Briefing on the Representation of the People Bill - Committee stage (Lords) - Conduct of elections
30 October 2026
This briefing has been prepared ahead of Lords Committee Stage consideration of Part 3 of the Representation of the People Bill. If you have any questions about this briefing, or the Bill more generally, please contact [email protected]
Part 3: Conduct of elections
Part 3 of the Bill makes several changes to how elections are conducted, including expanding the list of IDs accepted at polling stations to include bank cards, making changes to absent voting and candidate nomination processes, and changes intended to address candidate security at elections.
Clause 40 – Seniority of Returning Officers (see also Clause 32 – Seniority of Electoral Registration Officers)
This clause would require local authorities to appoint a senior officer to act as a Returning Officer (RO). The clause would narrow eligibility for RO roles to specified senior local authority officers, or other senior officers designated under the relevant local government legislation.
We support the policy intention of ensuring that ROs are appointed at an appropriately senior level within local authorities. This would help to ensure that they can direct local authority staff and resources to support the effective delivery of elections.
However, the current drafting may exclude experienced senior officers who already perform these roles effectively, creating risks for succession planning and electoral resilience.
Clause 41 – Timing of proceedings for candidate nominations
This clause amends the deadline for candidate nominations at UK Parliamentary general elections and Northern Ireland local elections. Currently, nominations can be delivered between 10am and 4pm during the nominations period and the deadline is 4pm on the last day of the period.
Clause 41 amends the nomination period for general elections so nominations can be delivered between 9am and 5pm, except on the final day of the nomination period when delivery can take place between 9am and 12pm. This makes 12pm on the last day the deadline for delivering nominations. This clause also amends the objections deadline to account for the amendments to the nominations period and deadline.
This change would provide more flexibility for candidates or their agents to deliver nomination papers. It would also give election teams more time on the final day to resolve queries, approve ballot papers and, for UK Parliamentary elections, begin printing postal ballots for overseas electors. This would help overseas voters receive, complete and return their postal vote in time for it to be counted.
Clauses 42 and 43 – Identification of candidates
These clauses introduce a requirement for a candidate to provide evidence of their identity, at UK parliamentary elections and Northern Ireland local elections.
Under current rules, a candidate must complete a set of nomination papers and sign a declaration of truth that the details they have provided are accurate. There is no requirement for a candidate to show ID as part of this, but it is an offence to provide a false statement on nomination papers.
The 2024 UK general election presented new challenges to the nomination system, with reports of alleged fake candidates and multiple candidates of the same name. The Commission recommended strengthening the requirements to deter candidates from misleading voters about their true identities.
Clauses 42 and 43 add a requirement for a candidate’s nomination papers at UK parliamentary elections and Northern Ireland local elections to be accompanied by, or by copies of, prescribed documents providing evidence of the candidate’s identity. The list of accepted documents will be set out in regulations.
These clauses also provide for a new ‘declaration of truth’. This must be signed by the candidate alongside their nomination papers to confirm awareness of offences relating to false statements on nomination papers, and that the papers do not contain any information or statement known to be false.
The clauses also prevent inspection of identity documents other than for a purpose authorised by law, set out circumstances where a nomination may not be valid in relation to identity documents and provide for the destruction of identity evidence.
Key considerations
Changes to the nominations process need to strike a balance between security, accessibility and workability.
The new requirement would provide assurance that the person named on the nomination paper exists as a real person. But it would not necessarily ensure that this is the same person who has submitted the nomination or consented to be nominated. This could only be achieved by requiring nomination papers to be submitted in person, allowing a visual check of the ID, which would significantly reduce the accessibility of the nominations process and increase the impact on Returning Officers and electoral administrators.
The proposed measures would place additional requirements on and create risk for electoral administrators to check the validity of identity documents for every candidate at a critical point in the election timetable.
Devolved considerations
These changes do not apply to devolved elections in Scotland and Wales. This will create significant divergence between the processes for reserved and devolved elections. We will support candidates and administrators in preparing for and managing any reserved elections in which the requirement applies.
Clauses 44 and 45 – Withdrawal of certificates authorising candidate descriptions; subscription of nomination paper
Clause 44 enables political parties to withdraw certificates issued by them to candidates authorising the use of a party description. The clauses cover UK parliamentary elections and local elections in Northern Ireland.
Certificates can be withdrawn up to 48 hours before the close of nominations and would invalidate the candidate’s nomination papers requiring them to submit fresh nomination papers if they wish to stand as an independent or for another party.
If a candidate’s nomination is invalidated because an authorisation certificate is withdrawn, clause 45 would allow anyone who had signed their nomination form to sign another form instead.
Key considerations
The proposed measures would place additional requirements on and create risk for electoral administrators to verify the validity of a notice of withdrawal, to ensure that this process is not misused.
It is important that these measures maintain fairness to candidates and subscribers. Parties should be responsible for carrying out due diligence on their candidates before the nominations period. Late changes to candidates risk confusing voters, particularly if a candidate has already started campaigning.
Amending the rules to allow a subscriber to subscribe another nomination form in the event of a candidate ceasing to be nominated because party support has been withdrawn should help maintain access to the nomination process for candidates and subscribers.
Candidates who wish to re-submit nomination papers following a withdrawal of certificates authorising the use of party descriptions will be able to seek support from the people who had subscribed to their original nomination form. Depending on the timing of the withdrawal of authorisation, however, there may be limited time for candidates to obtain the necessary support from subscribers and submit new nomination papers before the deadline.
Devolved considerations
These changes do not apply to devolved elections in Scotland and Wales. This will create significant divergence between the processes for reserved and devolved elections. We will support candidates and administrators in preparing for and managing any reserved elections at which parties can withdraw support from a candidate before the nomination deadline.
Clause 46 – Police contact form
Clause 46 makes provision for candidates to complete and return an additional (optional) form – the ‘police contact form’ – which would include the candidate’s full (and commonly used) names, and a statement that they wish to be contacted by police for matters relating to candidate safety.
Under these provisions, the Returning Officer must give a copy of the form to the relevant chief officer of police as soon as practicable after the publication of the statement of persons nominated. The RO cannot permit the inspection of the form by any person other than for a purpose authorised by law.
Key considerations
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 choice for voters.
At the 2026 elections in England, Wales and Scotland, many candidates told us they had experienced harassment, intimidation or threats. Of those that responded to our survey, 40% of candidates in England, 54% in Wales and 51% in Scotland said they experienced these issues. In England, this was an increase from 34% in 2025.
The Commission supports candidates, campaigners and parties to understand what constitutes abuse and where to go for help if they experience it. Ahead of the May 2026 elections we published principles to guide campaigning, with a focus on maintaining respect, safety and honesty during debate.
We are now reviewing how the principles worked in practice. Using these findings, we will expand the principles into a non-statutory code of conduct for future elections, in discussion with political parties, as recommended by the Speaker’s Conference. This will build on the existing codes of conduct for campaigners that have been developed in consultation with political parties.
This change should help support the safety and security of candidates. It places on a legislative footing changes we have already made to the 2026 nomination packs, which now include an optional candidate contact details sheet. This would enable police forces to proactively contact candidates to offer them information or support, but it would not require them to provide this consistently to all candidates.
We will continue to work closely with partners, including the police, to support responses to allegations of abuse. We will work with the Government to update guidance for police, electoral administrators and candidates on election safety and security.
Clause 47 – Calling out and completed corresponding number lists etc
This clause would remove the requirement in Northern Ireland for a poll clerk to call out the name and number of everyone they give a ballot paper to. There is no evidence that the absence of this requirement in polling stations elsewhere in the UK has led to an increased risk of electoral fraud. This would bring polling station procedures in Northern Ireland into line with the rest of the UK.
Clause 48 – Voter identification requirements
Amendments grouped with Clause 48
- 94 [Baroness O’Neill] would mean that the requirement for showing photographic ID at polling stations would remain, and removes the part of the Bill which allows for certain payment cards to be used as ID.
- 90 [Baroness O’Neill] would ensure that only payment cards and cash withdrawal cards that are issued subject to a search of a consumer’s credit file conducted in the way set out in the amendment would be able to be used as voter ID.
- 87 [Baroness Coffey] would remove bank cards as a form of voter identification.
- 86 [Baroness Coffey] would retain the requirement for voter identification to have a photograph.
- 88 [Baroness Coffey] would require a full name, not initial, when a bank card is used to identify a voter
- 89 [Lord Fuller] probes whether corporate purchasing cards or pay as you go currency cards will be accepted as a form of voter identification.
- 91 [Lord Fuller] would ensure eligible bank cards are marked so it is clear who meets the electoral requirements for voter identity.
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
We recommended that the Government reviews 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 first name or initial and surname 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
Adding digital ID to vote at a polling station gives voters more flexibility and options for proving their identity.
Key considerations
Introducing bank cards as voter ID will weaken security. This is because bank cards do not have a photo, and sometimes do not include a full name, so it is harder for polling station staff to verify a person’s identity. There are communities across the UK where several people with the same name and initial live at the same address.
We have previously recommended introducing ‘vouching’ or attestation 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, it keeps a link with a named voter who can prove their ID.
These changes would introduce significant difference between the requirements in Great Britain and those in Northern Ireland, where the requirement for voters to show photographic ID in polling stations would remain.
Clause 49 and Schedule 3 – Absent voting
More than 1.3 million people applied to vote by post at the 2024 general election. While most postal votes were received on time, some postal voters did not receive their ballot packs in time to complete and return them before polling day.
The Commission recommended improvements to the postal voting system to improve the service for voters, including considering whether the deadlines allow sufficient time to process postal votes.
The Bill makes provision for Electoral Registration Officers to issue postal ballots to people whose registration applications are still within the 5 working day period for objecting to a registration. The Bill also enables regulations to specify circumstances in which a postal voter may apply to have their postal vote sent to another address or may instead vote in person. It also amends the absent voting rules so that long-term postal and postal proxy vote arrangements can last for a maximum of five years rather than three years. These changes will work in conjunction with the UK Government’s proposals to move the postal vote application deadline from 11 working days before the poll to 14 working days.
Key considerations
Other forms of early or flexible voting could give voters further alternatives to postal or proxy voting. The Commission has carried out feasibility studies on whether potential alternatives, like advance voting or mobile voting in places like care homes, could work for elections in the UK.
The Government piloted two different flexible voting methods at the May 2026 local elections in England: early voting and voting at a centralised hub on normal polling day.
Our statutory evaluation found that the pilots were delivered successfully and received positive feedback from voters and electoral administrators. While uptake was limited, there was strong support for future flexible voting, particularly among newer voters.
Clauses 50 to 52 – Information to help people understand elections
These clauses provide the Secretary of State with powers to make regulations requiring electoral administrators to provide information to the Secretary of State or Electoral Commission about reserved elections in Great Britain.
Currently, information about elections is published by local authorities and several other organisations, including the Commission through the voter information section of our website.
This power would make it easier for us to help voters understand elections. It would require electoral administrators to provide us with more detailed local information about: elections, referendums or recall petitions, including information about who can vote; when, where and how to vote; the candidates or referendum question; how the election will be run; and support for people with disabilities and the election results.
We support the Secretary of State being given this power. The Secretary of State should be required to consult the Electoral Commission on the draft regulations to help identify, clarify and prioritise the data requirements. Regulations should ensure that data is provided in the correct format and in good time to provide the maximum benefit for voters ahead of elections.
Key considerations
Effective implementation of this provision would require changes to the electoral management software (EMS) used by administrators. EMS systems would need the functionality to capture and provide the data needed in a consistent and usable format. The Government should consult with EMS suppliers on the updates 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 provided voters with information for the May 2026 Senedd elections, and also for future devolved polls. There is no equivalent information sharing legislation in Scotland. Voters should have equality of information across all elections regardless of where they live. For this reason, the provisions in the Bill should be extended to Northern Ireland, and the Scottish and Welsh Governments should consider introducing equivalent legislation to support the provision of information at devolved elections.
Section 50(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 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.
The Government should explore more flexible ways of setting requirements for the content, manner, form and timing of election information for voters, without requiring changes to regulations each time. This should be informed by consultation with the Commission and electoral administrators to ensure that any approach is workable and supports the timely provision of accurate, accessible and up-to-date information.