Board minutes: 25 November 2025

The Chair welcomed everyone to the meeting. Particular welcome was extended to new colleagues attending their first Board meeting as full attendees, Sam Hartley, Director, Policy Research and Voter Engagement and Alison Williams, General Counsel and Director of Devolution and Law.

Michael Coldwell, Interim Head of Governance, Risk and Assurance would continue to support the Board through this meeting and the next ahead of his departure. The Chair recorded thanks for Michael’s contribution and support.

No formal apologies were recorded. One new declaration was noted from Katy Radford, who had been appointed Director of the Office of Identity and Cultural Expression (OICE).

Meet the Team

The Head of Projects, was joined by members of her team to present on the work of the Programme Management Office (PMO)

There had been good progress in establishing a strengthened PMO to support delivery of the Corporate Plan. Sustained focus would be required as projects moved from set-up into delivery and as further electoral administration change emerged.

PMO colleagues briefly described their roles in strengthening project governance, assurance, training and benefits tracking. The Board welcomed the growing capability of the PMO and the clarity it was bringing to portfolio oversight and delivery.

The Chair thanked the team for the update and noted the Board’s strong support for the PMO function.

The Chief Executive presented his update on key engagement since the previous meeting in September, supported by members of the Executive Team.

The 2026/27 main estimate submission to the Llywydd’s Committee in Wales had gone well. Discussions focused on electoral complexity, public awareness challenges and future legislative change, particularly in the context of devolved arrangements.

Informal discussions with the Speaker's Committee on the Electoral Commission (SCEC) were constructive and increasingly centred on delivery confidence, organisational resilience, and value for money. Ongoing engagement with the Ethics and Integrity Commission was emphasised as a crucial growing relationship, especially with regard to upholding institutional independence and standards in public life.

The Board noted meetings with Sir Jeremy Wright MP and continued engagement with a cross-party Lords’ Group, which was providing a valuable forum for informed discussion on elections legislation and political finance issues. Engagement with the Labour Party General Secretary was noted, with a focus on compliance challenges and support for improved political finance capability and training.

There had been useful engagement with minister Sam Dixon, and participation in the SOLACE Summit had provided insight into local government capacity, reform pressures and data challenges relevant to electoral administration.

Turning to international engagement, discussions with the Swedish Electoral Commission had provided useful comparative insight into electoral administration and regulatory approaches. Participation in Tertullias was noted as a valuable forum for wider democratic debate and polarisation.

Engagement with the Korean Electoral Commission had highlighted advanced approaches to tackling deepfakes and electoral misinformation. There had also been ongoing collaboration with the International Panel on the Information Environment (IPIE), focusing on epistemic risk, misinformation and the implications of emerging technologies for democratic trust.

The Board were updated on the coming Elections Bill, including emerging timelines. There was continuing uncertainty regarding legislative timing, commencement and the scale of secondary legislation, and the delivery risks this created for the Commission and electoral administrators. The Board emphasised the importance of sustained engagement with government departments, particularly on implementation planning, devolved administration impacts and the application of the Gould principle.

There had been a significant increase in the volume and complexity of Freedom of Information (FO) requests. As well as having operational and resource impacts, there was an emerging risk of the FOI process being used in a more tactical or burdensome way. Members emphasised the importance of robust triage, proportionate handling and organisational resilience.

The Board also noted emerging challenges associated with deepfake technology and wider misinformation risks, and the importance of maintaining situational awareness, capability and pilot development and partnership working in this area.

A helpful supplementary paper on the Website Improvement Programme included findings of a comprehensive user-focused audit and early actions taken to improve navigation, consistency, tone and accessibility. The Board welcomed early evidence of improved user engagement and supported the continued phased approach to delivery and performance monitoring.

There was an update on the Edinburgh office, including early engagement with potential accommodation options and plans to return with proposals in due course. Members also noted the timing of the forthcoming staff survey results, and the importance of using the results to inform organisational development and workforce planning.

A formal appearance before the Speaker's Committee, an appearance before the Scottish Parliament Corporate Body for the 2026–2027 main estimate submission, and ongoing development of relationships with the Independent Parliamentary Standards Committee (IPSA) were among the upcoming activities that the Board noted. As legislative and delivery pressures increased, members emphasised the significance of sustaining strong parliamentary and stakeholder engagement.

The Corporate Director was joined by the Head of Financial Planning and Analysis and the Head of Projects to present the update, including the Performance Report for September 2025.

An update on financial performance and budget planning, including the developing position on the UK Parliamentary Main Estimate for 2026/27 was given.

Members discussed the timing and sequencing of engagement with the UK, Scottish and Welsh funding processes. The Board welcomed earlier engagement than in previous years, noting that this had helped reduce risk and improve transparency, particularly given the interaction between the new Corporate Plan and devolved funding settlements.

The September performance report was noted and members particularly welcomed the new format and covering paper from the Corporate Director, drawing attention to key themes.

Resolved: The Board noted the Finance and Performance Update and the September 2025 Performance Report.

There was a progress update on the UK Parliamentary Main Estimate for 2026–2027 along with draft numbers and the status of the 2025–2026 Supplementary Estimate.

The draft Main Estimate reflected expected election-related activity, inflationary challenges, and delivery commitments and was in line with the approved Corporate Plan. The Executive affirmed that the numbers were still tentative and would be improved before being formally submitted, including by interacting with Parliament and devolved funding partners.

Resolved: That the Board noted the progress made on the UK parliament main estimate. A further update would follow in January prior to approval at the Board meeting on 24 February. 

The Head of Financial Control and Reporting and the System Accountant supported the Corporate Director for this item. The deep dive on the new finance system project was the third in the series on the four Corporate Plan projects subject to enhanced assurance. This reflected its scale, complexity and importance to financial control.

The Corporate Director outlined the justification for replacing the current finance system and highlighted functional resilience and reporting issues as well as the growing operational and assurance risks associated with keeping the old system.

Clarifying requirements, ensuring robust governance arrangements and a clear delivery methodology would be the key areas of focus during the project's formative phase.

The Board discussed the delivery risks, including the dependency on specialists, the need for realistic phasing, and the importance of avoiding over-ambitious timelines. The Executive acknowledged the risks inherent in finance system replacement and emphasised the intention to take a measured, staged approach, with further engagement planned as the business case and options were developed

Resolved: The Board noted the update and confirmed that it would expect further assurance and progress reporting as the project moved forward.

The Board considered the annual review of the Electoral Commission’s risk appetite statement, which had been reviewed in detail by the Audit and Risk Assurance Committee (ARAC) at its meeting of 15 September 2025

The Board noted that the proposed risk appetite remained largely unchanged from the previous year, reflecting the Commission’s statutory role and operating environment.

The risk appetite would continue to support proportionate risk-taking in areas such as transformation and digital delivery, while maintaining a low tolerance for risks relating to independence, integrity, legal compliance and reputation.

Resolved: The Board approved the annual review of risk appetite.

The Board confirmed the appointment of Sheila Ritchie as Chair of the Audit and Risk Assurance Committee (ARAC) and Roseanna Cunningham as a member of ARAC, noting that these appointments supported continuity, appropriate skills utilisation and effective challenge within the Committee.

The Board approved the minutes of the Board meeting held on 16 September 2025, noting that they were an accurate record. 

The Board noted the updated Annual Corporate Governance Framework, confirming that it remained fit for purpose and that it continued to reflect good practice, statutory requirements and the Commission’s operating context. The framework provided a clear articulation of roles, responsibilities and decision-making arrangements across the organisation.

The Board noted the status of actions requested by the Board, and was assured that Elan Closs Stephens would share the work Bangor University is doing on Welsh language AI with the Head of DITF 

The Board noted the 2025/26 Board forward plan of business items and events, and confirmed that it provided appropriate coverage of strategic, regulatory and assurance matters over the year ahead, alongside space for Board development activity.

3 January 2026 at 9:30 via Teams