With around 84.5 million inhabitants, Germany is the most populous country in western Europe. A German Federal election, where representatives are elected to the Bundestag (Germany’s national parliament), is therefore always an important event. From our perspective, it is particularly interesting to explore the outcomes of a major election that is conducted under a system of Proportional Representation (PR).

How the voting system works in Germany 

Since the Federal election of 1953, the second post-World War II election held in the Federal Republic of Germany, a Mixed Member Proportional (MMP) electoral system has been used for German Federal elections. In the UK, we describe this electoral system as the Additional Member System (AMS).

In this system, a number of representatives are elected in First Past The Post (FPTP) constituency seats and a number of ‘additional’ representatives are elected via a Party List system. The election of ‘additional’ representatives seeks to make the overall result of the election more proportional than it would have been if representatives were elected only via First Past the Post.

Different MMP or AMS systems seek to achieve different levels of proportionality. Germany’s MMP system is at the very proportional end of that scale, with the overriding aim being for a party’s seat share in the Bundestag to closely match the party’s vote share in the Party List section of the election.

One of the ways this is achieved is by having more Bundestag seats reserved for members elected via the Party List section (331 seats) than via the FPTP constituency section (299 seats). In contrast, the AMS system used for Scottish Parliament elections has more FPTP constituency seats (73) than Party List seats (56), meaning that Scottish Parliamentary election outcomes are often slightly less proportional than those for German Federal elections.

MMP systems allow us the interesting opportunity to explore how an election result might have looked if it had been conducted using FPTP, without the ‘additional’ seats that make the overall result more proportional.

What happened this time? 

In this regard, the results from the 2025 German Federal election are striking. The CDU/CSU alliance came top in 190 of the Bundestag’s 299 FPTP constituency seats*. This represents nearly two-thirds (63.5%) of the FPTP constituency seats, on the basis of just under one-third (32.1%) of votes across the FPTP constituency seats.

This outcome is remarkably similar to the 2024 UK general election, held under FPTP, where Labour won 63.2% of seats, on the basis of 33.7% of votes, which was the most disproportional election in the history of the UK.

The voting system does a far better job of reflecting the wishes of voters 

The difference between the German and UK electoral systems are the ‘additional’ seats that that mean the outcome of the 2025 German Federal election much more closely reflects how people voted than the 2024 UK general election did. Therefore, despite winning two-thirds of the FPTP constituency seats, the CDU/CSU won only one-third (33.0%) of Bundestag seats overall because its overperformance in the FPTP constituency section meant it was entitled to very few of the ‘additional’ seats.

Like many proportional systems, Germany’s includes an electoral threshold that parties need to achieve in order to enter the Bundestag. In this case a party needs to receive a minimum 5% of Party List votes across the country, or win a minimum of 3 FPTP constituencies, in order to enter the Bundestag and receive representation in line with their nationwide Party List vote.

Inevitably, some parties do not meet this threshold, which means that those parties who do reach the threshold receive slightly higher seat shares than their national Party List vote share. Despite this, there can be no denying that Germany’s MMP system has done a far better job of reflecting the wishes of German voters than the FPTP system did at last year’s UK general election. This is reflected in the below Party List vote shares and seat shares in the Bundestag:

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Fresh off the heels of voters in Germany’s northernmost state of Schleswig-Holstein, this Sunday 15th May it is North-Rhine Westphalia’s turn to elect their state parliament or Landtag. With a population just shy of 18 million, North-Rhine Westphalia is Germany’s most populous state, with this vote being a crucial test for the still young Scholz government.

But elections in all the German states are hugely important. Not just are they some of the most powerful subnational bodies in Europe, they also have a fair bit of influence at the federal level through the Bundesrat – Germany’s upper house. So, let’s take a look at the voting systems used to choose these sixteen key state parliaments.

Personalised PR

As per the national Bundestag, 13 of the 16 states use some version of the Mixed-Member Proportional (MMP) system, known in Germany as ‘personalised proportional representation’. Most states broadly follow the federal example – a set number of seats are elected by First Past the Post, with the remainder elected by PR in a compensatory manner with the possibility of additional levelling seats being added; voters have two votes, one for a local constituency candidate and one for a closed party list; and there is a 5% exclusion threshold in every state.

But there is some variation. There is no consistent electoral formula, with D’Hondt, Hare-LR and Sainte-Laguë all used by at least one state, and the default proportion of single-member seats varies from 49% in Saxony-Anhalt to 71% in North Rhine-Westphalia. Also, in states where there are small but significant national minorities, parties representing those groups – such as the Danish-Frisian SSW in Schleswig-Holstein – are exempt from the threshold.

And then we come to Germany’s two southernmost states…

Bavaria

At first glance the Bavarian model of MMP is fairly standard – 91 seats are elected in single-member districts and a minimum of 89 are elected proportionally. But, as with many things Bavarian, it’s certainly got a unique twist. The 5% statewide threshold, for instance, also applies to the First Past the Post seats. This means that it is possible for a party to win the most votes in a constituency but then forfeit the seat if their party doesn’t get enough votes elsewhere.

Voting is a bit different too. Voters still have two votes, but the second vote is for a candidate on a list rather than for a list itself (open lists rather than closed lists). It is also the sum of both votes that determines the allocation of the proportional seats rather than the second vote alone. Unlike the other states, the proportional allocation occurs in seven multi-member regions rather than statewide.

Baden-Württemberg

Baden-Württemberg’s version of MMP also makes some radical changes to the standard model. The differences start at the polling booth – voters only have a single vote which decides both the winner of the single-member constituencies and the allocation of the proportional seats (which is also done in regions rather than statewide).

But most notably, Baden-Württemberg doesn’t use party lists at all. Instead, the proportional seats are given to the best performing constituency candidates who didn’t win a seat – i.e. the strongest runners-up. This prevents the need for the large ballot papers often seen with open lists and ties the proportional candidates to an individual constituency – giving such seats a ‘second mandate’.

List PR

There are, however, three states who eschew MMP in favour of a List PR system – Saarland and the city states of Bremen and Hamburg, which together make up three of the four least populous states in Germany. Bremen and Hamburg, along with MMP states Brandenburg and Schleswig-Holstein, also have votes at 16.

Bremen’s system is a fairly straight PR system – with the vote taking place in two constituencies comprising Bremen and Bremerhaven, the two cities that make up the tiny state. Voters have five votes which they can spread between candidates however they like – including between parties and casting multiple votes for the same candidate. This is a mixture of cumulative voting and panachage. Unlike the rest of Germany, the 5% threshold is applied individually in the two constituencies rather than statewide. Bremen is also the only state where elections are every four years, like national elections, as opposed to every five.

In Hamburg, 71 seats are elected in 17 constituencies of between three and five members, with the remaining minimum of 50 seats allocated statewide in a compensatory manner – all using List PR. Hamburg uses the same ‘cumulative panachage’ system as Bremen, except Hamburgers have ten votes – five for constituency candidates and five for state candidates.

Saarlanders, however, do not get the flexibility offered to the voters of Bremen and Hamburg – instead using a closed list where voters simply vote for parties. 41 seats are elected in three multi-member constituencies, with the remaining ten compensatory seats appointed statewide – all using the D’Hondt method. Saarland’s election back in March was notable for providing the SPD with a rare single-party majority and seeing the Greens fall short of the 5% threshold by just 23 votes!

The German states certainly showcase the wide variety of different ways that proportional electoral systems can work and even coexist!

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Many countries use a bicameral political system – meaning that they have two chambers in their parliament. These parliaments are comprised of a lower house where the government is formed and day-to-day politics is carried out, like the House of Commons, and an upper house that scrutinises and revises legislation, like the House of Lords. Upper houses are sometimes referred to as second chambers or senates.

But while all lower houses in democracies share broadly similar functions and are elected with an equal as possible ratio of voters to representatives across the country, the same is not true of upper houses. Not only do they vary in terms of powers and functions, from the powerful Senates of Italy or the United States to the weak and overridable House of Lords or Austrian Federal Council, but the methods by which they are chosen differ enormously.

Some Upper Houses are directly elected

One way that an upper house is chosen is through direct popular election, though usually with a different method to that used for the lower house.

A common change in method is a different voting system. Australia, who use the majority-based Alternative Vote to elect their House of Representatives, use the proportional Single Transferable Vote to elect their Senate. While the Czech Republic, Poland, Spain and Switzerland all choose their upper houses with a non-proportional voting system in contrast to their proportionally elected lower house. There are also some, like Italy or Japan, that use the same voting system for both chambers, with some small adjustments.

Many directly elected second chambers, including Australia, Spain and Switzerland, have followed the US’s model of giving subnational units (states, provinces, etc.) equal representation regardless of population. This is designed to give less populous units a stronger voice and prevent their interests from being overridden by more populous areas. But ‘territorial representation’ can be done by other means. The Italian Senate is focused on regional representation, but it is done in proportion to population.

Elections to upper houses usually take place at the same time as elections to the lower house. Some do have longer terms, but it is by no means a universal feature. Many of those that do achieve longer terms by electing only a portion of the chamber at each election as in Australia, the US, the Czech Republic or Japan – though the latter two are elected on a different cycle to their respective lower houses.

The obvious reason for directly electing the upper house is to give it a greater level of democratic legitimacy, which enables it to better assert its own authority. It is thus not surprising that most of the more powerful upper houses are directly elected – especially those that are ‘incongruent’, i.e., have a substantively different partisan make-up to the lower house.

But the legitimacy gained through popular election is often lost through the method of election. Equal representation for subnational territories may give smaller areas parity to larger ones, but it can give a minority of the population a veto over a much larger majority – in the US Senate, small, largely rural states with one-sixth of America’s population have the same representation as the remaining five-sixths. Using a plurality or majority voting system over a proportional one also makes the chamber less representative and thus lessens its democratic legitimacy.

Upper houses that use indirect election

The other common method of choosing upper houses in Europe is through indirect election by subnational political units – often state or regional parliaments (e.g., Austria, Belgium, the Netherlands), but sometimes lower-level bodies like local councillors (France). The purpose of such chambers is often to directly represent and protect the interests of regional governments at the national level.

Although indirectly elected chambers lack the direct mandate of a popularly elected one, they are still chosen by directly elected politicians and, given the design and purpose of such political systems, it is best to think of their mandate as an extension to the one given to the regional parliaments. Most indirectly elected chambers are also appointed proportionally – both in party and population terms – avoiding some of questionable methods used to choose some directly elected upper houses.

Unlike directly elected chambers, which are often relatively powerful, there is little consensus on the strength of indirectly elected chambers. Austria’s Federal Council is very weak – other than on certain constitutional matters, it can only delay legislation as the lower house can simply override it with a simple majority vote. The Dutch Senate, on the other hand, has a full veto over the House of Representatives that cannot be bypassed.

Other Methods

Given the powers and purposes of upper houses vary so much, it is unsurprising that there are some election methods that don’t fit neatly into two categories. There are hybrids – such as the Spanish Senate, which combines direct and indirect election. The ‘unusuals’ – like the Irish Seanad, which is part indirectly elected ‘experts’, part Prime Ministerially appointed, part elected by graduates. Then there’s Germany’s Bundesrat which, although sometimes grouped with indirectly elected chambers, is appointed through state governments rather than state parliaments.

There is also the Canadian Senate, which, being entirely appointed by the Prime Minister, is probably one of the most similar to Westminster’s House of Lords. It does, however, have a fixed size of 105 and a mandatory retirement age of 75, meaning a new Senator can only be appointed when a vacancy arises. New appointments must also be made on a regional basis – with each state holding a fixed number of seats. Though there are still calls for reform, the Canadian Senate is at least not ever-expanding in size and is not dominated by certain parts of the country like the House of Lords.

And there are, of course, some countries that simply choose not to have an upper house, instead opting for a single legislative chamber. This is called ‘unicameralism’, in contrast to bicameralism, and is typically the case in smaller countries, such as New Zealand, where there are no strong subnational identities or powerful regional governments.

All 82 Free Democracies

Parline classification of principal method of delegation of upper house in the 82 countries classed by Freedom House as Free Democracies.

A Democratic Second Chamber for the UK

Around the world, countries have found different solutions to balancing democratic legitimacy and the powers of their second chambers. While the exact way the upper house is filled varies quite significantly from country to country, the one commonality between nearly all Western second chambers is that they are designed in some way to represent subnational units, be they states, provinces or regions, at the national level.

Britain remains the odd-one-out. It lacks the democratic legitimacy afforded by elections, whether direct or indirect, virtually nullifying the extent to which it can successfully exercise its scrutinising and revising functions. And it completely fails to represent the UK in all its diversity, overrepresenting some territorial units (especially London and the South East) to the detriment of the other nations, regions and localities.

Instead of a house of powerful regional representatives, we have an antiquated chamber whose membership is chosen partly by aristocrats, partly by the Church of England and largely by Prime Ministers rewarding donors and allies. We need to reform our upper house so that it can have the democratic legitimacy to do its job properly.

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With pressure mounting on Boris Johnson, it’s looking increasingly possible that Britain could well soon have a new Prime Minister. Who it would be, would be a decision for Conservative MPs and, possibly, Conservative party members. But this isn’t how things would go in every country. So, let’s take a look at how other countries choose a new Prime Minister.

Parties Choose Their Candidates

First, a political party needs a candidate. In Britain, if there are multiple candidates, both main parties choose their leader by a ballot of their party members, though they both have preliminary rounds where potential candidates are whittled down by MPs. But membership elections elsewhere are fairly rare – Canada being one of the few countries where all major party leaders are selected this way. Though this is changing, with membership elections becoming more and more common.

Across Europe, there is significant variation in how a party leader is chosen – both between countries and between parties within them. But the most common method of selection is some form of election by party delegates. While members may have some input, the final decision often rests with party officials and/or elected representatives. However, this is only the case if a vote is needed. In many European countries, it is the norm for there to only be a single candidate – with consensus being reached by party elites without need for an election.

There is also the German model where the position of Chancellor candidate is distinct from that of the party leader. The position is usually chosen by party delegates in the run-up to a federal election and, while it does normally go to the party leader, it gives parties the opportunity to recognise that different skills are required to govern than to lead a party. This has been the case with current Chancellor Olaf Scholz. He is not the leader of the SPD, rather somebody with a history of governing successfully and popularly at the state and federal level.

Positive vs Negative Parliamentarism

But, in many countries, being elected party leader is just the first step, you can’t automatically become Prime Minister just because your party is in power. Unlike in countries like the United Kingdom that operate a policy of ‘negative parliamentarism’, whereby parliamentary support for the incoming government is often assumed, many European countries opt for ‘positive parliamentarism’.

Under positive parliamentarism, a new potential government needs to explicitly prove that it is supported by parliament before it can be formed. This ‘proof’ takes the form of an investiture vote – whereby MPs vote on either the nomination of one Prime Ministerial candidate or between several. Exact rules vary from country to country, but you can’t form a government without winning it. Positive parliamentarism can be found in Germany, Ireland and Belgium, as well as the devolved parliaments of Scotland and Wales.

In Germany, positive parliamentarism is strengthened by the rule of constructive votes of no confidence. There, governments can only be defeated in a vote of no confidence if there is a majority in support of an alternative government. If parliament cannot find an alternative, the incumbent government remains in place. This system has since been adopted by other countries, including Spain, Italy and Poland.

However, some ‘negative’ countries do also have investiture votes, just with different rules to positive countries. This is the case in Sweden where a majority of all MPs have to vote against a proposed government for it to be defeated. Last November, Social Democrat Magdalena Andersson (who was unanimously chosen as party leader) was elected PM despite more MPs voting against her than for her. However, as only 49.6% of MPs voted ‘No’, and crucially 21.5% abstained, there was not a majority against her election.

Effectively, under positive parliamentarism a government can only be formed if a majority of MPs have explicitly endorsed it, while under negative parliamentarism a government will be formed unless a majority of MPs explicitly reject it.

2022 is a big year for presidential elections in Europe – with the Italian (24^th January), German (13^th February) and French presidencies (10^th April) all open over the next few months. Of course, these are very different roles – the French President has significant executive powers, while the Italian and German Heads of State are largely ceremonial, performing a similar role to our Queen. But, regardless of their constitutional functions, let’s look at how these presidents will be elected.

How are Heads of State chosen around Europe?

* Not classed as a fully free democracy by Freedom House.

Direct Election

The French President may be unusual in western Europe in being a Head of State with substantive influence over day-to-day government policy, but the presidency does stick to the norm of a popularly-elected president – it is chosen using the Two-Round System. There are a few variations to the rules of the Two-Round System, but the one used for the French President is what you might call the ‘classic’ version: If a candidate wins more than half of votes in the first round, they are elected. If not, the two candidates with the most votes proceed to a second round where the winner will take both a majority of votes and be elected.

Nearly all of Europe’s other directly elected presidents are also chosen using the Two-Round System. Ireland is one of the few to buck the trend – opting instead for the Alternative Vote, still a majority-based voting system, but one that saves them the expense of a second round of election and is in keeping with their tradition of preference voting. Other exceptions are the President of Iceland and Bosnia-Herzegovina’s three Presidents who are all elected by First Past the Post.

You might also like Four ways of electing a president – ranked from worst to best

Indirect Election

However, not all of Europe’s presidencies are directly elected. Some, including Estonia, Germany, Greece, Hungary, Italy and Latvia, are instead chosen by legislators in special sessions. Rules vary from country to country, but generally, the winning candidate requires the support of at least the majority of national legislators – though higher thresholds and representatives of subnational parliaments, governments or councils are often involved.

The Italian President is elected by a joint session of the Chamber of Deputies and Senate, as well as 58 representatives chosen by Italy’s regional councils (each get three representatives, except the tiny Aosta Valley who only get one). Unlike most elections, there are no explicit candidacies – electors are free to choose any eligible citizen, though parties will often have a preferred candidate. For the first three rounds of voting, a candidate requires two-thirds of votes to be elected, with this being reduced to a simple 50% threshold from the fourth round. Italy’s fractured party system has meant the vote has sometimes gone on for days, with the 1971 election taking 23 rounds of voting before a winner emerged.

Germany’s President is chosen by a specially convened Federal Convention comprising all members of the Bundestag and an equal number of delegates elected by the state parliaments. The election has a maximum of three rounds. In the first two, support from a majority of delegates is required, but this is reduced to a simple plurality for the third. Candidates often receive the formal support of more than one major party – for instance, parties in coalition together usually field a joint candidate. Some, such as the incumbent Frank-Walter Steinmeier of the centre-left SPD in 2017, have even been supported by all four major parties.

The Italian Presidential election will start on the 24^th of January; the incumbent Sergio Mattarella declined to seek re-election, although he was eligible to do so. The German Federal Convention meets on the 13^th of February; Frank-Walter Steinmeier is seeking re-election. The first round of the French presidential election is on the 10^th of April, with the likely second-round pencilled in for the 24^th; incumbent Emmanuel Macron is also seeking re-election.

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[Note: Germany updated their voting system for the 2025 election, and introduced new rules. You can find out about that in our article on the election]

This Sunday (26th March), Germany goes to the polls to elect its national parliament – the Bundestag. With Angela Merkel stepping down as Chancellor after 16 years, this election will cause only the fifth change in Germany’s head of government in the last 50 years. Ahead of this vote, I thought we’d take a look at the electoral and party systems of Europe’s largest democracy.

The voting system

The Bundestag is elected using a Mixed-Member Proportional system, known in Germany as ‘Personalised Proportional Representation’. It currently has a base of 598 members, with 299 elected in single-member constituencies by First Past the Post and a minimum of 299 elected using Party List PR in each state. To be eligible to win list seats, a party must win more than 5% of the vote nationally or win three single-member constituencies. 299 is only the minimum number of list seats as there are almost always more than this due to both ‘overhang’ and ‘levelling’ seats.

Overhang seats

Overhang seats occur when a party wins more FPTP seats than it would be proportionately entitled to. Under the Scottish and Welsh Additional Member Systems, doing this denies other parties of the ability to win their full, fair allocation of seats. But in Germany, additional list seats are added to ensure that each party has a near-identical vote:seat ratio at the national level. These levelling seats create pure proportional representation for parties that qualify for list seats and neutralise any advantage a party builds up on the FPTP seats. They do, however, lead to a significant inflation in the size of the Bundestag – the 2017 election saw the creation of 111 additional seats, giving Germany a total of 709 MPs.

Parties and Government

The moderately multi-party system of modern Germany is led by the two major, ‘Chancellor’ parties – the centre-right CDU (including their Bavarian sister party, the CSU) and the centre-left SPD. The CDU has historically been the more dominant party, being the largest parliamentary faction after all but three elections and providing five of the Federal Republic’s eight Chancellors – including Adenauer, Kohl and Merkel, who all served in office for more than 14 years. The SPD, who held the Chancellery in two periods from 1969-82 and 1998-05, have spent the last eight years as the junior partner to the CDU as part of a so-called ‘grand coalition’.

During the 1960s and 70s, Germany had a pure two-and-a-half party system with the half being the liberal FDP. Then the ‘pivot’ party in the middle, the FDP is today associated more with right-wing, economic liberalism and is seen as closer to the CDU. In 1983, the Greens became the first other party to cross the 5% national threshold since it was introduced in 1957. They have since become a key presence in German politics and have held the Minister-President (state-level head of government) position in Baden-Württemberg since 2011.

After reunification in 1990, these four parties were joined by the PDS – the successor to the East German Communist Party. It merged with a left-wing breakaway from the SPD in 2007 to form Die Linke (The Left) and its support remains heaviest in the former East Germany. The most recent addition to the Bundestag is the right-wing populist, if not far-right, AfD, who won their first seats in 2017. Like Die Linke, their support is stronger in the East.

The German party system runs deep, with nearly all seats in Germany’s 16 state parliaments being taken by these six parties. Nonetheless, this election could represent a big shake-up of that system, with polls pointing to the CDU’s worst-ever result and the Greens expecting the best third-party performance ever. The SPD, who have long been regarded as in a terminal decline, have experienced a surge in support in the last month, with their candidate, Olaf Scholz, now favourite to be the next Chancellor. The AfD and Die Linke are both set for moderate losses.

Germany has historically opted for two-party coalitions at the national level – with the last 50 years seeing SPD-FDP, CDU-FDP and SPD-Green governments, as well as the CDU-SPD grand coalition that has been in power for most of Merkel’s term as Chancellor. It isn’t entirely clear which coalition will be formed this time, but polls suggest it will likely have to involve three parties – a situation that has become increasingly common at the state level.

There, pretty much every combination of CDU, SPD, FDP and Green has been tried, with many given nicknames based on the colours of the parties. A ‘traffic light’ coalition (red-yellow-green) comprises the SPD, FDP and Greens, a ‘Jamaica’ coalition (black-yellow-green) is the CDU, FDP and Greens and a ‘Kenya’ coalition (black-red-green) involves the CDU, SPD and Greens. There are also some ‘Red-Red-Green’ state coalitions involving Die Linke, but there is still some apprehension about inviting them into the national government. The AfD, who have been subject to a ‘cordon sanitaire’, are likely to remain excluded from any government at any level for the foreseeable future.

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A common feature of many Party List PR systems is an electoral threshold – a pre-set bar that parties have to reach if they want to win seats.

The exact level at which the threshold is set varies from country to country. The lowest is in the Netherlands, where a party has to win just 0.67% of the vote nationally to win a seat, and the highest is currently Turkey’s 10% ‘mega-threshold’ (EDIT: This was reduced to 7% in March 2022). Most electoral thresholds are, however, somewhere between 3 and 5%.

The rationale

The main argument in favour of electoral thresholds is that they reduce party system fragmentation – i.e. parties splitting into smaller ones – with countries with higher thresholds generally having fewer significant parties than those with no or low thresholds. This is typically seen as desirable as a higher number of significant parties often leads to government formation becoming more difficult. There is also a worry that, with no threshold, extremist parties can win a few seats and then use their parliamentary presence to gain legitimacy.

These concerns were apparent in the development of Germany’s 5% national threshold in the 1950s. Memories of the instability of the Weimar Republic meant there was some concern when early post-war elections saw ten parties win at least five seats. The installation of the national threshold in 1957 is often regarded as key in making Germany the bastion of moderate multi-partism that it is today.

Thresholds also aim to make sure that national parliaments are composed of parties with a national reach. This can contrast with single-member voting systems, such as First Past the Post, where parties only need to be marginally the most popular in a small area to win a seat. This is particularly apparent in the Indian parliament, where nearly 8% of seats are held by parties who won fewer than 1% of votes.

National, state or constituency?

Where you set the threshold matters. Belgium and Germany both have 5% thresholds – but Belgium’s is set in each constituency, while Germany’s is based on national vote share. This means that Belgian parties like DéFI, who win around 10% of the vote in Brussels but only 2% nationally, can win a few seats in the Belgian parliament. But German parties, like PDS in 2002, were left with no list seats despite winning more than 14% of the vote in five states, as their poor performance elsewhere left them at just 4% nationally.

In multi-tier list systems or mixed-member systems (like the Additional Member System), it is common for the threshold to include ‘get-out’ clauses for parties that achieve some success at the lower level. For instance, New Zealand’s barrier for list seats is 5% of the vote nationwide or one FPTP seat – something the Māori Party took advantage of at the last election, with their victory in Waiariki offsetting their 1% national vote and enabling them to take a list seat as well.

Nationally Imposed Thresholds

Thresholds that are based on national vote shares and which affect seat allocation at a sub-national level can have peculiar effects. The 2013 German federal election is a great example of this – 16% of voters voted for parties that failed to cross the 5% threshold. So while seats were allocated perfectly proportionally between the parties that crossed the threshold, 100% of seats were being allocated based on 84% of votes – distorting things so much that, between June and September 2017, the British House of Commons was more proportional to its most recent election than the German Bundestag!

At the national level, the 5% cut-off is clean and simple, but German list seats are actually allocated at the state level. This can create perverse results such as in the south western state of Baden-Württemberg, where Die Linke were able to win seats on 4.8% of the vote, while the FDP and AfD won no seats on 6.2% and 5.2% respectively. Nationally imposed thresholds mean that the representation of one area will be, in part, determined by votes cast in other areas and can prevent popular, regional voices from being heard.

Effective Thresholds

While thresholds are generally an effective way at reducing party system fragmentation, there are other ways of achieving this. Smaller constituencies create a higher ‘effective’ threshold making it more difficult for smaller parties to win seats. This effect can be seen in countries like Portugal as well as the Scottish and Welsh Parliaments, where moderately multi-party systems have been created without the need for fixed thresholds.

Do thresholds work?

Where the efficacy of thresholds is less clear is when it comes to preventing extremist parties from winning seats. Today, most of Europe’s parliaments are home to at least one party deemed unsavoury by the political mainstream, with right-wing populist parties frequently attaining vote shares to clear even the highest thresholds – statutory or effective.

The surest guard against such parties actually comes from systems like the Single Transferable Vote – whose preferential nature and small constituency size combine to make it very difficult for small, divisive parties to win seats and can penalise larger parties that have limited secondary support.

Though, of course, if a substantive number of people vote for such parties, they should be entitled to some degree of political representation. There is little risk of many of these parties entering government as they are usually subject to a ‘cordon sanitaire’ – whereby major parties simply refuse to work with them.

The same can’t be said of situations in two-party systems under First Past the Post, where extremist factions can take over one of the parties. The logic of First Past the Post limits voters’ and elites’ ability to prevent them from winning power.

Of the 43 countries most often considered to be within Europe, 40 use some form of proportional representation to elect their MPs.

The UK stands almost alone in Europe in using a ‘one-person-takes-all’ disproportionate voting system. If we exclude the authoritarian state of Belarus – “Europe’s only remaining outpost of tyranny” – France is the only other European country to use a ‘one-person-takes-all’ system (the Two-Round System).

Proportional voting systems used for lower house national elections in Europe

Source: Inter-Parliamentary Union, Parline Database, https://data.ipu.org/

What type of proportional system do European countries use?

Party List PR

Party List proportional representation is the most widely used form of PR in Europe – 28 countries use it to elect their MPs.

In Party List systems, constituencies are bigger than under First Past the Post and voters elect a group of MPs, rather than a single person. In this system, voters get MPs roughly in proportion to how many people voted for each party.

Party List systems differ in the extent to which citizens can choose which individuals get elected. In ‘closed’ list systems, parties decide who their candidates are and voters can only mark their support for a party (some point out that first past the post is a closed party list of one) Parties decide which candidates fill the seats they have won in the election.

In ‘open’ list systems, each party presents a list of candidates, and citizens can choose which candidate to vote for (or – in some systems – they can choose to vote just for the party if they want). A vote for a candidate is counted as a vote for that candidate’s party.

Semi-open list systems are a mix of the above: voters have more choice in who they can vote for, but – generally – parties can decide the order in which candidates are elected.

Single Transferable Vote

Ireland and Malta use the Single Transferable Vote (STV) to elect their representatives.

As with Party Lists, voters elect a small group of representatives in bigger areas, like a small city or county, as opposed to a single MP in small constituencies as we do in Westminster.

STV gives voters maximum choice on who to vote for. Each elector has one vote. Voters number candidates in order of preference, with a number 1 for their favourite – they can rank all candidates or just vote for their preferred candidate.

To get elected, a candidate needs to reach a set amount of votes. This quota based on the number of seats to be filled and the number of votes cast (read our explanation to find out more about how votes are counted).

If your favourite candidate already has enough votes to win or stands no chance of winning, your vote is transferred to your next choice based on how you ranked candidates.

Under STV, voters can choose between candidates from the same or different parties, which incentivises parties to stand candidates who reflect the diversity of society. Electors can also vote for independent candidates, without worrying about ‘wasting’ their vote.

Mixed Member Proportional Representation

Germany elects their representatives with Mixed Member Proportional Representation (MMP). Which is similar to the Additional Member System (AMS) in the UK.

MMP is a mix of Westminster’s First Past the Post system and Party List PR – the goal is to provide a proportional parliament but also keep a single local MP.

Voters have two ballot papers. On the first is a list of candidates who want to be the local MP. Like a Westminster election, the voter marks their preferred candidate with a cross and the candidate with the most votes wins and gets a seat, even if most people didn’t vote for them.

On the second ballot paper is a list of parties who want seats in parliament. Each party publishes a list of candidates for these elections, a vote for a party is a vote to make more of their list of candidates into MPs. Seats are allocated in proportion to the votes a party received in the election, taking into account how many ‘first vote’ seats they obtained.

Other systems

The remaining countries (Andorra, Greece, Hungary, Italy, Lithuania, North Macedonia, Monaco, San Marino and Ukraine) combine a number of voting systems – mainly First Past the Post and List PR. These tend to be less proportional for a number of reasons.

In Italy, for example, the distribution of the List PR seats does not take into account seats won under the First Past The Post section. While in Greece, the party with the most votes receives a bonus of up to 50 seats, in addition to those they are entitled to on a proportional basis. This makes it likely that a party that receives 40% of votes would achieve an overall majority of seats in the Hellenic Parliament.

Conclusion

The UK is unique among European countries in terms of its electoral system – and not in a good way. It’s the only democracy that uses the outdated, one-person-takes-all First Past the Post system. Westminster is even unique within the UK, as the Scottish and Welsh parliaments, as well as the Northern Ireland and London Assemblies all use forms of proportional representation.

While the List PR systems commonly used in Europe can create parliaments that closely reflect the opinions of their countries, there is often a weaker constituency link.

This is why the ERS favours the Single Transferable Vote: this system enhances voter choice and guarantees a strong link between MPs and voters, while also distributing seats in parliament in a way that is fair and reflects how people voted. Rather than throwing votes on the electoral scrapheap as ‘wasted’, STV helps ensure every vote counts and people’s voices are heard.

It’s time that we caught up with the rest of the world and changed the way we elect our parliament so it finally reflects public opinion.

Sign our petition for a fair voting system in the UK

[Note: Germany updated their voting system for the 2025 election, and introduced new rules. You can find out about that in our article on the election]

Elections to Germany’s Bundestag – Germany’s House of Commons – are held under Mixed Member Proportional Representation (MMP).

This electoral system seeks to combine features of Westminster style first past the post voting – in particular each constituency having one MP – and proportional representation – with parties’ seats in parliament determined fairly in proportion to how people voted.

In the UK, this system is called the Additional Member System (AMS) and is used to elect the Scottish Parliament and Welsh Assembly, and the London Assembly.

How does Germany’s electoral system work?

Mixed Member Proportional Representation (or AMS in the UK) is a mix of Westminster’s First Past the Post electoral system and Party Lists. Members of the Bundestag are elected every four years by all German citizens over the age of 18.

German citizens have two votes:

The first vote is for the voter’s local MP (see column on the left in the ballot paper below), and is elected through First Past the Post, as in the UK. This system tends to return few, large parties to the Bundestag and ensures – at least in theory – that there is a tight and direct link between voters and MPs.

The second vote is for a party, not a single candidate (column on the right in the ballot paper below). This means that, as well as the winning candidate for local MP, each German state sends a team of MPs to the Bundestag, based on how much of the vote share they won. This vote is generally considered to be the most important as it determines the percentage of seats a party will get in the Bundestag and thus its relative strength. Each party publishes an ordered list of candidates in advance to fill these positions.

How do votes translate into seats?

The first vote determines the election of 299 members of the Bundestag. As in the UK, candidates only need to obtain more votes in their district than anyone else in order to win (even if the majority did not vote for them), while votes for losing candidates are effectively wasted and do not count towards the election of any candidate.

The second vote decides the allocation of the remaining 299 seats, which are filled in proportion to the share of parties’ votes in the election. The amount of local MPs won by the parties using the first vote is also taken into account. Unlike First Past the Post, no votes are lost in the list system as parties gain seats in relation to their share of the vote.

If a party wins five local constituencies, but its fair share of MPs based on the second vote is eight MPs, the top three candidates on its list are elected.

To prevent party fragmentation and small splinter parties from gaining representation, parties must obtain at least five percent of the vote (or three directly elected local MPs) in order to enter parliament.

What are ‘overhang’ seats?

Being able to vote for a constituency MP and a party list means that voters can split their first and second votes among parties. For instance, you may want one party to be in power, but think your local candidate from that party is terrible. While this can increase voter choice, vote splitting can also distort proportionality.

In fact, sometimes the number of seats parties obtain through first votes can exceed the share of seats they should have received based on second votes, which – as mentioned above – set the percentage of seats a party should have in the Bundestag. Candidates who win a constituency seat are guaranteed a seat in parliament, so parties get to keep these ‘overhang’ seats.

Following a ruling by the Federal Constitutional Court, reforms were implemented in 2013 to make up for this distortion. Other parties are now given ‘balance’ or ‘levelling’ seats to ensure representation in the Bundestag is in line with second votes.

It is because of overhang and balance seats that the 2017 federal election returned 709 members to the Bundestag – 111 more than the constitutional minimum of 598 MPs.

Concluding remarks

Germany’s Mixed Member Proportional system is an improvement on our Westminster-style electoral system, as it incorporates proportionality and fairness through the party list system, ensuring that parliament reflects the country’s political views, while maintaining the personalised, local link typical of First Past the Post.

But MMP is a compromise solution that still retains some of the worst features of Westminster’s electoral system, such as wasted votes. Though an improvement on ‘pure’ First Past the Post, the party list system means that parties have a lot of control over who gets elected. What makes matters worse, the system incentivises vote splitting, which leads to disproportionalities in election outcomes.

Only the Single Transferable Vote – the ERS’s preferred system – can ensure that parliament reflects the diversity of British political views and that MPs have a strong local link with their voters. What’s more, voters have maximum choice over whom to vote for – with ranked choices removing the incentive for vote splitting.

Whether it’s a restaurant, a stadium, or your belly – when something is full, logic determines you stop adding to it.

This basic principle should be applied to the House of Lords, but it isn’t.

There are currently 793 peers making it the second largest legislative chamber in the world, after China’s National People’s Congress.

There are more peers than could ever sit in the chamber at the same time, and the bulk of the work of the House is done by a much smaller group of peers.

This situation isn’t normal. Most democracies have upper chambers which are around 100 members: India’s upper house is only 245 members, France’s is made up of 348 members, and Germany’s just 69.

The growing consensus is that the current size of the House of Lords is not only absurd but also an embarrassment.

New polling shows this is a view shared by the majority of people in the United Kingdom.

Of those with a view, nearly four in five (78%) believe there are already too many Lords – compared to just 18% who think the current size is ‘about right’. Just 4% say there are ‘too few’ peers.

That’s the situation now. But rumours have been bubbling about new appointments to be made in the near future.

It has been reported that Theresa May is set to appoint 12 new members of the House of Lords, while Jeremy Corbyn is set to appoint three new members – sending the total number to over 800.

The polling finds that 60% of those with a view oppose the mooted appointments – compared to just 9% who support them.

This isn’t a partisan issue: party leaders face similar levels of opposition across the political spectrum.

59% of Conservatives are against the new peerages, as well as 63% of Labour voters.

Question: It has been reported that in the coming weeks Theresa May is set to appoint 12 new members of the House of Lords and Jeremy Corbyn is set to appoint 3 new members. To what extent do you support or oppose further appointments being made to the House of Lords?’

Nor is the opposition entirely outside the walls of Parliament – overpopulation of the Lords has also been identified by concerned Peers themselves (only a cynic would suggest this was a means of self-preservation).

A recent report commissioned by the Lord Speaker, Lord Fowler, proposed a ‘two-out, one-in’ system to bring the total down to 600 by 2027.

Downing Street barely concealed the fact it has no intention to act on the report, stating it would study it carefully but that ‘comprehensive’ reforms were not a priority.

So why in the context of widespread opposition to expanding the House of Lords – including from peers themselves and Conservative voters – is the Prime Minister set to introduce a further dozen?

The answer, of course, lie with the political demands upon her: namely being able to get the EU withdrawal Bill through the House of Lords without amendment or delay.

But what does it say about the Mother of Parliaments when opposition can be overcome by packing one chamber to the rafters with party loyalists – many of whom are donors or defeated politicians?

Question: ‘There are currently 794 members of the House of Lords. In your view, is this too many, too few, or is the number about right?’

We are faced with a bizarre problem: there’s no room left in the clubhouse. Perhaps that will lead to the realisation that this gentleman’s club has had its day, after all.

Rather than trying to squeeze them all in, there’s a better solution: to listen to the calls for change, and embark on a reform agenda. Times change – now Parliament must follow suit and give us a second chamber which is fit for a modern democracy.

Sign our petition to stop appointing peers to the Lords