Parliamentary briefing: Representation of the People Bill

The Representation of the People Bill has the potential to significantly improve the electoral system for voters, parties, campaigners and administrators. Changes to voter registration and political finance rules will bring particular benefits. Lowering the voting age will give around 1.7 million additional people the right to vote.

These reforms should strengthen the resilience and integrity of our electoral system, tackle many of the threats it faces and improve how elections work for those who participate.

While the Commission welcomes many of the changes set out in the Bill, some provisions could be strengthened further to improve the experience for voters and better protect the system from foreign interference.

The timetable for automated voter registration is unlikely to deliver benefits for voters before the next general election unless the Government thinks more ambitiously and flexibly about the way it intends to pilot and implement the scheme. The successful pilots in Wales last year show this is possible.  

The recent Rycroft Review into foreign financial influence and interference has rightly sounded the alarm on foreign interests seeking to interfere or exert influence on UK politics. The Bill offers a timely opportunity, where feasible, to act on the review’s proposals for strengthening the political finance system.  

We welcome the UK Government’s intention to amend the Bill to implement the review’s recommendation to use profit, not revenue, to determine how much a company can donate. This will make sure that voters can have confidence that entities are only able to influence the political process in a way that is more directly tied to the value of money they have made in the UK, and more closely reflects their true financial capacity to donate to UK politics from that money.  

This will significantly improve the Bill’s protections against foreign interference, and give voters confidence that only money made in the UK is funding donations to parties and campaigners. While we welcome the change of metric from revenue to profit, there are several opportunities, as recommended in the Rycroft Review, to further strengthen these controls to ensure they provide an effective and workable limit on these types of donations.

The Commission will work with the Government to support effective implementation of the Bill, making sure voters, political parties, campaigners and candidates, and electoral administrators have sufficient notice to understand and prepare for changes. Implementation should balance pace with practicality, recognising the scale of reform.  

Any change to the electoral system should improve the experience for voters, be workable, and improve the system’s security and accessibility. It is a crucial principle that changes to any electoral legislation should be clear at least six months before they are due to be implemented or complied with.  

The progress of the Bill is already delayed. Even on the Government’s current timetable, the timing for implementation of the complex measures is incredibly tight. The scale of change should not be underestimated. It is important there is sufficient time to put in place the necessary guidance, resources and public awareness campaigns to help those participating in and delivering elections understand what the changes mean for them. Further delay to the Bill’s progress will risk our and our stakeholders’ ability to implement changes for the 2028 and 2029 scheduled elections across the UK, and is likely to impact our ability to deliver clear and effective messaging to voters, candidates, campaigners and electoral administrators.

Votes at 16

Extending the franchise to 16- and 17-year-olds will give around 1.7m additional people the right to vote. It would align the voting age with devolved elections in Scotland and Wales, where 16- and 17-year-olds already have the right to vote.  

Although the Commission doesn’t take a view on the principle of franchise changes, which are significant constitutional questions for Parliament to consider, all those who are eligible to vote in elections should be able to do so freely and without barriers. Currently, 16- and 17-year-olds are the group least likely to be on the electoral register.  

Our priority will be to ensure that all newly enfranchised voters know how to register and exercise their right to vote, have access to educational material through their schools, colleges and communities, and to support the electoral community to deliver franchise changes effectively.

Research across several countries and states that have lowered their voting ages shows that when enfranchised, 16 and 17-year-olds tend to vote in greater numbers than those enfranchised at 18. 16 and 17-year-olds can already vote in Scottish Parliament elections, Senedd elections, and local elections in Scotland and Wales.

Extending the franchise to 16- and 17-year-olds increases the importance of equipping young people with the confidence to participate, so that they can continue to do so into the future. Our research shows that most young people support learning more about politics and elections:

• 72% of young people think children and young people should learn more about politics in school/college
• 53% of young people want to learn more about what difference their vote makes

We will build on our democratic education work to improve young people’s understanding of electoral systems, expanding our work to provide teachers and students with resources and support to deliver democratic education.  

Automatic or direct registration

Having complete and accurate registers is fundamental to democratic participation – if voters are not correctly registered, they cannot participate. Our research shows that as many as 8 million people across the UK are not correctly registered to vote.

The requirement to submit an application to be registered can be a barrier to some, and we know that some groups of people are less likely to be registered correctly: attainers and other young people, people who live in private rented accommodation, disabled people, and recent home-movers.

The Bill includes provisions that would enable automatic or direct registration. When commenced, these would impose a duty on Electoral Registration Officers (EROs) to register voters (or update a person’s details on the register) without requiring them to submit registration applications. An automated registration process would remove barriers for voters and make it easier to register and vote.  

As well as direct registration, the Government is exploring other forms of automated registration. These range from integrated registration – where applications for other services, such as obtaining a passport or driving licence, are used to prompt users to register to vote – to assisted registration, where EROs could use the information to offer targeted support to people rather than register them automatically.  

The Bill includes a power for regulations to be made to enable relevant data to be 
shared between (for example) Government departments, public bodies and EROs, to support these new forms of electoral registration.

While the final version of automatic/direct registration may take longer, we believe that significant progress can be made on integrated and some automatic registration implementation before the next general election, adding significant numbers to the electoral register accurately, and in particular helping add new 16- and 17-year-old voters to the register. Successful pilots in Wales last year show how effective this can be.

The Bill also includes powers to pilot the direct registration provisions before they are 
brought into effect. The Commission will independently evaluate automatic or direct registration pilots and continue to provide support and guidance to EROs, who under these proposals would continue to be responsible for compiling and maintaining the electoral registers throughout the year.  

We are urging the Government to move quickly to introduce automated systems to enable voters to be added to UK parliamentary electoral registers, in time for the next general election. We expect significant progress in rolling out integrated registration and, subject to successful pilots, the introduction of direct registration. We also currently run public awareness campaigns to promote voter registration ahead of elections. We will continue to do this, adapting our campaign approach to ensure it reflects the final registration model and accounting for possible divergence across the UK.

Expanding the list of accepted voter ID

The 2024 general election was the first at which voters were required to show photo ID when voting in polling stations, and most people were able to vote successfully. Our research found:

• fewer than 0.1% of people in Great Britain who tried to vote at a polling station were unable to because they could not present an accepted form of ID    
• around 4% of people who did not vote said that the requirement to show ID was a factor    
• that the requirement to show voter ID affected some people more than others, particularly people from a disadvantaged background.  

We recommended that the Government review the list of accepted IDs and the way the Voter Authority Certificate is issued, including whether there could be a later deadline to apply for a digitally-issued VAC. We also recommended that options for voters without accepted ID – such as attestation or ‘vouching’ – be considered.  

The Bill proposes expanding the list of ID accepted at polling stations to include bank cards as a non-photo form of ID for elections in Great Britain, and clarifies that digital versions of ID can be accepted at polling stations if they can be verified visually. Bank cards must include the person’s full name and be within a visible expiry date to be accepted.  

We will inform voters of any changes to accepted forms of ID, and continue to communicate when they need to show ID and how they can apply for a Voter Authority Certificate as an alternative. We will support electoral administrators and polling station staff in managing the voter ID verification process.  

Bank cards as voter ID

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 they make it harder for polling station staff to verify a person’s identity.  

It will also require staff to have a different way of checking ID because there is no common format, design or validation feature for bank cards, which is the case for other forms of ID.

Digital ID and voter authority certificates

Adding digital ID to vote at a polling station gives voters more flexibility and options for proving their identity.

Company donations

Currently, if a company is registered at Companies House and ‘carrying on business’ in the UK, it can donate to a UK political party or campaigner. The company does not need to have made enough money in the UK to cover the donations it makes. This opens the system to donations funded from activity overseas as foreign actors could, within the law, use a UK company as a conduit to channel money into UK elections.

As drafted, the Bill would introduce additional controls to reduce the risk of companies being used to allow foreign funding of campaigners in the UK, including a revenue test to limit the amount that companies can donate each year. However, using a company’s revenue to define the limit would mean that companies can still donate more money overall than they have made in the UK.  

The Government has tabled amendments which would replace revenue with profit as the metric for calculating how much a company can donate to a political party. We strongly support this change. Using profit instead of revenue ensures voters can have the confidence that entities are only able to influence the political process in a way that is more directly tied to the value of money they have made linked to the UK, and more closely reflects their true financial capacity to donate to UK politics from that money.  

While we welcome the move to a profit limit, as recommended in the Rycroft Review and previously by the Commission, there are several outstanding issues and opportunities to further strengthen these controls to ensure they provide an effective and workable limit on donations by companies.

Candidate enforcement regime 

Currently, individual police forces and prosecuting authorities are responsible for investigating and enforcing alleged political finance offences by election candidates. Criminal investigations and prosecutions may, in some cases, be disproportionate to the severity of the alleged offences. This can mean that prosecutions are not always taken forward, leading to an enforcement gap. The threat of criminal sanctions also deters people from standing for office or acting as an agent.  

The Bill would give responsibility for investigating and enforcing certain political finance offences relating to candidates and local third-party campaigners to the Electoral Commission, rather than the police. These offences would be subject to civil sanctions (for example, a fine or an enforcement undertaking) rather than criminal sanctions, which could lead to imprisonment and a criminal record.

Further changes needed to simplify candidate spending return rules

Currently candidates/agents must submit spending returns and declarations to the returning officer (RO) for the constituency or local authority. As our new enforcement functions come into place with the enactment of the Bill, candidates/agents will continue to be required to submit their returns to ROs but the Bill as drafted will also require them to submit a copy to the Commission.  

To ensure a simplified returns system and for the Commission to carry out its role effectively, it would be more practical for this to be switched, with returns delivered to the Commission as the primary recipient and copies going to the RO.

This would enable the regulated community to make use of our new Political Finance Online system, once established. The PFO system will produce an exact copy of the return, which candidates/agents can use to submit to ROs. This would ensure consistent submissions to the Commission and ROs and reduce the burden on candidates themselves. 

Candidate security

There has been a worrying rise in the abuse and intimidation of candidates in recent years. This has a significant impact on individuals and can deter those considering standing, thereby limiting the diversity of candidates and choices for voters.  

At the 2024 general election, we found that over half (55%) of candidates felt they had experienced some harassment, intimidation or abuse. Women were twice as likely, and ethnic minority respondents three times as likely, to report serious abuse.  

The Bill proposes adding a statutory aggravating factor in sentencing for certain election-related offences where they are motivated by hostility, and extends disqualification orders to include offences against electoral staff. This reflects the seriousness of these offences and should help deter potential offenders from engaging in abusive behaviour.  

The Commission supports candidates, campaigners and parties to understand what constitutes abuse and where to go if they experience it. Ahead of the May 2026 elections, the Commission also published a set of principles for campaigning, with a focus on maintaining respect, safety and honesty during robust debate. We are now considering our approach to expanding these and how a code of conduct for campaigning, as recommended by the Speaker’s Conference, can facilitate a robust but respectful campaigning environment.  

We will continue to work closely with partners, including the police, to provide support in tackling allegations of abuse. We will work with the Government to update guidance for police, electoral administrators and candidates on the safety and security of elections.