Board minutes: 24 February 2026

The Chair welcomed all to the meeting, including Laura Ottery as the new Head of Governance, Risk and Assurance and Esmat Jeraj, the new Head of Voter Education and Partnerships who would observe the first part of the meeting.

The Chair explained that he would be absent for part of the meeting as he had been invited to give evidence at a session of the Public Administration and Constitutional Affairs Committee. In accordance with the Standing Orders, members were invited to agree that Sue Bruce would act as the temporary Chair until the Board Chair returned. Board members supported this motion.

Resolved: The Board approved Sue Bruce as the temporary Chair.

Apologies were received from Niki Nixon, Director, Communications.

Sue Bruce declared a new appointment; from 1 April 2026 she would be joining the Board of the Scottish and Southern Electricity Networks (SSEN); no conflicts with the business of the Commission were anticipated. Elan Closs Stephens declared a new appointment; she had been co-opted as a Council member of the Learned Society of Wales from January 2026 and had been elected as President from mid-May 2026. It was noted that the Society published reports and provided evidence to the Government on higher education matters; no conflicts with the business of the Commission were anticipated.

Meet the team – Legislation, Strategy and Coordination

The Head of Legislation, Strategy and Coordination introduced the structure and current priorities and areas of focus for the team, explaining that they were split to have a team focused on electoral administration and another on the regulation aspects of the bill. It was noted that the team did not just focus on UK legislation but coordinated legislative agendas across the devolved nations. The teams work on the two key programmes to deliver changes coming out of the Representation of the People Bill, reported through the Portfolio Assurance Board, chaired by the Chief Executive.

Board members discussed the progress of the Bill noting that this would be the 27th Representation of the People Act and yet there had been no electoral law consolidation, noting that it made the legislation impenetrable for voters, campaigners and electoral administrators. The Board supported continuing to press the importance of consolidation and simplification. Voter registration was also discussed in terms of the differing pace and practice across the nations.

The Chair thanked the team for the update and recognised how busy they had been and how crucial their work was.

The Chief Executive presented his update, supported by Executive Team members. He confirmed that organisational focus remained firmly on preparations for the May elections across all three nations, alongside planning for implementation of the Representation of the People Bill.

Preparations for the May polls were progressing well with continued close engagement with Returning Officers and Electoral Management Boards to support delivery of the elections. The Board noted that the Commission had needed to stand up aspects of its own operational plans at short notice following the reinstatement of certain local elections, and that teams had responded quickly to ensure appropriate guidance, support and communications were in place. Engagement with parties, campaigners and other stakeholders was continuing, including through an expanded programme of information and training sessions.

The Board also noted increased engagement from parties and campaigners in Wales as they prepared to operate under a new voting system. While this had resulted in a higher volume of queries, this was expected given the legislative changes, and it was positive that stakeholders were actively seeking advice and clarification where needed.

The Board noted increased engagement with policing partners, including joint training for Single Points of Contact (SPOCs) on integrity and safety. The Chief Executive highlighted improvements in coordination since the last elections and ongoing work to promote good practice nationally and locally. He reiterated the importance of securing stronger national‑level leadership within policing structures.

The Chief Executive spoke to the planned schedule for parliamentary discussions on the Representation of the People Bill and the Commission’s focus on implementation once the Bill completed its passage. Members discussed the compressed parliamentary schedule, the technical complexity of provisions on political finance, particularly the company donation provisions, and the interactions between reserved and devolved elements, including the need for Legislative Consent Motions. The Chief Executive reported constructive engagement with ministers and officials, including the ongoing independent Rycroft Review, which was expected to report at the end of March and would have implications for political finance reforms.

The Chief Executive also reported on wider engagement activities, and Commissioner Carole Mills updated the Board on her attendance at a recent elections conference in Delhi, which focused on global democratic challenges such as disinformation, intimidation of politicians and pressures on independent regulators. Opportunities for future international collaboration were being considered as part of development of the Commission’s international engagement strategy.

The Executive outlined progress on internal activity. Procurement for the Political Finance Online (PFO) system was moving ahead following agreement of the technical specification. The voter education programme was progressing well, with materials being tested in 35 schools. Corporate updates included configuration and testing of the new procurement system ahead of a June go‑live, completion of appraisal moderation, further development of the organisational design programme, and plans to streamline the Annual Report and Accounts.

Members discussed organisational capacity and resilience, particularly in the devolved offices. Immediate steps had been agreed by the Executive, including increasing management capacity in each devolved office. The Board emphasised the importance of staff wellbeing and sustainability as operational, legislative and regulatory demands continued to increase.

Resolved: The Board noted the update and endorsed the Executive’s approach to prioritisation and organisational resilience

The Board received an update on the proposed new office accommodation in Edinburgh. The current premises were not suitable either in size or quality, and alternative options had been assessed through a value‑for‑money process. The proposed new space offered a standard of accommodation consistent with other Commission offices, and government buildings across the UK, and was considered the best available option to meet organisational needs, including supporting recruitment and providing appropriate facilities. The cost, however, was significantly higher that our current rent in Edinburgh, which was not a market rent.

Members noted the positive engagement with senior stakeholders throughout the process and expressed thanks to those involved in bringing the recommendation forward.

Resolved: The Board approved:

(i) the signing of a 12‑year lease, with a break point at year 5, at Quay 1, Edinburgh Quay, subject to completion of legal checks and landlord approvals

(ii) commencement of the fit‑out procurement and transition planning to enable occupation from August 2026

The Corporate Director presented the Finance and Performance update to January 2026 and the accompanying summary paper, noting that this same report had been discussed with the Audit and Risk Assurance Committee (ARAC) the day prior. Overall organisational performance remained stable, with progress continuing across key activity areas. Members noted ongoing work to strengthen surge capacity arrangements to support operational resilience during periods of peak demand.

The Board was updated on recruitment activity, with headcount continuing to grow in line with planned workforce expansion to deliver the Corporate Plan. Members noted that work was also underway to review payroll provision to ensure it remained fit for purpose as the organisation expanded.

The Board discussed Freedom of Information performance. Members noted assurance from recent ARAC discussions, including the establishment of a strengthened Freedom of Information (FOI) working group and the use of digital tools to support efficient and accurate responses. The Board welcomed progress made to date and the continued focus on delivering statutory compliance.

Members received an update on financial planning, including preparations for upcoming Estimates processes. The Board discussed the likely areas of parliamentary interest, alongside improvements in forecasting that had resulted in a more precise funding request for core budgets. Members welcomed the clarity provided through the Main Estimate documentation and accompanying explanatory material.

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

The Board discussed the proposed international strategy, reflecting the Commission’s commitment to learning from global partners and contributing to wider democratic strengthening. Members noted the increasing level of external interest in the Commission’s expertise and commended the team’s work in managing this demand.

The Board agreed that a more strategic approach would support effective prioritisation and ensure that resources were focused on activities that delivered clear organisational benefit. Members discussed the proposed strands of work, the opportunities for shared learning, and the potential to support staff development through increased exposure to international practice.

The Board also discussed the proposed approach to monitoring international electoral developments. Members emphasised the importance of ensuring this work generated meaningful insight and noted that the level of monitoring would depend on agreed thematic priorities. Further clarity would be developed once the strategy was in place.

The Board highlighted opportunities to strengthen links with academic and research organisations and noted the potential value of reciprocal observation and other forms of peer learning. Members also recognised the need to consider resourcing implications as part of implementation planning.

It was noted that progress against the strategy would be brought back to the Board later in the year, and that consideration would be given to the proposal for a lead Commissioner to support oversight of this area of work.

Resolved: The Board endorsed the strategic objectives and areas of delivery for 2026, noting the associated resource considerations and risks.

The Board received a data-led presentation of how the Enforcement Policy had operated over 2025. This provided members with visibility of how the policy was being applied across the range of regulatory activity, consistently and impartially.

The systems and processes in place allowed a consistent, proportionate and timely regulatory approach, including the development of new tools and workflows since the policy was introduced. Members noted that these improvements were strengthening assurance, supporting compliance, and helped the Commission prepare for future legislative changes.

The Board discussed the use of data and trend analysis to inform regulatory decision‑making. Members welcomed the increased visibility this provided and the way it supported early engagement and preventative activity with parties and campaigners. The Board also noted the benefits of real‑time intelligence‑sharing across regulatory teams.

Members highlighted the importance of maintaining a clear and impartial process for managing concerns raised, and were assured that decision‑making remained

proportionate, evidence‑based and consistent with the policy approved by the Board. Members also recognised the progress made in improving clarity of communication with stakeholders and reducing unnecessary escalation.

The Board noted that this first consolidated dataset would allow year‑on‑year comparison in future and would support continuous improvement, including work to review the enforcement policy in light of forthcoming legislative reforms.

Resolved: The Board noted the update and confirmed their assurance that the Commission was operating a proportionate, impartial and supportive enforcement approach, consistent with the approved Policy.

The Board received the proposed key performance indicator (KPI) targets for the coming year. The overall set of 19 KPIs, aligned to the Corporate Plan, remained unchanged, with the Executive proposing a small number of targeted adjustments to reflect performance in the first year of the Plan and progress towards longer‑term aspirations.

Minor increases to the ambition of targets for complaints handling, timely regulatory advice and staff engagement were proposed. Members agreed these were appropriate and proportionate.

The Board discussed a small number of KPIs where further refinement would be required as part of a wider review during the next planning cycle. Members noted that the KPIs relating to the duration of investigations and the service of statutory notices were becoming less representative due to the small number and complexity of relevant cases. A more nuanced and segmented approach would be explored over the year ahead.

Members welcomed the clarity provided by separating Key Strategic Indicators (KSIs) from operational KPIs and emphasised the importance of maintaining stability in the KSIs to enable meaningful time‑series comparison. The Board agreed that the KPI set should remain limited in number and focused on statutory and organisational priorities.

The Board also discussed the KPI relating to Freedom of Information performance. Members reiterated the importance of improving response times and noted the actions underway to support recovery, including strengthened triage and improved data management. The Board supported maintaining the public‑facing target while using internal milestones to track progress.

The Board noted that the Executive would bring forward the scope for a wider review of KPIs, including how revisions could align with the development of corporate plans for Scotland and Wales.

Resolved: The Board approved the KPI targets for 2026/27.

The Board received the updated Strategic Risk Register, noting that the ARAC had undertaken detailed scrutiny of the revisions at its meeting the previous day. The update reflected the Executive Team’s full annual review of strategic risks.

Members noted that the overall risk environment facing the Commission continued to become more challenging, with several inherent risks increasing in scale or likelihood due to factors outside the Commission’s direct control. The Board emphasised the importance of ensuring this wider context was accurately reflected in the risk scoring and narratives.

The Board discussed the addition of a new strategic risk relating to organisational impartiality, and changes made to the risk concerning information and technology utilisation. Members agreed these were appropriate developments given the sector‑wide changes in regulatory expectations and the pace of technological advancement.

Members also reflected on the growing relevance of artificial intelligence and noted ARAC’s discussions on the need for caution when deploying new technologies while maintaining awareness of emerging risks.

The Board welcomed the planned work to review and sequence mitigations, recognising that some risks would remain inherently high, for reasons outside the Commission’s control, even with strong controls in place. Members noted the importance of continuing to articulate clearly what is within the Commission’s ability to manage and where residual risk is influenced by external factors.

Resolved: The Board noted the updated Strategic Risk Register and the outcome of the annual review of strategic risks.