Board minutes: 12 May 2025

Commissioners had been provided with a paper providing background on how electoral administration was being delivered in the local government context across England. Partner Day guests would include Returning Officers and Local Government officials with recent experience of financial challenges (including current Section 114 notices), campaigning and intimidation issues. The day would also be an opportunity to discuss the Local Government review and what this could mean in the medium and longer term.

As part of its new Corporate Plan, the Commission would consider how to build its support for Local Authorities; how to utilise performance standards in a more proactive way and how to offer more intensive support to Returning Officers.  

Discussion highlighted the current support needs of local electoral services teams; in particular, that teams required supporting guidance and polling station resources from the Commission as early as possible. Aligned to this was the suggestion that, when guidance was being reissued for a new round of elections, it could be accompanied by a ‘changes schedule’ to quickly direct experienced officers to relevant areas of reading.

In summary, the Partner Day would focus the Board on gaining a common understanding of where the real challenges are in practical terms.  This would enable the Commission to improve its own offer and, through engagement with the Government, the pace of useful legislation.

The Chief Executive updated the board on significant engagement activities in the period since the previous meeting on 24 February 2025.  

The Speaker’s Committee had approved the new Corporate Plan followed by the Scottish Parliament and the Senedd, with all required signatories to funding now in place.  

Discussion with Hilary Benn, Secretary of State for Northern Ireland, had covered candidate abuse and instances reported during the UKPGE campaign, political party donations in Northern Ireland, the Northern Ireland canvass and the need for reform. The Secretary of State for Northern Ireland had raised concerns about deepfakes and questioned how to combat such threats alongside online abuse.

Written evidence from post-poll reports had been submitted to the Speaker’s Conference on the Security of MPs, Candidates and Elections. An oral session attended by the Chief Executive and the Director of Communications had followed. This had generated an expanded remit of ideas around what constitutes abuse and intimidation, and the Conference appeared to be both accelerating and more wide-ranging than first conceived.

The Central Election Commission of Ukraine had accepted an invitation to visit, probably in July 2025.

There was particular focus on Artificial Intelligence at CETaS (Centre for Emerging Technology and Security), a roundtable at the BBC and the International Panel on the Information Environment. All have been asking ‘how is AI affecting elections?’ and all have surmised that this has yet to be a significant issue, but will be. A great deal of thinking is now underway on the detection of AI material and progress in this field is moving rapidly.  

The annual gathering of the Anthropy group at the Eden Project had provided strong support for the Commission’s work on education and it had been useful to hear from Kemi Badenoch, MP and Leader of the Opposition, who was the keynote speaker.

A meeting with Rushanara Ali MP, Minister for Homelessness and Democracy, had taken place, a note of which had been added to the papers for this meeting. In the context of voter registration as a top priority for the Board, a letter had been submitted to the Minister laying out key proposals on registration.  The discussion with the Minister also covered votes at 16 and the political finance regime. The pressing need for cross-party discussions on these areas had been impressed upon the Minister and indications were that these would commence soon.

Board discussion highlighted the risks around impartiality, including on education and there being a Government majority on the Speaker’s Committee. The Board were reminded of the very clear guidelines around impartiality that had been produced by the Commission.

Polls had taken place on 1 May 2025, covering 14 County Councils and 11 unitary authorities and including the Runcorn and Helsby by-election. All had proceeded smoothly from an electoral administration perspective.  Commission observers had been at various locations across the UK. Voter ID is now well-embedded. Guidance to administrators on security and safety had been strengthened and had worked well. The new centralised portal for reporting of concerns about imprints had received over 130 referrals on the same day.  

During the elections, advice to the public had been delivered effectively through the usual channels of email and phone as well as new ‘how to’ animations on the Commission website, including on filling in nominations forms. New guidance had also been issued on crowd funding. Overall, no wide-spread or systemic issues had occurred. Post-poll reporting, including consideration of lessons-learned, would follow.

Federal elections had taken place in Canada on April 28, 2025, and in Australia on May 3, 2025. Key themes and findings and a more detailed analysis of lessons learned would follow. In both elections, results had defied expectations, with opposition leaders losing seats. Canadian turnout was the highest since 1993. To address mis and disinformation, Elections Canada had set up ‘ElectoFacts’ to allow voters to easily check whether information about elections is true or not, along the same lines as the Commission’s 2024 General Election hub.

Concluding the CEO update:

• Welcome to Your Vote Week had achieved a remarkable reach of 590,000 young people.  
• The Commission had conducted a very useful business continuity exercise, the first for a number of years.  
• The pay review was on-track, with individual contract change letters due go out on 19 May.  
• Through the hard work of the IT team, accreditation to Cyber Essentials had been achieved, new laptops had been rolled out to most staff and Webex would be turned off on 22 May 2025.  
• The CEO would be attending the Stockholm Conference on Electoral Integrity on 11/12 June.

Finally, it was noted that a government strategy and policy paper was expected in mid-June which would provide a description of the draft legislation. The Board would be consulted to frame the Commission’s response.

The Board noted the Q4 Performance Report. The Board were reminded that the new Convene board portal software, in use for the first time at this session, allowed members to make annotations that can be shared. Using this function, the Director of Finance and Corporate Services had added a commentary on the report for the Board’s attention.

The Board noted the Chief Executive’s update.

The board received the report from members of the Policy and Research teams. The context for the report was the peculation earlier in the year on large value donations. Board input was particularly invited on the key issues arising from the evidence gaps, the broad policy framework interim position and on the next steps. While there had been no further developments and no specific live issues to report, this remained a matter of significant political interest with the pending Elections Bill.

New research had been commissioned to ascertain the public’s view. This had found that the funding of political parties was an important issue of public concern, but there were very low levels of knowledge and no strong areas of agreement on the sources of funding, nor the level at which a cap on donations could be supported in theory.

The Research team had also analysed pre-existing data on reported donations to model the impact of potential caps at different levels.  

Board discussion highlighted the lack of consensus within or between political parties or from the public on this issue. The arguments ‘for’ could be seen as strong but political appetite was low, although this could change rapidly in the event of a major donation scandal. More data was needed to flesh out the research and understand potential risks.  

The scope of the paper’s research was discussed, in particular the usefulness of focusing primarily on funding levels rather than funding sources. The Board agreed that, given the low appetite for the cap at present, the Commission’s focus should be on the sources of funding, eligible donations and cleaning up the system to deliver public transparency and accountability.

The paper provided a good basis of groundwork, but more work was needed to understand options. The Board asked for an update in 6 months.

Action: Update paper to Board in November 2025

The Board noted the paper on emerging research and policy work on donation caps.

The Finance and Corporate Services Director reported that the Audit and Risk Assurance Committee (ARAC) had reviewed the draft Annual Report and Accounts 2024/25 on 6th May and noted positive progress to date. An unqualified opinion from the NAO was targeted. The near-final accounts would be agreed by the Board at its shorter online meeting on 24th June 2025.  The final accounts audit had commenced today (12th May).

The Chair of ARAC summarised the useful discussion that had taken place with the NAO on the audit report process. The current Annual Report template was felt by the ARAC to be overly long and therefore did not sufficiently set out the impact of the Commission. The format of the accounts and the performance report would be reviewed and modernised for 2026.  For this year’s draft, the Head of External Engagement agreed to review and focus the performance narrative sections.

The Board were keen to understand sources of underspend and it was clarified that there was an important distinction between underspend as a result of not spending money asked for as a contingency which is not drawn down from the nation concerned and underspend where something is planned as a budgeted activity and not delivered, which would be of greater concern. It was noted that the first quarter of 2025/26 would be a key review point to look at options to address emerging underspend this year. It was also noted that a major factor affecting underspend was the need to set budgets by mid-year (end of September) which is much earlier than most organisations but does heighten forecasting risk. The financial control strategy was to bring actual spend in line with funding levels and minimise underspend.  

It was noted that the Speaker’s Committee had encouraged the Commission to have in place a contingency so that supplementary funding would not be requested. This was clearly reflected in the current model whereby funds not needed were not drawn down and directly returned.  

Action: A further update on underspend controls at the end of Q1 would be provided to the July Board.

The Board noted the draft Annual Report and Accounts and looked forward to formal approval in June 2025.

The Board received the presentation on the interlinked Corporate Plan and Electoral Reform portfolios from the Head of Projects and Head of Legislation Strategy and Coordination.

Dependences between the two portfolios would be overseen by a joint Portfolio Board. Three were emphasised:

• Extending votes to 16 means stronger focus on engagement with schools
• One set of people delivering both portfolios, allowing resources to be allocated effectively.
• The Commission’s Plan for Growth provided a strong framework for a joint approach to adding more resources to the portfolios if required.

On Electoral Reform, focus in the next 12 months would be on:

• Implementing new reforms for Senedd and Scottish Parliament elections in 2026. The work in Wales on registration pilots will feed into the UK Government agenda on improving registration.  
• A focus on aligning UK absent vote provisions with Wales and Scotland in time for the elections next year.
• Ensuring that the ongoing changes in English devolution would be communicated effectively to electoral administrators and voters, and the operational and structural implications worked through.

A draft strategy paper from the UK Government on the coming Elections Bill was expected imminently. The Commission would have the opportunity to comment on this statement and set out its plans to help the Government implement the reform package

Looking two years ahead, the focus would be on continuing to advise on and implement legislation in Wales and Scotland; local government elections in Wales and Scotland in 2027; potential elections to new authorities in England following devolution; elections to new authorities in England following devolution. It was noted that the UK Government currently had a planning assumption that the next UK parliamentary general election could take place in May 2028.

On the Corporate Plan portfolio, a headline overview of emerging core programmes and standalone initiatives was given, highlighting the four enhanced ‘assurance projects’ of major public interest should they stray off-track: Political Finance Online, Polling Station Finder, New Finance system, Voter education and engagement.  

As a very large-scale programme, lot of work had gone into the planning of capacity within the Portfolio Management Office to ensure that the Executive Team received the level of oversight that was needed.

The Board were provided with further details on the enhanced gateway review arrangements for the ‘Big 4’ projects. More information was also provided on the contingencies in place to ensure PMO capacity needs would be met

It was noted that the Political Finance Online project was now up and running and would be the subject of a deep dive to the July board meeting. The Board agreed to include the other three enhance assurance projects in the deep dive programme.  

Action: The Board would continue to be sighted on PMO resource capacity levels via the portfolio dashboard which would incorporate resource tracking in future. Consideration would also be given to a single ‘Plan on a Page’ view for both portfolios.

The Board noted the strategic update on the corporate project.

It was clarified that the scope of complaints reported annually was limited to the services provided by the Commission, rather than about the wider electoral system.    

KPIs were very positive, every complaint since October 2024 having been replied to on time. It was noted that complaint responses were now a performance measure on the Corporate Plan and data would be available publicly which would assist in driving collective responsibility across the Commission.

As well as useful changes made because of complaints received, there had been a positive change in the tone of responses and a more personal approach to handling.

The Board commended the quality of the work from teams across the Commission which was evidenced by so few complaints. It was noted that the timeliness of follow-up responses could still be tightened up.

The Board asked how all other types of query were being recorded and requested a report summarising topics and the key feedback received.

Action: Data on non-complaint queries into the Commission to be presented to a future meeting.

The Board noted the annual review of complaints.

The Director of Finance and Corporate Services reported that the Risk Management Framework is reviewed every two years by the Audit and Risk Assurance Committee. This had taken place over two sessions in February and May 2025 with considerable feedback provided by Commissioners and the Independent Advisor to ARAC. The Committee were content and recommended the framework to the Board.

The Independent Advisor acknowledged the very substantial improvements made to the framework. The issue outstanding was to bring some risks back within appetite and, as part of this work, to give further consideration of mitigations.  

Members of ARAC also commended the updated framework while noting that it was still a very lengthy document that could be made more accessible and straightforward. This was acknowledged by the Director of Finance and Corporate Services who reported that the framework would be re-purposed into a more user-friendly format, with supplementary training to staff.

Resolved: The Board Approved the biannual review of risk management framework.

Decisions between meetings

No formal decisions had been requested of the board since the previous meeting in February 2025.

Commissioner reappointments

The Board noted with approval the reappointment to the Commission Board by the Speaker’s Committee of:  

• John Pullinger, Commission Chair, for a further 4 years ending on 30 April 2029  
• Dame Elan Closs Stephens, for a further 2 years ending on 12 March 2027

Minutes

The minutes of the Board meeting held on 25 February 2025 were agreed

Action log

One action from the February 2025 meeting had been closed and there were no outstanding actions.

Committee Annual Reports 2024/25 – Audit and Risk Assurance Committee (ARAC)

The Annual Report of the ARAC to the Commission Board was co-presented by the current committee Chair and the previous Chair (to February 2025).

The report clearly evidenced the range of work by the committee over the past year and particularly where it had been pushing for more clarity, more depth and better information.  

The quality of internal audit had improved following the on boarding of BDO. More work was still needed for BDO to regard themselves as part of the internal team. The ARAC would continue to have an important role to play in project assurance and particularly the four Corporate Plan initiatives highlighted earlier (at item 6) that would be subject to enhanced assurance.

At the meeting of ARAC on 6 May 2025 there had been a pre-meeting discussion with the NAO and BDO where both had been very positive about their client relationship with the Commission and particularly about the response of management to audit reports.

The Board noted the annual report of ARAC and verbal report of the 6 May 2025 meeting.

Committee Annual Reports – Remuneration and Human Resources Committee (RemCo) 

The Annual Report of the RemCo to the Commission Board was co-presented by the current committee Chair and the previous Chair (to February 2025).

After a period of change, the committee was in a much stronger place. The Pay Review was nearly completed and this had been all-consuming. Once completed, the focus would shift to embedding performance management and training initiatives. This had been a significant topic of the 6 May RemCo meeting where the committee’s forward plan had also been discussed.

HR team capacity needed to grow further, in particular to allow greater focus on supporting the Commission to deliver culture change.

It was noted that the induction programme had been significantly improved over the past year, and it was important to have this in place now, ready for the significant onboarding of new staff due to take place over the coming year.

The Board noted the annual report of RemCo and verbal report of the 6 May 2025 meeting

Final Report of the Equality, Diversity and Inclusion Committee

The Chair, in his capacity as the former EDI Committee Chair, reported that the committee was confident that its work has been completed, citing two reasons.  

• At its final meeting on 11 March, the committee had looked at where it had started from and had seen a very significant shift over its lifetime, not least linked to the issues of risk management and culture referred to in this Board meeting.  
• An EDI ‘lens’ had been placed on the Corporate Plan so that it could take forward a mainstreamed EDI agenda that demonstrates a commitment to looking out for everybody included in elections.

Having agreed to conclude the committee, the Chair extended thanks to its members and particularly to Julie Howell for her excellent support throughout.

The Board noted the final report of the Equality, Diversity and Inclusion Committee and verbal report of 11 March meeting.

Tuesday 24 June, from 9:30am via Microsoft Teams

The Board were reminded that the June ARAC, RemCo and Board meetings would take place online. The June 24 Board meeting would be a shorter session centred on approval of the Annual Report and Accounts and receipt of the annual audit opinions.  

Following the main business, the board held short, closed session with the CEO to review progress with implementing board effectiveness recommendations from BDO’s survey of Commissioners, the Executive Team and the Senior Leadership Team in 2024.

Findings from this had been synthesised into BDO’s recent internal audit of Governance, reported to ARAC in May 2025. The board were satisfied with progress made, while also agreeing that many of the report’s recommendations had now been superseded by the rapid progress made to improve governance information flows over the last 12 months.

The Board reaffirmed its commitment to an annual process of self-assessment of its skills and effectiveness, to be revisited in November 2025.