Parliamentary briefing: Representation of the People Bill (Part 3 – Conduct of elections: Voter ID, absent voting, and remaining conduct clauses) – Committee Stage

Key considerations

• Allowing voters to show bank cards as a form of ID is less secure than the current requirements, where voters need to show photo ID at polling stations. Because bank cards do not include a photo and sometimes do not include a full name, it will be harder for polling station staff to verify a person’s identity when they use a bank card.
• Bank cards also present practical challenges for polling station staff because they do not have a common format, design or validation feature, which is the case for other forms of ID.
• It is not uncommon for people with the same surname and initial to live at the same address, which if using ID without a photo or full name will be hard for staff to verify. This not only causes difficulties for administrators, but may also cause voters to be needlessly turned away as staff cannot confidently verify their identity.
• A similar issue may arise if bank cards are subject to different rules to other forms of ID. The government amendment requires bank cards to be in date, a rule which does not apply to any other form of voter ID.

Key consideration

• We have previously recommended that the Government should consider introducing ‘vouching’ or attestation for voters who do not have or cannot access any form of accepted ID at polling stations. Canada uses ‘vouching’ at its federal elections. It allows registered voters with an accepted form of ID to vouch for someone who does not have accepted ID. As a result, provides a safeguard by requiring a formal link to a named voter who has had their own identity verified.
• Given the Bill’s introduction of votes at 16, the list of accepted voter ID should be kept under review. It will be important to ensure it includes secure forms more likely to be held by younger voters to ensure elections are accessible for newly enfranchised young people.

Devolved considerations

• The Welsh Government and Scottish Government have both taken the decision to not introduce voter ID for devolved elections for which they are responsible. They did not provide legislative consent to the Elections Act 2022 and have not introduced the requirement as part of their own electoral reform programmes. This means ID is not required at Scottish and Welsh Parliamentary elections or devolved local elections – although it is required for reserved elections and recall petitions in Scotland and Wales.
• In Northern Ireland, photo ID has been a requirement for elections since 2003 and is well understood.

Key considerations

• Other forms of early or flexible voting could give voters further alternatives to postal or proxy voting. We have published feasibility studies showing how potential alternatives like advance voting or mobile voting in places like care homes could work for elections in the UK. 4
• Three local authorities in England are piloting early voting hubs at May 2026 local elections, and one local authority is piloting a voting hub on polling day itself. We will evaluate and report on these.

Key considerations

• This will require development work on administrators’ Electoral Management Software (EMS) to ensure that their systems have the required functionality to capture and provide the data needed in a consistent and usable format.
• This may result in new burdens on funding to cover the additional costs. We recommend that the UK Government undertakes direct consultation with EMS suppliers on the updates to systems required so that any necessary enhancements can be identified and factored into the planned implementation of the provisions.
• The new power only applies to reserved elections, excluding elections in Northern Ireland. The Electoral Management Board for Wales (EMB) has developed a Welsh Elections Information Platform, which will provide voters with information for the elections in May, and for future devolved polls. The Government should ensure its plans complement existing provisions in Wales and Scotland. Voters should have equality of information across all elections regardless of where they live. For this reason, the information sharing powers covered by these clauses should ideally be extended to all elections.
• Section 49(4) provides that the manner and form in which information must be provided will be set out in secondary legislation. While we welcome this as being a more useful mechanism than primary legislation, we are concerned that requiring 5 any changes to be made via regulations would hamper our ability to make changes quickly, for example to reflect changing circumstances or developments in information technology. This could make it difficult to provide information to voters in the best and most up-to-date way, and hard for voters to get information about elections in the future.
• A more flexible way forward would for the Commission to be given powers to issue directions, similar to those powers given to the Democracy & Boundary Commission Cymru to request information from Welsh Returning Officers. This would allow us the ability to make changes to how we inform voters about elections.

Key considerations

• The Government should make sure any legislation, including secondary legislation is made clear for voters, administrators and campaigners at least six months before they are due to be implemented or complied with.