Board minutes: 15 July 2025

The Chair welcomed everyone to the meeting and provided an overview of the agenda. On the occasion of her last meeting, he paid tribute to Binnie Goh, Director of Legal Services and Reform and General Counsel, for all she had done in guiding and setting up the governance framework at the Commission in its current form.

There were no apologies and no new declarations of interest.

The Chief Executive Officer updated the Board on a very busy period for the Commission.

The Director of Electoral Administration and Regulation and the Interim Director of Policy and Research visited Ofcom the 24th of June to discuss the Online Safety Act, in particular Ofcom's statutory duty to produce a Code of Conduct on Material of Democratic Importance. The Commission would be supporting Ofcom to mobilise this work as soon as possible.

Meetings in Cardiff on 2 July with The Llywydd’s Committee and with the Cabinet secretary for Wales had been very productive. Discussions covered a wide range of issues including confirmation of spending limits, getting regulations through the Senedd in time for the 2026 Election, the planned deep fake detection pilot and the complexities of the communications campaigns for 2026, in particular the regional different rules on Voter ID having a ‘bleed across’ effect on social media.

Alongside the Chair, the CEO met with Patrick Valance, Minister of State for Science in the Department for Science, Innovation and Technology on 7 July. DSIT gave positive support to the Commission’s digital and automatic registration work and further engagement on this would follow in the Autumn.

A meeting with the cross-party House of Lords Group on 9 July looked ahead to the elections policy paper expected to be published by the government shortly.
The Director of Electoral Administration and Regulation updated the Board on a busy period for her team. Thursday 17 July would see the scheduled publication of the last tranche of 2024 General Election spending returns. This had been a hugely intensive and complex piece of work.

The Board asked if the Commission shared embargoed copies of spending returns before publication. This was not the case.

The Electoral Administration and Regulation team would be reissuing published guidance for regulated donees, which had not been updated since 2010. This guidance would outline the controls on donations and loans given to Office Holders, Party Members and Members Associations.

Executive leads updated on the Corporate Plan projects subject to enhanced assurance, with the exception of Political Finance Online, which was covered at item 5.

The Polling Station Finder/Post Code Look-Up project was moving forward and there had been useful engagement with Sym Roe, from Democracy Club, on how they put their tool together. A meeting with MHCLG would take place in the coming days to explore options for ensuring cooperation from local authorities to provide data for the tool.
The Voter Education project would have its first Project Board meeting in the coming week. Additional funding had been secured through the Portfolio Assurance Board for the first year of the project, which would enable certain priorities to be brought forward, in particular support for parents, increasing the regional scope of teacher training, and scaling up work on mis- and disinformation.

In preparation for the new Finance System project, a status review of the current finance system had been undertaken and this had revealed a number of challenges. Given that the Commission would be running with the current system for another two years while the new system was procured, fully tested and implemented, work was underway to look at getting more out of the current system and mitigating the associated risks.
On the Pay Review, there had been 100% staff sign-up to the new Terms and Conditions (excluding two staff absent due to long-term sickness). RemCo had signed off the new pay remit at its July meeting and union negotiations were moving forward positively. The Board acknowledge these important milestones and commended the work of the HR team.

The current round of recruitment to the Executive Team was progressing well with most interview panels concluded. The CEO thanked members of the Board for their involvement with the panels. Confirmation of the three new appointees was expected in the coming week.

The CEO looked forward to the 2025 All-Staff Conference, due to take place the following day at the Kia Oval, all arrangements for which were in place.

The Four Country Conference scheduled for 3 and 4 of  September was still intended to go ahead but may require postponement due to by-elections which would likely prevent attendance in-person by delegates from the countries affected.

The attendance strategy for UK Party Conferences during 2025 had been provided to the Board in the Convene document library. Each party conference would be attended by one Commissioner, one Executive Team member, and one member of staff. The attendance strategy has been designed give Commissioners access to  the full party  landscape, not just the Conferences that were most close-at-hand or familiar.

The Q1 Finance and Performance Report was noted. The Chair highlighted the importance of continuing to keep abreast of the four enhanced assurance projects. The Board noted that any KPIs not meeting target were explained in the pack, with remediation plans. The Board were also encouraged to see the use of Key System Indicators (KSIs) in the report. Although primarily a tool for the Executive Team, it was very useful for the Board to see the performance report and have the opportunity to challenge and seek further information as required.

Resolved: That the Board noted the Chief Executive’s update and Q1 Finance and Performance Report

The Head of Legislation Strategy and Coordination provided an update on the soon-expected strategy paper, which would be setting out what the Government intended to include in its Elections Bill, due in November 2025.

Following the useful consultation with the Board at the June Board meeting, the Commission had engaged intensively with MHCLG. Many aspects of the expected content reflected Commission proposals and were to be welcomed. Key areas of concern were raised (as noted at the June Board meeting) around the SPS, use of bank cards as a form of ID and the level of maximum fines. Discussions with officials on these concerns were productive and ongoing. The Bill remains on course to be published in the Autumn with drafts of secondary legislation expected to be shared by the end of 2025.

Discussion highlighted the various alternatives to using bank cards as a form of ID that had been identified by the Commission and were being raised with MHCLG. Specific concerns from Northern Ireland were also noted by the Head of Legislation Strategy and Coordination.

The lack of cross-Party engagement on the strategy paper to date was discussed and options for the Commission to convene this would be explored.

Resolved: That the Board noted the Strategy Paper update.

The Director of Corporate Services and Head of Financial Planning and Analysis were joined by members of the Scotland and Wales teams to present the the proposed budget proposals for 2026/27 and the provisional proposal to Westminster (UK and NI).

Costs in the proposals were consistent with the Corporate Plan. Comparing 2025 to 2026/27, core costs would increase in line with expected planned growth, although average costs would fall as a result of efficiencies. The significant area of uplift between 2025/26 and 2026/27 related to the elections in Scotland and Wales in 2026/27.

Commissioners with responsibility for Scotland and Wales had found the process of engagement this year to be very positive, particularly as this had happened at an earlier stage in the year than in 2024.

Action: There was a discussion about the budget for Westminster and it was agreed that additional analysis would be added to show:

• the separation between England and Northern Ireland (based on population headcount) and;
• cost of each country proposal per voter

The Board appreciated on the early work on the budgets and noted the current estimation of numbers, in particular the significant contingencies in place, especially in Wales, to be confirmed. Further work on efficiency due to be factored in was welcomed and the separation of budgets between England and Northern Ireland provided useful regional context.

Resolved: With final budget agreement for Scotland and Wales required before the next Board meeting in September, the Board agreed delegated authority for final sign-off to the CEO and Commissioners with responsibility for Scotland and Wales.

The Director of Electoral Administration and Regulation introduced one of the four Corporate Plan projects subject to enhanced assurance, all of which would be presented to the ARAC and the Board over the coming year. The ARAC focus would be risk-based and discussions the previous day had been on delivery assurance - given history of previous iterations of the project. A sound framework for project delivery was now in place, building in appropriate checkpoints.

The PFO Project lead gave an overview of the project, including governance arrangements, key stages and progress to date.

The Board emphasised the importance of engaging party experts, contractors, and constituency-level representatives to ensure practical feedback, while also making the PFO system accessible for smaller parties with limited experience. Direct dialogue between internal teams and party representatives was considered essential.

Clarification was provided to the Board on the merging of Stage Gates Three and Four to align build, migration, integration, testing, and training into a seamless process. Broader organisational dependencies were noted as critical to success. Concerns were raised about current risk scores, and it was explained that adjustments above the tolerance were used to escalate significant risks.

The project’s RAG status remains red until full resourcing is in place, though revision is anticipated. Staff were reported to be motivated and engaged, despite pressures. Members stressed the reputational importance of delivery, the need for transparency with the Board, and for political parties and candidates to be treated as closely-managed stakeholders.

Resolved: That the Board noted the deep dive into the PFO project
 

The Board considered the public awareness campaign for the May 2026 elections, focusing on paid advertising as the largest budget item. This was noted as one part of a wider strategy including partnerships, education, and owned channels. Future changes such as votes at 16 and automatic registration are expected to shape campaigns, with a further review scheduled next year.

A budget of just under £14 million across two financial years was presented, with emphasis on value for money and minimising wastage. Allocations were informed by analysis of previous campaigns and adjusted for inflation and electorate size. The strategy combines innovative digital platforms, community-specific outlets, and traditional media, with new initiatives targeting groups facing barriers to voter ID.

Discussion highlighted the need to improve youth registration, balance advertising with education activity, and ensuring outreach to underrepresented groups through both digital and non-digital means. Particular concern was expressed about voter engagement in Wales, where clear communication will be essential to maintaining trust.

Resolved: The budget was agreed, with the Board welcoming the campaign’s focus on efficiency, transparency, and inclusive engagement.

The Board reviewed the proposed impartiality framework for partner organisations delivering voter education and engagement work. It was emphasised that the Commission must target under-registered and under-represented groups based on need, while remaining demonstrably impartial. Members noted that clear requirements and robust controls are necessary to protect the Commission’s reputation and ensure projects are politically neutral.

The framework had been consulted on and introduced in England in Autumn 2024, with work now underway to adapt it for the devolved nations. Members welcomed this progress and highlighted the importance of consistency across all jurisdictions. They also discussed how guidance should be sufficiently clear to partners, particularly in relation to activities that could be perceived as partisan.

The Board stressed that impartiality safeguards should not deter valuable partnerships, but instead provide confidence in the Commission’s work. It was agreed that continued monitoring and transparency would be essential. The approach was agreed, subject to ongoing oversight as implementation was extended to the devolved nations.

Resolved: The framework proposal was agreed, subject to ongoing oversight as implementation was extended to the devolved nations.
 

The Board agreed the minutes of the meeting held on 24 June 2025 and noted the Commissioners’ annual declarations of interest.

The status of outstanding actions was reviewed, with items either confirmed as complete or incorporated into ongoing work.

The draft Forward Plan of meeting dates for 2026/27 was reviewed.  Members were assured that the calendar supported scrutiny, planning, and accountability. The Board agreed to hold the June 2026 meeting in Cardiff with an All-Staff Event, with venue options under consideration. Members highlighted the need to support travel arrangements, particularly for colleagues from Scotland. The November 2026 meeting in Belfast was also agreed in principle, with details to be confirmed. The Board were asked to feedback individually on the draft calendar ahead of the September meeting, when it would be finalised.
Committee Appointments: The reappointment of Commissioner Katy Radford  to the Remuneration and Human Resources Committee for a further three-year term from 1 November 2025 was agreed.

The forward agenda plan of future Board items was noted.

There being no further business, the meeting concluded at 16:30.
 

Tuesday 16 September 2025, 9.30 am, in person and by conference