Board minutes: 12 May 2026

The Chair welcomed all to the meeting, including Rashik Parmar and Alan Mabbutt who had recently been appointed Commissioners and were attending the Board for the first time.

No apologies for absence were received from Commissioners or Executive Team members.

Katy Radford brought to the Board’s attention a conflict she had with item 2.1 on the agenda, due to her remunerated role as the Director of the Office of Identity and Cultural Expression. Katy explained that she would recuse herself from the boardroom whilst the Board considered this topic.

The Executive Team assessed that the polls held the previous week had been delivered smoothly overall, with only minor or isolated issues, including some postal voting and data-related challenges and slower counts in certain areas. There had been broad acceptance of results across parties, with online commentary that had not developed into significant concerns.

The elections had been well run and professionally delivered by electoral administrators, with effective support from policing partners and other stakeholders. There had been no indications of major issues relating to Returning Officer performance, and strong cooperation with Electoral Management Boards in Scotland and Wales. Polling day saw some isolated and, in a few cases, novel issues, all managed effectively. While some counts were slower than expected, their integrity was not in question; however, limited transparency in some cases prompted external commentary and highlighted a need for greater consistency.

In Wales, the introduction of a new voting system had been managed successfully, with only minor issues reported, including two reported cases of personation and a postal vote printing issue in Cardiff which was resolved effectively. In England, issues arising on the day included candidate eligibility queries, campaign material near polling stations and routine questions about electoral integrity matters. Reinstated polls had been carefully monitored and delivered effectively. Pilot schemes aimed at improving voter accessibility, including early and more flexible voting, were implemented in a range of locations. Initial feedback suggested these operated effectively, though differences in usage across settings highlighted questions around consistency and cost-effectiveness. Further evaluation will follow. The election results will give rise to a number of by-elections, and there may be some election petitions arising out of candidate eligibility considerations.

New approaches to social media monitoring had been implemented at scale, including scanning over 900,000 posts, which identified a small number of deepfakes. Engagement with platforms led to the requests for removal of harmful content where required, including a serious account which was rejected. While some online narratives emerged, these did not gain traction.

Engagement with political parties and campaigners had reached record levels, reflecting both the complexity of the polls and the high number of first-time candidates and agents. The Regulatory Support services had experienced unprecedented demand, and stakeholder engagement, including training and pre-poll webinars, had been well attended. The imprints regime saw a marked increase in activity, with more

reports received in April than in the whole of the previous year, and teams were largely able to support compliance. A number of cases remain open and would be progressed in line with established processes. Webinars to support post-poll spending returns were starting with a high number of candidates signed up.

Operational activity was delivered at scale. Around 700 electoral administration queries were handled during the election period, with the vast majority resolved within target timescales. Public engagement was high, including approximately 8,000 inbound messages, over 1,000 on polling day alone, and close to one million website views. Media coverage exceeded 290 items, supported by a proactive approach to communications, including monitoring and piloting “pre-bunking” of potential misinformation narratives in Wales and close coordination with partners across the electoral system.

Commissioners provided feedback from their observations at polling stations and counts across GB, consistently reporting that polling was well organised and professionally delivered and supported by committed staff. The benefits of advance planning were particularly evident in Wales, where a longer preparation period supported smooth delivery and public confidence in the new system. The use of digital tools, including electronic registers, was highlighted as a significant improvement. These were widely reported to improve efficiency and voter flow and were well received by staff. Some connectivity, charging and training issues were identified. There was agreement on the value of capturing and sharing best practice to support wider rollout, alongside the need to maintain public confidence, including addressing perceptions about ballot secrecy.

Several operational and policy issues were raised for further consideration. These included:

• variations in count timings and transparency, including cases where counts did not begin as expected or results were delayed without clear explanation, which in some cases had generated external commentary
• voter confusion relating to identification requirements, particularly where different rules applied across elections
• continued uncertainty around polling communications, including confusion between polling cards and letters, and the risk of digital exclusion;
• handling of postal vote returns at polling stations, where the form in England was administratively burdensome

Emerging issues in the polling environment were also discussed, including campaign materials and flags near polling stations, the role and conduct of observers following updated guidance, and the use of private security at some locations. A small number of cases attracting media and public attention, including issues relating to party registration and candidate eligibility, were highlighted and will be considered further through post‑poll activity.

The post‑poll reporting programme was outlined, including statutory reporting on Scottish and Welsh parliamentary elections and planned reporting on the English local elections and pilot schemes. This would be supported by a programme of research, including surveys of voters, candidates and electoral staff, with publication expected later in the year. An earlier report on pilot schemes would also be delivered in line with statutory requirements.

The significant scale of operational delivery was noted, including very high volumes of stakeholder engagement, public enquiries and administrative queries handled within tight timeframes. The value of strengthened coordination arrangements with partners was highlighted, including across electoral administrators, policing bodies and government. Commissioners expressed thanks to staff across the organisation for their sustained efforts in delivering the polls, noting the high levels of collaboration across teams and support provided to colleagues, in particular in Scotland.

Turning to legislative matters, the Board received an update on the Representation of the People Bill. Constructive engagement with Government continued, and the Commission’s briefings had been welcomed by Parliamentarians in their scrutiny. Increasing uncertainty around the timetable for Royal Assent was highlighted, with implications for implementation planning. The complexity of the Bill, particularly in relation to political finance, interactions with devolved legislation and the requirement for Legislative Consent Motions was a challenge. Contingency planning was underway in light of reduced clarity on timing. Recent amendments, including repeal of the Strategy and Policy Statement, were welcomed. Beyond the Bill, the Commission would raise further the difficulties arising from different implementation timescales across the nations of automatic voter registration.

Progress in responding to the Rycroft Review was discussed. Engagement with policy officials had strengthened. Consideration of the full set of recommendations was ongoing, including those relating to reporting cycles and enforcement, with attention to feasibility and implementation risks. A formal response would be issued in due course.

Wider organisational activity was discussed. Procurement of the Political Finance Online system was progressing towards final stages. The voter education programme continued to expand its reach, including through a successful “Welcome to Your Vote Week”, which engaged over 700,000 young people and 30,000 educators and stakeholders, with increased confidence in participation reported. Research programmes on political finance and candidate intimidation were progressing, with early findings indicating strong public concern about the influence of large donations and the increasing negativity in political discourse. Progress with finance and procurement systems was noted, including challenges associated with supplier transition.

External engagement activity by the Chair and the Executive continued across a range of areas including participation in events on the Representation of the People Bill and its implementation, contributions to discussion on misinformation and AI, and engagement with academic audiences on the health of democracy. Preparations were underway for the Four Countries’ Conference, which would focus on shared challenges, including abuse and intimidation. Representatives from the Ukrainian electoral commission were expected to visit again, with consideration being given to how best to support those based in the UK in the context of any future electoral event.

2.1 Identity and Language Act (NI) 2022

Katy Radford recused herself from the meeting as the Executive set out its consideration of the approach to Irish language translation. The standards were being developed ahead of consultation later in the year. Whilst the Commission was not currently a named public authority, a proactive approach had been taken with a stakeholder scoping exercise which had informed the proposed approach. The Executive considered three proposed options and supported a case-by-case approach to translation requests. Demand to date had been limited, with one request received in the past year. Commissioners recognised that this position may evolve as the

standards are introduced, and the potential use of technology, including AI, to manage translation needs and costs was also discussed.

Resolved: The Board noted the update from the executive.

The Corporate Director presented the Finance and Performance update to March 2026 and the accompanying summary paper. Overall performance remained stable, with most indicators on track and year‑end reporting in development for inclusion in the Annual Report.

Financial performance for the year showed a forecast underspend of £6.5m. This had remained broadly consistent over recent months and reflected a combination of efficiencies and the use of contingency held at the start of the year. Around half of this total related to provision that had been deliberately held as contingency, with the majority of the balance reflecting movements in budgets between returns to Scotland and Wales in September, and Westminster in February. While the position reflected improved financial management and forecasting, it was acknowledged that the scale of underspend was higher than would be expected in the longer term. The constraints created by early budget-setting requirements for devolved funding, and some shifts in funding allocations were also recognised.

Three key performance indicators had performance marked as red and the Board discussed the reasoning behind these. It was recognised that the timely conclusion of investigations was influenced by external dependencies, including police involvement, as well as resourcing pressures. Whether the current measures appropriately captured performance had been discussed previously, especially where blunt measures were used in areas of complex activity. The importance of clear narrative in external reporting was emphasised, particularly given sensitivities around enforcement performance and the associated risks if cases were perceived not to be progressed promptly.

The timely response to Freedom of Information Act requests was discussed as performance remained below target. The underlying causes, including peaks in demand falling on specific teams had been identified. Actions were in place to address this, including additional resource, improved triage of requests based on complexity, and greater delegation to support timeliness while maintaining compliance. It was recognised that whilst performance was moving in the right direction, this had not been at the pace hoped for though assurance was provided that more substantial improvement was expected over the next quarter.

Portfolio performance was reviewed, with a small number of areas rated as red. These included electoral reform activity, reflecting delays to legislation, and one digital project where recruitment challenges were affecting delivery. Members discussed the level of concern arising from these ratings and were assured that underlying issues were understood and being actively managed.

Progress on organisational growth was noted, with the first phase of the Plan for Growth completed successfully and reflected in a significant increase in headcount, which now exceeded 300. Focus was turning to the next phase, aligned to delivery of the reforms that will result from the Representation of the People Bill.

The delivery of the internal audit plan was considered, particularly the areas receiving limited assurance. It was recognised that there was scope to improve these ratings over time, with an expectation that future performance should move towards moderate assurance where appropriate. A draft head of internal audit opinion of ‘moderate’ was anticipated, representing a positive trajectory and improvement in assurance.

Resolved: The Board noted the Finance and Performance update and the March 2026 Corporate Performance Report.

The Corporate Director introduced the draft Annual Report and Accounts, explaining that the annual report had been refined to focus on clear, concise statutory reporting, and that the accounts had been shared with the National Audit Office who were commencing their final audit. He confirmed the timetable for laying in Parliament before the summer recess.

Commissioners commented positively on the overall presentation, noting that the draft was clearer, more concise and appropriately balanced, with an honest reflection of achievements alongside areas for improvement. Several points for refinement were raised, including strengthening references to public confidence and trust, ensuring clarity when referring to arrangements across different parts of the UK and maintaining a succinct style throughout.

It was suggested that the report should more clearly explain areas of underperformance, particularly in relation to investigation timelines and Freedom of Information response performance, to provide greater transparency to stakeholders. Commissioners also highlighted the importance of including a clear narrative on the year‑end underspend, setting out its principal drivers, including contingency, efficiencies and slower recruitment, and explaining the funding position. The recognition of outgoing Commissioners and welcoming new members was also suggested for inclusion in the forewords.

Some Commissioners reported issues with accessing the draft report and it was agreed that this would be circulated by email with comments to be received by the end of the week.

Resolved: The Board approved the key messages included within the annual report, subject to further comments to be provided, and identified a small number of areas where additional narrative should be developed ahead of the next draft.

The Director of Communications introduced the annual report, explaining that following the introduction of a revised approach to handling complaints, improvements were evident. The volume of complaints remained low and stable, with responses being delivered within target timeframes, reflecting a more structured and consistent approach. The contribution of the Customer Service Manager in strengthening and professionalising the process was recognised.

One complaint had been upheld during the year, with clear learning identified and embedded within the enforcement team. It was acknowledged that changes to the approach limited year‑on‑year comparability, and that the small number of complaints made it difficult to identify consistent trends.

The report also included instances where dissatisfaction had been expressed but did not meet the threshold for formal complaints. These were recognised as a useful early indicator of voter sentiment, with themes expected to inform post‑poll reporting.

Commissioners discussed how compliments and wider feedback were captured and shared internally, agreeing that while the report should remain focused on complaints, there was value in considering how broader feedback could be reflected in future.

For the first time, the report included complaints made to the Information Commissioner’s Office relating to Freedom of Information responses. This was considered in the context of the performance challenges discussed earlier in the meeting.

Resolved: The Board noted the annual report on complaints and took assurance from the actions in place to address the issues raised.

The Board noted the approval, by electronic resolution on 9 April 2026, of the decision to defend litigation through a judicial review in respect of the Commission’s statutory guidance on the legal responsibilities of Returning Officers to enable blind and partially sighted voters to vote independently and in secret.

The Chair of the Audit and Risk Assurance Committee (ARAC) introduced the Committee’s annual report. Clear progress had been made across a number of areas over the year. Internal audit arrangements had strengthened, with improvements in process and assurance. Broader improvements were also highlighted in financial planning and forecasting, risk management and procurement, including stronger oversight of supplier and contract management. The value of detailed deep dives was emphasised in providing an effective mechanism for strengthening assurance, particularly in relation to projects.

The Board expressed confidence in the operation of the Committee and the level of scrutiny being applied. Thanks were expressed to the previous Chair, Lord Gilbert of Panteg, for his significant contribution in shaping the approach and tone of the Committee, and to Paul Redfern for his eight years’ service as the Independent Advisor, including his sustained commitment, expertise and support through a period of significant change.

The Board noted the Annual Report from the ARAC and took assurance from the Committee’s oversight of the effectiveness of governance, risk management and internal controls.

The Chair of the People, Culture and Remuneration (PCR) Committee introduced the Committee’s annual report, reflecting on a productive year in which the Committee had continued to develop its approach and effectiveness. The Committee was well supported by Executive colleagues, and members were able to engage constructively, asking challenging questions in an open and collaborative way. A clear forward programme of work had been established, and there was confidence in the direction of travel and the Committee’s ability to deliver against its priorities.

Commissioners expressed their thanks to the Chair for bringing the Committee together effectively over the year, noting the significant contribution made during a busy period.

The Board noted the Annual Report from the PCR and took assurance from the Committee’s detailed scrutiny on its behalf.

The Board approved the minutes of the Board meeting held on 24 February 2026, noting that they were an accurate record.

The Board noted the update on the outstanding action from the September Board meeting for the Wales Commissioner to share with the Commission the work undertaken by Bangor University on Welsh language AI.

The Board noted the forward plan of business for 2026-27.

The Board noted that the annual report on the relevant interests declared by Commissioners in 2025-26. The report had prompted members to either raise additional interests or to correct the record, which would be reflected in the register.

The meeting concluded at 12.54 pm with no further business.

The date of the next meeting was confirmed as 16 June 2026, held in person at Pierhead, Cardiff.