 2,400 Euros. There is a strong argument that the UK threshold is, particularly after the increase, set too high.

However, the type of information available and accessibility of the data remains a strong part of the UK’s political finance regime. One area that hinders transparency in donations and spending is the length of time between an election and the publications of returns. Spending returns for parties spending over £250,000 in the 2021 Senedd election were not reported until February of the following year. The Committee on Standards in Public Life has previously recommended reducing these timescales so that the information is available in a timely way.[2]

Many countries have moved to reporting either in real time or much more directly, and advances in technology allow for streamlining this process without additional administrative burden, improving transparency for voters.

Value of Donations

At present there is a monetary threshold for registration of a donation having been received, but there is no limit on the amount of money that can be donated.

We would be keen to know:  

• How much discretion do you think politicians should have in the amount of money they accept? 
• Do you think there should be a limit on the amount donated for specific campaigns, and if so, what should this limit be from: a) individuals; b) companies; c) charities; d) other organisations; or e) for the entire campaign 

Rules around donations typically seek to ensure that there is a ‘level playing field’ for electoral participants so the electorate is enabled to vote for their preferred candidates and policies. They may also seek to prevent distortion caused by foreign interference and ensure that those with the deepest pockets are not able to have an undue influence over campaigns, to safeguard against corruption and maintain a fair contest. This is essential for public trust in the system.

Whilst there are limits on spending, there are currently no limits on donations. This creates a space for individual, corporate or other interests to have an outsized impact on the financial flows to parties and candidates. Both the total amount of political donations and the size of donations has been increasing. Transparency International found that in 2023, £56.5 million of the total £85 million of reported contributions from private sources that year came from just nineteen donors. In addition, TI found that since 2001, almost 1 in every 10 pounds of reported donations has come from either unknown or questionable sources.^[3] Whether it’s parties or candidates, reliance on a small number of wealthy donations can distort politics and open up the potential for corruption. A donations limit is not only better for preventing undue influence, but protects political parties and representatives from risky fundraising behaviours.

A Welsh example of controversy related to donations was the £200,000 donation to Vaughan Gething MS, at the time when he was a candidate in the Welsh Labour leadership contest. This led to significant debate within the Senedd, and ultimately, to him standing down. This is likely to have had a negative impact on public trust in the system as a whole.

Many countries place limits on donations. Canada for example has a limit of $1,750 maximum total donations to a party by an individual in a year (the same limit applies to total donations to election candidates and leadership candidates).^[4] Most Northern, Western and Southern European countries also have individual donation limits, either annual or for electoral contests, (ranging from 2,500 Euros in Ireland to 50,000 Euros in Spain).

In 2011, the Committee on Standards in Public Life recommended a donation limit of £10,000 each year.^[5] This would be high by international standards but was seen as appropriate in the UK context. A lower limit might be appropriate for specific electoral contests, and it would be sensible to consider donations limits alongside spending limits, as well as considering the period in which the limit is in effect (whether annual or contest related) to ensure that regulations are compliementary.

There are clear spikes in donations during electoral cycles, but it is also understood that much activity also happens outside of regulated periods, and campaigning can take place all year round, every year. Restricting donations for a regulated period would not necessarily prevent larger donations being made outside of that.

Additional Accountability

The Senedd currently records information about donations on the individual Member’s register of interest and the information is also published on the Electoral Commission website. 

There is no other requirement on Members to record any interaction with individuals or groups. 

• Would you expect people/individuals donating to politicians to declare or register information somewhere? 
• Do you think the various ways, other than financial ones, in which Members can benefit should be recorded (such as the use of resources / facilities / services etc..)? 
• Do you think that the Senedd needs a method for recording interactions, other than financial ones, by any particular group of people with Members?

Outside of donations, the main areas of concern are gifts and hospitality, the funding of foreign trips, and the funnelling of funds through third parties.

The Senedd Register of Members’ Interests covers most of the categories of gifts and benefits.

Whilst foreign trips are registered, there are no restriction on the funders of those trips, which leaves open the possibility of foreign states seeking influence through funded visits.

In addition, there are still gaps in the framework around Unincorporated Associations (UAs) and the source of funds that come through UAs. Similarly on corporate donations, there are currently still loopholes that allow for funds made outside the UK to be funnelled through shell companies. Knowing the name and address of the entity that makes the donation is often not enough to ensure that the donation comes from a permissible source.

The onus is typically on the candidate or party accepting the donation rather than the donor and there is a strong case for having robust know-your-donor checks to protect parties and candidates, and for entities that receive and collate donations such as Unincorporated Associations to be required to enhance their permissibility checks.

Outside of the financial rules, one clear gap in how interactions are recorded between MSs and organisations or campaigning groups is a lack of a lobbying register in Wales. At present, the guidance on lobbying and access to Members of the Senedd is not extensive, indicating that “members should consider” a number of steps, including taking records and notes of any meeting with those they consider to be lobbyists.^[6] The lack of mandatory record keeping and strong guidance, risks inconsistency between members when capturing information around meetings. Given the guidance also does not require the publication of such information, there is a lack of transparency for the public who have no way of accessing information about meetings their elected members have undertaken.

As such, we would recommend that a lobbying register is introduced ahead of the seventh Senedd. This would bring the Senedd into line with the register in operation in Scotland,^[7]  and at a UK level.  

[1] International IDEA (2022) Regulating the Business of Election Campaigns: Financial transparency in the influence ecosystem in the United Kingdom, https://www.idea.int/publications/catalogue/regulatingbusiness–election–campaigns

[2]  CSPL (2021) Regulating Electoral Finance https://assets.publishing.service.gov.uk/media/60e460b1d3bf7f56801f3bf6/CSPL_Regulating_Election_F inance_Review_Final_Web.pdf  

[3] Transparency International (2024) Checks and Balances: Countering the influence of big money in politics https://www.transparency.org.uk/publications/cheques–and–balances–countering–influence–bigmoney–uk–politics  

[4] This amount increases each year.

[5] https://www.gov.uk/government/publications/political–party–finance–ending–the–big–donor–culture

[6] https://senedd.wales/how-we-work/code-of-conduct/guidance-on-lobbying-and-access-to-members-of-the-senedd

[7] https://www.lobbying.scot/

Part 1: Guidance for political parties about developing, publishing, implementing and regularly reviewing diversity and inclusion strategies for local and national Welsh elections

Question 1: The Welsh Government must specify the characteristics and circumstances for the purpose of Parts 1 and 2 of the guidance. What are your views on the specified characteristics and circumstances? For ease, they are listed here:

• Age*
• Disability*
• Race*
• Religion or belief*
• Sex*
• Sexual orientation*
• Trans status or history (including gender reassignment*)
• Socio-economic background
• Health conditions
• Previous political experience
• Caring responsibilities
• Parental responsibility
• Language

* Protected characteristics as defined by the Equality Act 2010

We are broadly supportive of the characteristics and circumstances listed for the purpose of Parts 1 and 2 of the guidance. This appears to be consistent with the Local Government Candidate Survey, however we do believe there should be a balance between gathering the information needed and ensuring the survey isn’t overly extensive, to maximise the number and usefulness of responses.

Research into the impact of survey length on response rate indicates that shorter surveys obtain a higher response rate. A number of staff members at ERS Cymru have tested the proposed template survey and found it to be under five minutes to complete on average, which we imagine would vary depending on the nature of an individual’s response (i.e. if you have more protected characteristics to declare).

Question 2: Please indicate your level of agreement with the suggested actions for political parties to take to increase diversity and inclusion in Welsh elections?

Strongly agree

2a: Please explain your reasons for your rating of agreement with the suggested actions for political parties to take to increase diversity and inclusion in Welsh elections.

We were supportive of the statutory gender quotas outlined in the Senedd Cymru (Electoral Candidate Lists) Bill and were disappointed with the Bill’s withdrawal. As such, while these measures are not statutory we do welcome them. With no formal quotas being introduced, parties’ actions to improve diversity and inclusion and the data around this are even more important.

However, we do remain concerned about the voluntary nature of these measures. They will only be effective if all parties returned to the Senedd in 2026 adopt them. We will be working with the parties to support them in this, alongside WEN Wales, Race Council Cymru and EYST Wales as part of the Diverse 50:50 campaign.

Yet, it is important to consider how wider support can be offered to political parties to help them to utilise these measures. With each party in theory taking on the same or similar measures, regardless of their size, there could be a central hub for information or support, potentially through the new Electoral Management Board of the Democracy and Boundary Commission Cymru.

Question 3: Are there other things which you think political parties need to consider in developing, publishing, implementing and reviewing diversity and inclusion strategies for Welsh elections? If so, what?

Parties must properly consider issues around data protection and anonymisation. Parties must ensure data is disaggregated so it does not easily identify individuals’ complete responses. They should also ensure they have the structures to hold this data securely.

We are happy that this guidance is comprehensive and strikes the right balance between effective, if utilised properly, and hopefully not too overburdening for parties. However, parties’ feedback should be a key part of considering this.

Part 2: Guidance for political parties standing candidates at Senedd elections on collecting, collating and publishing diversity information relating to candidates and elected Members

Question 4: What are your views on the candidate survey questions in Part 2?

We are broadly supportive of the candidate survey outlined in the template and in the draft guidance.

As outlined in our response to question 1, we are confident that this is consistent with the Local Government Candidate Survey, however are mindful that this should be balanced with something people will actually want to complete. Response rates for the Local Government Candidate Survey have historically been low (12% in 2022) and it is worth considering why this is. Any learning from low uptake of the Local Government Candidate Survey should be applied to this survey of candidates for the Senedd too.

Parties should be encouraged to use this template to ensure consistency and that when published, parties’ performances around diversity and inclusion, in terms of the selection of their candidates, are easily accessible and comparable.

Question 5: Do you think the guidance will help political parties to collect, collate and publish diversity information on Senedd candidates?

Yes – depending on uptake

5a: Please explain why you think this guidance will / will not help political parties to collect, collate and publish diversity information on Senedd candidates.

The lack of official data on the diversity of candidates and elected representatives is a significant issue that has yet to be addressed. Existing data around the diversity of candidates and Members of the Senedd is not based on official figures and this could go some way to addressing that.

The limited information currently available on the diversity of the Senedd is largely restricted to those elected as MSs and not the candidates that stood (apart from gender representation where some candidate data is available). This guidance on collecting, collating and publishing diversity information on Senedd candidates will help to provide an important missing link in the information chain. To understand where barriers to election lie we need both diversity information on those who stand as candidates and those who are then elected.

This allows parties and electoral stakeholders to identify barriers at specific stages of the process i.e. whether there are barriers in terms of candidate selection or candidate placement on lists.

It also allows for measuring the effectiveness of a party’s strategy on diversity and inclusion. For example, the effectiveness of approaches taken around voluntary gender quotas.

This is the first time guidance has been developed centrally to help parties to collect, collate and publish diversity information on Senedd candidates. The reality is that it doesn’t matter how strong the guidance is, due to its voluntary nature it is the uptake that will make it successful or not successful. The responsibility will be on political parties to implement these measures and ensure they are collecting and publishing this data.

In terms of the timescales on reporting back on diversity information gathered we are supportive of the six weeks proposed.

If parties do adopt the guidance it is worth considering how the guidance evolves over time after parties have used it and fed back. This should be a relatively iterative process.

Over the longer term the Welsh Government should engage the UK Government to see whether further powers could be devolved allowing for statutory measures around equalities in relation to elections to be implemented.

Part 3: Guidance for political parties standing candidates at Senedd elections on voluntary quotas for women

6a: Please explain why you think this guidance will / will not support political parties to take appropriate steps to achieve better gender representation in the Senedd.

We welcome the inclusion of voluntary quotas in the guidance, in lieu of the statutory quotas outlined in the now withdrawn Senedd Cymru (Electoral Candidate Lists) Bill. While we remain disappointed that this Bill was withdrawn, if parties take voluntary quotas seriously they could have a big impact. Voluntary measures in Wales have had an impact on gender representation in the past. The relatively high levels in terms of the representation of women in the Senedd has historically been reliant on voluntary measures. These include political parties taking positive action around the selection of their candidates and the placement of these candidates in winnable constituencies or high on lists, for example through the use of All Women Shortlists and Zipping.

This effect of voluntary measures impacting gender representation can be seen at the 2021 Senedd elections where 31% of candidates were women but 43% of elected MSs are women. This increase in womens’ elected representation compared with the candidate pool was in part due to positive action by specific parties, namely Welsh Labour, who returned 30 MSs, 17 (56.7%) of whom are women.

While this was a positive outcome for women’s representation in the 6th Senedd, it is heavily reliant on specific parties winning seats. Continued levels of party representation can never be guaranteed at future elections, and with the new electoral system coming in for the 2026 Senedd elections the results are even more likely to be different, thus highlighting the importance of every party committing to voluntary quotas for women ahead of 2026.

The new Closed List electoral system will allow for quotas to be easily implemented but parties will have to think carefully about their placement of women candidates to ensure the representation of women in the Senedd does not backslide.

The three dimensions of quotas outlined in the guidance (representation threshold, vertical criteria and horizontal criteria) are vital and should be used by parties in combination to maximise the effectiveness of voluntary quotas. Parties should also consider polling and past performance (although difficult in the first Closed List elections in 2026) to also consider where winnable seats may be.

In the course of work around the Senedd Cymru (Electoral Candidate Lists) Bill ERS Cymru produced some modelling of the effects quotas might have if implemented.

This modelling shows that quotas, while likely to have a positive impact on the representation of women in the Senedd, still requires parties to play an active role in considering where to place women at the top of electoral lists.

This can be seen in more detail in our written evidence to the Bill and should be considered by political parties when selecting candidates.

The most significant factor in the success of the voluntary quotas will be uptake by the political parties. Unless all parties represented in the Senedd after 2026 use voluntary quotas, its success will be limited.

Question 7: Are there other measures you think political parties could take to achieve a gender balanced Senedd? If so, what?

In terms of what else the political parties could do to help ensure a gender balanced Senedd we believe that timing is key. One issue likely to arise is that parties are already positioning candidates for 2026, even ahead of the final boundaries being published. That could put this guidance at risk of being published after the horse has already bolted. Parties should be playing an active role in the development of this guidance and having discussions within their leadership now ahead of any selections.

At the same time the Welsh Government should be playing their part in ensuring timely conversations with parties around this guidance and that it is published as soon as possible.

Final comments

Question 10: We have asked a number of questions in respect of the different parts of the guidance. Do you have any other thoughts you would like to share with us on the guidance?

We strongly welcome the publication of this draft guidance on diversity and inclusion. It is vital that the Senedd is properly representative and reflective of the people it serves. The Senedd has an important scrutiny function to undertake and a more diverse Senedd ensures that a wider range of lived experiences are taken into account on a day-to-day basis.

For this guidance to be effective, the political parties should engage and commit to implementing these processes.