Under the Political Parties, Elections and Referendums Act 2000 (PPERA), there are spending, donations and reporting laws that apply depending on how much you spend at a Senedd election, starting at spending above £700. The law sets out how much particular individuals and organisations can spend, and the registration and reporting requirements that will apply.

We call individuals and organisations who are thinking of campaigning in the run-up to an election but are not standing as a political party or candidate ‘non-party campaigners’. Political parties, candidates and non-party campaigners are vital to a healthy democracy. We encourage active participation by campaigners and aim to support campaigners with the law as they participate. 

Campaigners are entitled to carry out regulated campaign activities. However, where there is spending on regulated campaigning, there are laws that must be followed to ensure that this is transparent. This includes adding details to election material to show who is responsible for its publication (known as ‘imprints’), complying with limits on spending, requirements around donations, and reporting after the election.

This guidance provides detail on these laws and how they will apply to you if you are spending money on regulated campaign activities. 

If you are also campaigning at the Scottish Parliament election in 2026, please be aware that similar laws apply in Scotland. Please see our non-party guidance for Scottish Parliament elections.

Background

The Elections and Elected Bodies (Wales) Act 2024 introduced a new duty on the Electoral Commission to produce a Code of Practice on the laws relating to non-party campaigner spending. The Code is different from other types of guidance that we produce because it has been approved by the Senedd. The Code applies to elections to the Senedd.

The Commission must have regard to the Code when exercising its functions under Part 6 of PPERA. This part sets out the laws for non-party campaigners at elections. It is a statutory defence for a non-party campaigner to show that they complied with the Code in determining whether their campaign activity was regulated.

This non-statutory guidance for non-party campaigners at Senedd elections is based on the wording of the Code and provides additional information, advice and examples to help you understand the law. We have also provided case studies of real campaigns to guide you in determining what limits or reporting apply to your campaign activities.

This should support you to understand your obligations and campaign with confidence.

Key terms are explained throughout and provided in an alphabetical list at the end of the guidance.

Who is this guidance for?

This guidance is for individuals and organisations who are thinking of campaigning in the run-up to a Senedd election but are not standing as a political party or candidate.

Terms and expressions we use

In this guidance we use ‘must’ when we refer to a specific legal requirement. We use ‘should’ for items we consider to be minimum good practice, but which are not legal requirements.

We use ‘you’ when we refer to the individual or organisation spending or intending to spend money on campaigning ahead of an election.

Our guidance is separated out into sections, each of which deals with a different topic within the controls on non-party campaigners.

When you click on a link in the navigation list to the right, it will reveal the links to the different areas of guidance for each section. When you reach the end of a page, you can use the link at the bottom right-hand side to move to the next page of guidance.

If you would like to read an overview of how the non-party campaigner laws apply at Senedd elections, you should read:

• What is a non-party campaigner?
• Overview of the non-party campaigner requirements

If you are spending money at a Senedd election, you should read the following sections to understand how the laws will apply to you:
 

If you are intending to spend more than £10,000 on regulated campaign activities at the Senedd election, you should also read the following sections that apply to registered non-party campaigners:

Some individuals and organisations that are not registered political parties campaign for or against political parties or candidates or on issues around elections, without standing candidates themselves.

In electoral law, these individuals and organisations are defined as third parties. We call them non-party campaigners. There are laws that non-party campaigners must follow on campaign spending, donations, and reporting.

The two types of non-party campaigns

There are two types of non-party campaigns. These are:

Local campaigns

At Senedd elections, local campaigns are covered by the Senedd Cymru (Representation of the People) Order 2025. Under the law, local campaigns are subject to a spending limit. This limit is £1,000 on campaigning for or against one or more individual candidates in a constituency.3  There are different spending limits for local campaigns at each type of election.

The Electoral Commission does not regulate local campaigning and this guidance does not cover the local campaign regulations in detail.

Please see our guidance for local campaigners for more information about these campaigns.

Complaints about breaches of the laws that apply to local campaigns should be made to the police.

General campaigns

The laws for general campaigns are set out under the Political Parties, Elections and Referendums Act 2000 (PPERA). The Electoral Commission regulates these campaigns.

If you are campaigning for or against political parties, party list candidates, or categories of candidates, you may need to register with us and follow the laws on campaign spending, donations, and reporting.

These are set out in this guidance.

If your campaign involves both local and general campaigning, the controls that apply in these scenarios can be complicated. In these cases, we recommend you contact us for tailored advice.

If you are considering campaigning in the run-up to the Senedd election, you must be aware of the laws you must follow, which are covered by this guidance. Your reporting requirements and responsibilities will depend on how much you spend on regulated campaign activities during this period.

Your spending on regulated campaigning includes:

• spending paid by you, including spending on items or services bought before the regulated period begins and used during it1
• the value of something provided to you that you use in the campaign (notional spending)
• spending by your joint campaign partners when you campaign together with others in certain arrangements (joint campaigning)
• spending on regulated activities relating to other elections in Wales during the regulated period, such as spending at any local elections or by-elections.

You should not include spending that falls within the candidate or political party spending controls, or spending on activities that are not regulated. The activities that will and will not be regulated are detailed in this guidance. 

The lowest spending limit you must be aware of for campaigning at Senedd elections is £700. Anyone can spend up to £700 on regulated campaign activities, but only certain UK-based individuals and organisations can spend more than this.2  These are individuals and organisations that are eligible to register with us. The full list of eligible individuals and organisations can be found in Who can register?

If you are eligible to register, you can spend up to £10,000 in Wales.3  Campaigners intending to spend more than £10,000 can register with us to be included on the register of non-party campaigners. We call these ‘registered non-party campaigners’.

Registered non-party campaigners can spend a maximum of £30,000 on regulated campaign activities in Wales and must report their spending and donations to us after the election.4

For all non-party campaigners, you must also follow the laws about including imprints on election material. These apply whenever certain election material is produced, regardless of how much you spend or whether you are registered with the Electoral Commission.

The following table provides an overview of the responsibilities of non-party campaigners according to the amount they intend to spend on regulated campaign activities.

The regulated period

Spending by non-party campaigners on activities that are regulated will count towards the campaigner’s spending limit during a particular period in the run-up to the election. This period is called the ‘regulated period’.

The regulated period for the 2026 Senedd election begins on 7 January 2026, and ends on polling day, 7 May 2026.1   

Any spending you have incurred on regulated campaign activities which is used during the regulated period will count towards your spending limit. It includes: 

• spending on items or services bought before the regulated period begins, but used during it2
• the value of items or services given to you free of charge, or at a non-commercial discount of more than 10%, and then used in your campaign (see notional spending)3
• spending by your joint campaign partners when you campaign together with others in certain arrangements (joint campaigning)
• spending on regulated campaign activities relating to other elections in Wales during the regulated period, such as spending at any local elections or by-elections

The non-party campaigning laws apply to spending on what we call ‘regulated campaign activities’ during the regulated period. Electoral law specifies the activities that will and will not be regulated for non-party campaigners.

All non-party campaigners must keep records of their spending on regulated campaign activities to ensure they do not exceed their spending limit. If you register with us, you will also need to itemise and report your spending on these activities to us after the election.  

The activities that are regulated are:1

• the production or publication of material which is made available to the public at large or any section of the public
• canvassing and market research seeking views or information from members of the public
• press conferences and media events organised by the non-party campaigner
• transport in connection with publicising your campaign
• public rallies and other public events

These expenses are known as ‘controlled expenditure’ under the Political Parties, Elections and Referendums Act 2000 (PPERA).

To assess whether spending on one of these campaign activities is regulated, we look at two factors:

• the ‘purpose test’
• whether the activity is aimed at or involves the public 

In all cases, you should make an honest and reasonable assessment, based on the facts, of the proportion of spending that can be fairly attributed to your regulated campaign activities.

What is the purpose test?

Spending by non-party campaigners on one of the above activities is only regulated if it can reasonably be regarded as intended to promote or procure the electoral success of:

• one or more political parties
• one or more party list candidates
• political parties or candidates who support or do not support particular policies or
• another particular category of candidates

by influencing voters at an upcoming election to vote in a particular way.2

Whether an activity can reasonably be regarded as intending to influence voters to vote in a particular way is commonly known as the ‘purpose test’. Spending on any of the campaign activities will only be regulated if the activity meets the purpose test.

Meaning of the public

Some activities only need to meet the purpose test to be regulated, while other activities will only be regulated if they are also aimed at, or involve, the public. These are:

• the production or publication of material which is made available to the public at large or any section of the public 
• canvassing and market research seeking views or information from members of the public
• public rallies and other public events

‘The public’ is not defined in electoral law and therefore needs to be considered in its ordinary meaning. You will need to consider the involvement of the public for each of these activities. Guidance on the meaning of the public is included in the campaign activity pages.

The purpose test must be applied at the time spending on the activity is incurred. If spending was incurred prior to the regulated period but the activity takes place during the regulated period, the purpose test must be applied at the time the activity takes place.

While these are not set out in law, there are a number of factors that can help to determine whether campaign activity can be reasonably regarded as intended to influence voters to vote in a particular way at an upcoming election. These are:

1. Call to action
2. Tone
3. Context and timing
4. How a reasonable person would see the activity

No single factor on its own will determine whether  a particular campaign activity meets the purpose test. Rather all of the relevant factors taken together will determine whether a campaign activity meets the purpose test.

The Commission uses these factors when considering whether an activity meets the purpose test.

1. Call to action

A campaign that involves a call to action to voters to vote in a particular way at an upcoming election is likely to be reasonably regarded as promoting electoral success for a particular party or category of candidates and so meets the purpose test. The call to action may be explicit, or implicit.

A campaign that explicitly promotes particular parties or candidates, or implicitly promotes certain political parties or candidates over others, is likely to meet the purpose test.

It is unlikely that a public campaign without an explicit or implicit call to action to voters will meet the purpose test.

2. Tone

A campaign that is positive or negative towards a political party or parties, a category of candidates or a policy closely and publicly associated with a party or category of candidate is likely to be reasonably regarded as intending to influence voters to vote in a particular way and so meet the purpose test.

A campaign that makes a voter think of a particular political party or category of candidates is likely to be regarded as intended to influence voters to vote in a particular way and so meets the purpose test.

3. Context and timing 

A campaign on an issue or policy that is a prominent issue at the time the campaign activity takes place, that also meets the other factors, is likely to be reasonably regarded as promoting the electoral success of a particular party or category of candidates and so meet the purpose test.

A campaign that starts close to the date of an election and also meets the other factors, is more likely to be reasonably regarded as intending to influence voters to vote in a particular way at the upcoming election.

An ongoing campaign is unlikely to be reasonably regarded as intending to influence voters to vote in a particular way at the election.

4. How a reasonable person would see the activity

Campaign activity will only meet the purpose test if a reasonable person would regard the activity as intending to influence voters to vote in a particular way at an upcoming election.

The following pages provide detail on the factors you should consider when assessing whether your campaigning meets the purpose test.

The intention of your campaign may not be to influence voters. For example, you might run a campaign with one or more of the following intentions: 

• raising awareness of an issue
• influencing political parties to adopt a policy in their manifestos
• campaigning for or against government legislation
• providing information to voters
• encouraging people to register to vote
• encouraging people to vote, but not for anyone in particular

It is important to consider how a reasonable person would see your activity and whether they would think the purpose of your campaign is to influence people to vote a certain way at an upcoming election. Whatever the goals or intentions of your campaign, it may be that a reasonable person would see it as having a different intention, or a further intention.

Even if your intention is something else, your campaign will still meet the purpose test if it can be reasonably regarded as intended to influence voters to vote for or against a political party, one or more party list candidates, or a category of candidates. 

For example, your intention may be to influence political parties to adopt a policy. If you go about this by identifying and promoting parties and candidates who have already adopted the policy, then this will meet the purpose test.

Campaigns that mention political parties or candidates

In almost all cases, an activity will meet the purpose test if it:

• explicitly promotes political parties or candidates who support your campaign’s aims
• implicitly promotes some parties or candidates over others, for example by setting out or comparing the merits of the positions of political parties or candidates on a policy

Campaigns that do not mention political parties or candidates

If your campaign does not mention candidates, parties, or elections, then your spending is less likely to be regulated. This is because on the balance of the factors - in particular ‘call to action to voters’ and ‘tone’ – your activity is less likely to meet the purpose test.

In order for an activity to meet the test, the voter needs to know which way they are being persuaded to vote.

However, your campaign might identify a political party, parties, or group of candidates implicitly, without naming them. This could happen if a policy or issue is so closely and publicly associated with a party, parties or category of candidates that it is effectively a shorthand for them in your campaign.

In this case, your campaign will meet the purpose test if, after assessing all the factors, it is reasonable to regard your campaign activity on the policy as intended to influence voters to vote for or against those political parties or candidates.

This is because specific policies may be more likely than more general issues to be closely associated with parties or candidates.

A political party may publicly adopt policies that you are already actively campaigning for or against.

If your campaign did not meet the purpose test before the party changed its position, your planned campaign remains unlikely to meet the test.

However, as a result of the party changing their position, you might enhance or increase your spending on the issue over what you originally planned.
In this case where you alter your approach, the further campaign spending will be regulated if it can reasonably be regarded as intended to promote or criticise the party.

As usual you should assess your campaign using the factors we have set out.

For example, if you welcome a political party’s commitment to a policy that you have campaigned on, and it is clear that you would welcome a commitment from any political party, this will typically not meet the purpose test.

Some organisations have restrictions on their political activities, for example in their constitution, or charities which are bound by charity law.

These organisations may find that abiding by these separate restrictions means that they are less likely to carry out activities that meet the purpose test.

This is because the restrictions mean that many of the sorts of campaigns that meet the purpose test are prohibited for those organisations.

For example, charities must remain independent of party politics and must not support a political party or candidate, or create a perception of support as a result of their actions or participation.

If you are a charity and abide by charity law and guidance from the relevant charity regulator, in most circumstances your campaign activity is unlikely to meet the purpose test. The charity regulator in Wales is the Charity Commission for England and Wales.

You will still need to be aware of the non-party campaigner rules in case your activities meet the purpose test. In some circumstances, charities can and do carry out campaign activity that is regulated under electoral law. 

Our case studies from recent elections provide examples of issues-based campaigning that will be helpful when applying the purpose test to your own campaigns.

If you are planning a campaign and you are still unsure how it fits in with the rules for non-party campaigners, please get in touch and we can provide tailored advice.

Our case studies give examples of issues-based campaigns and explain whether or not they met the purpose test:

Case study 1: 0.7% of GDP on foreign aid

Case study 2: Immigration

Case study 3: Fracking

Case study 4: Balloting for industrial action

During the regulated period, spending on any of the following activities will be regulated if the activity meets the purpose test:1

• the production or publication of material which is made available to the public at large or any section of the public
• canvassing and market research seeking views or information from members of the public
• press conferences and media events organised by the non-party campaigner
• transport in connection with publicising your campaign
• public rallies and other public events

The following pages provide detail on the above activities.

Overheads

Overheads that are directly attributable to regulated campaign activity must be reported. The amount that must be included in the spending return is the proportion that reasonably reflects usage during the campaign.

Where there is no increase in spending on overheads beyond the normal spending incurred by a campaigner, spending on overheads will not be regulated. Where there is an increase in the cost of overheads incurred by a campaigner as a result of regulated campaign activity, that increase in spending must be reported.

The proportion that reasonably reflects usage is generally the cost that is incurred over and above the usual costs in a given period. Where an apportionment of overheads is necessary, an aggregated figure for each overhead is sufficient to meet the reporting obligations.

Overheads can include items such as:

• office space
• electricity bills
• the provision of phone lines and internet access
• mobile phones
• the provision of office equipment of any kind

Water, gas and council tax costs do not need to be reported, as they are not sufficiently closely connected to the regulated activity.

Campaign material will be a regulated campaign activity if it meets the purpose test and is made available for the public or a section of the public to hear or see. Whether the material is publicly available is determined by who has access to that material.

If you produce material that relates to an electoral event, or to a party, candidate or elected office-holder, you may need to include an imprint. There are separate requirements that apply to printed and digital materials. As good practice, we recommend you include an imprint on all materials you publish.

Material restricted to specific people

Material that you limit so it can only be seen by a closed group of members or people that have chosen to receive it will not be considered made available to the public, or a section of the public.

If the public are not able to access material, it will not be regulated campaign activity. This applies whether the material is printed or digital.

Canvassing and market research that meets the purpose test and take place during a regulated period will only be regulated campaign activity if it seeks the views of or information from the general public.

Canvassing and market research may include activities such as: 

• door knocking or other ways to canvass or collect information from members of the public
• using phone banks to call members of the public to promote a particular party or categories of candidate, or to find out how an individual intends to vote
• surveys or questionnaires sent to members of the public to find out how an individual intends to vote

If your canvassing or market research activity meets the purpose test but is conducted only with your organisation’s members or supporters, it will not be regulated campaign activity because it does not involve the general public.1

The following are examples of costs that will be included in connection with canvassing and market research.

Services, premises, facilities, or equipment

Examples include the costs of:

• services provided by any agency, individual or organisation
• premises or facilities
• equipment

used in connection with canvassing or market research. This includes recording, analysing or making use of the results of any market research or canvassing activity.

A press conference or media event will be considered regulated campaign activity if it is organised by you or on your behalf, and it meets the purpose test.

If you do not specifically invite the media to an open event you are holding, but the media attend anyway, it will not generally be regarded as a media event. However, it may be regarded as a public rally or event, where the laws apply.

If you hold a member-only event that you invite the media to, this will usually be a media event.

Examples include the costs of:

• services provided by any agency, individual or organisation
• equipment
• premises or facilities
• rights or licensing fees for images

used in connection with press conferences or other media events.

Press releases

The media will often ask organisations for comment on particular issues or events. If you are responding to queries from the media, any comment or statement made by you will not be considered a regulated campaign activity.

Press releases will not generally be considered regulated campaign activity if they are only sent to the media.

There is an exemption for content included in a newspaper or periodical other than advertisements. Please see The production or publication of material for more information.

Transport costs will be considered regulated campaign activity if you transport people in order to publicise a campaign that meets the purpose test. For example, you may have a campaign bus that you use as part of your campaign.

Sometimes spending on transport may instead fall within another category of regulated campaign activity. For example, if you hire a van and place advertisements on the van, this may be election material, or if you hire a minibus to take your supporters to a public rally, the transport costs may need to be counted as part of the costs of holding the public rally.

Regulated campaign activity does not include reasonable personal expenses incurred by an individual in travelling or providing for the individual’s personal needs.

Examples include the costs of transporting: 

• volunteers
• members, including staff members
• others campaigning on behalf of the non-party campaigner

to, from or around an electoral area where they are undertaking campaigning on behalf of the non-party campaigner. These transport costs can include: 

• purchasing or reimbursing tickets for public transport
• hiring vehicles
• purchasing fuel for a vehicle or charging an electric vehicle
• parking costs

It also includes the cost of using, or hiring, any vehicle or form of transport that displays material promoting the election result, including:

• design and application of the design to the vehicle or form of transport
• travelling between electoral areas
• travelling around an electoral area
• parking fees where a vehicle is used to display material

Reportable costs include all transport costs associated with one of the other listed activities. For example, transporting someone to a rally.

Rallies and events that meet the purpose test and take place during a regulated period will only be regulated campaign activity if they are open for anyone to hear, see or attend.

Where access to the rally or public event is limited by the non-party campaigner so that the general public are unable to take part, this will not be regulated.

Services, premises, facilities, or equipment 

Examples include the costs of:

• services provided by any agency, individual or organisation
• premises or facilities
• equipment

used in connection with public rallies or other public events. This includes costs associated with in-person and virtual rallies and events, such as hiring a venue or live streaming a virtual event to the public.

Other costs

Other costs may include:

• the cost of promoting or advertising the rally or event by any means
• providing goods, services or facilities at the event, such as seating or food

Costs that are excluded

The cost of providing general security at the event or security for any person attending the event will not be reportable.

Public rallies and events are also not regulated if they are:

• your organisation’s annual conference
• non-selective hustings, which are hustings that would not reasonably be regarded as intended to promote or oppose particular parties or categories of candidate

You may need to apportion your spending on regulated campaign activities that you undertake during and outside of the regulated period. For instance, this would include a service you started using before the regulated period began and continued using during the regulated period. In these scenarios, only the spending incurred on regulated campaign activities used during the regulated period are reportable and count towards your spending limit.

When you use an item for the first time, you must include the cost in your spending.

This includes items that were bought and paid for before the regulated period began, but used during it.

Items that are not used

You do not have to report spending on items that are not used (for example if leaflets are never distributed) and this does not count against the spending limit. You should retain the unused material or evidence it was destroyed.

If you use the leftover items at a later election, you must report the spending on those items at that later election.

Re-use of items

Where you have paid for an item, you must report the full cost at the time of first use, even if you intend to use it again at a future election.

If you do use it again at a subsequent election, you do not have to report the original payment again. There may be some associated costs which must be reported at that election, for example for storage or cleaning.

The following activities are not regulated:

• costs associated with publishing anything (except adverts) appearing in a newspaper, periodical or on a licensed broadcast channel1
• costs associated with translating anything from English into Welsh or from Welsh into English2
• costs that are reasonably attributable to an individual's disability3  
• volunteer time4
• reasonable personal expenses incurred by an individual in travelling or in providing for the individual's accommodation or other personal needs5
• reasonable expenses incurred that are reasonably attributable to the protection of persons or property6
• anything that counts as campaign spending by a registered political party or a candidate’s election expenses7

Translating material into or from Welsh

Any additional costs you incur if material you are publishing is translated from Welsh to English and vice versa do not count towards your spending limit. You must make an honest assessment of the basic costs if only one language was being used and should use this to determine the additional costs.

The following section covers registering as a non-party campaigner.

This includes:

• when you need to register with us
• which individuals and organisations can register
• what details you need to provide in your application
• the responsibilities of the responsible person
• what you need to do once you have registered
• how long you remain on the register of non-party campaigners

You may want to read this section alongside the earlier table that sets out the non-party campaigner requirements according to the amounts spent on regulated campaign activities. It can be found under Overview of the non-party campaigner requirements.

If you are eligible to register, you can register at any time before or during the regulated period at a Senedd election. 

You must be registered before you spend more than £10,000 on regulated campaign activity during the regulated period. We call this limit the ‘registration threshold’. Spending more than this amount without being on the register of non-party campaigners is an offence.1

The Commission maintains the register of non-party campaigners in the lead up to elections. Once a non-party campaigner is registered, we will publish their details on our public register.2  We will not publish any personal information, such as home addresses, email addresses or phone numbers.

You should check carefully whether you are eligible to register.

Only the following individuals or organisations can register with the Electoral Commission:

• an individual registered on a UK electoral register or resident in the UK
• a UK registered company which is incorporated in the UK and carries on business in the UK
• a UK registered trade union
• a UK registered building society
• a UK registered limited liability partnership which carries on business in the UK
• a UK registered friendly, industrial or provident society
• a UK based unincorporated association that carries on the majority of its business or other activities in the UK
• a body incorporated by Royal Charter
• a UK charitable incorporated organisation
• a Scottish partnership which carries on business in the UK1

If you do not fall into one of these categories, you cannot spend more than £700 in Wales on regulated campaign activities during the regulated period.2  If you do spend more than £700 when you are not eligible, you will be guilty of an offence.3

You should ensure you register as the type of entity that is carrying out the campaigning. For example, if you are an individual registered on a UK electoral register and you have a registered company, you should register as the entity that is doing the campaigning.

Who cannot register?

You cannot register as an individual non-party campaigner if you are already the responsible person for a registered non-party campaigner.4

Registered political parties are not eligible to register as a non-party campaigner and cannot spend more than £700 on regulated non-party campaigning activities. If you are a registered non-party campaigner, you will not be able to register as a political party until you are no longer registered as a non-party campaigner.5

You can register online using PEF Online. Alternatively, you can complete Form TP1 and send a signed copy of the form to us by email or post.

When we receive your application, we will check that you are eligible to register, that all the necessary information is provided and confirm in writing when you are registered. In some cases, we may ask you to provide further information before we can process your registration.

You should allow for time for your application to be processed and wait until we confirm that you are registered before spending over £10,000. This will ensure you do not exceed the registration threshold before you are registered, which is an offence.1

What information do you need to provide?

If you are registering as an individual, you must provide your name and home address.2  

If you are registering as a body incorporated by Royal Charter, a UK charitable incorporated organisation or a Scottish partnership which carries on business in the UK, you must provide:

• the name of the organisation and the address of its main office3
• the name of the ‘responsible person’4
• the organisation’s ‘relevant details’5
• the authorisation of the organisation’s secretary (or an individual acting in a similar capacity)6

For other organisations eligible to register, you must provide:

• the name of the organisation and the address of its registered or main office7
• the name of the ‘responsible person’8
• details of the organisation’s ‘relevant participators’9
• the authorisation of the organisation’s secretary (or an individual acting in a similar capacity)10

A person acting in a similar capacity to an organisation’s secretary will have overall responsibility for the organisation’s administrative affairs.

Please see the next pages for information about the responsible person, their responsibilities, and the relevant details and participators.

These details, except for an individual’s home address, will be included on your entry on the register of non-party campaigners.

We will not publish any personal information, such as home addresses, email addresses or phone numbers provided in your registration. 

As part of your registration, you will also be asked to provide information or evidence that you meet the requirements to be added to the register of non-party campaigners under your chosen category. For example, if you are registering as a company, you will be asked to provide your company registration number and evidence that you are carrying on business in the UK.

When submitting a notification as a non-party campaigner, you must appoint a responsible person. This person is responsible for making sure that the registered non-party campaigner follows the laws on spending, donations and reporting set out in the Political Parties, Elections and Referendums Act 2000 (PPERA).

If you are submitting a notification as an individual, you will automatically be the responsible person.1  All other categories of non-party campaigners must nominate someone to act as the responsible person when submitting a notification.2

If you are registered as an individual non-party campaigner or already act as the responsible person for another registered non-party campaigner, you cannot be appointed as the responsible person for another registered non-party campaigner.3

The responsible person must ensure that suitable systems are in place to ensure that spending and donations are dealt with correctly. They must also make a declaration in respect of each report to say that the reports are complete and correct. It is an offence to make a false declaration knowingly or recklessly.4

Under the law, some organisations must provide the names of the people that make up their governing bodies or committees when they submit a notification to the Commission. In law these are known as the organisation’s ‘relevant participators’ or ‘relevant details’.

The relevant participators and relevant details for each type of organisation are set out in the following tables:

Relevant participators

Relevant details

As a registered non-party campaigner, you must comply with spending and donations laws and reporting requirements.

As an overview, all registered non-party campaigners must:

• have a system in place for authorising spending on regulated campaign activity
• keep invoices and receipts for payments over £200 made as part of your spending on regulated campaign activity
• check that you can accept any donations you receive that are over £500 and record them
• report certain donations you receive for spending on regulated campaign activity to us after the election
• report your spending on regulated campaign activity to us after the election

Once you are registered, you are entitled to a free copy of the full electoral register.1  You can use it for electoral purposes, such as campaigning and checking the permissibility of donations from individuals.

You must not pass it on to anyone else, disclose any information on the register that doesn’t appear on the open register or make use of any information on the register for non-electoral purposes.2

Making changes

If you want to change any of your details, you can amend your notification at any time using Form TP2.3

You will remain on the register of non-party campaigners for 15 months from the date on which you applied to register.1  If your registration is due to expire during a regulated period, it will be automatically extended until the end of that regulated period.2

If you want to renew your registration, you must send us Form TP3 no sooner than one month prior to the 12-month anniversary of your original registration and no later than three months after that date.3  You can also renew using PEF Online. 

If any of your registered details have changed, you must update these when submitting your renewal.4

While we will aim to send you a reminder before your registration lapses, it remains your responsibility to renew your registration within the deadline if you wish to remain registered.

Your registration will expire if you do not submit your renewal to us during this time.5  If your registration expires and you want to be re-added to the register, you will need to submit a new application.

Registered non-party campaigners can spend up to £30,000 in Wales during the regulated period on regulated campaign activities.1

If you are eligible to register, you can spend up to £10,000 in Wales during the regulated period before registering.2

If you are not eligible to register, you can only spend up to £700 on regulated campaign activities in Wales during the regulated period.3

Under the law only certain individuals can authorise and make payments on behalf of registered non-party campaigners.

Once a non-party campaigner is registered, only the following people are allowed to incur and make payments for regulated campaign activities:

• the responsible person registered with us
• anyone authorised in writing by the responsible person1

For example, someone may be authorised by the responsible person to spend money on particular items, or up to a particular amount.

By ‘incur’ we mean make a legal commitment to spend money. You incur spending when you enter a transaction with a supplier and become liable to pay for the item, goods or service they have provided to you. For example, you hire a printing company to print leaflets, or you sign a contract to rent an office.

All payments over £200 must be supported by an invoice or receipt.2

Where an authorised person makes a payment of over £200, they must deliver both:

• the supporting invoice or receipt
• notification that they have made the payment

to the responsible person as soon as possible after making the payment.3  

These laws are in place to make sure that spending can be controlled and accurately recorded and reported. You should make sure that your staff, volunteers and campaigners know who can and cannot incur costs.

There are also time limits by which the responsible person must receive all invoices for regulated campaign spending.

This section covers notional spending, where you use any items, goods or services given to you for free, or at a non-commercial discount of more than 10%. It provides detail on the scenarios in which this spending is regulated and guidance on valuing and reporting this spending in your return.

Non-party campaigners may sometimes use property, services or facilities in their campaign that they did not have to spend money on, because the item or the services were provided as a benefit in kind, for free, or at a non-commercial discount.

This is known as ‘notional spending’.

You may incur notional spending where you use any items, goods or services given to you for free, or at a non-commercial discount of more than 10%. If any of these are used for regulated campaign activities, the value of what you use may count towards your spending limit and may be reportable in your spending return.

Notional spending is only applicable to non-commercial discounts which are special discounts given to the non-party campaigner. These are different to commercial discounts available to all customers, such as discounts for bulk orders or seasonal reductions. Items, goods and services purchased with commercial discounts will not be treated as notional spending.

What spending is treated as notional spending?

There are five tests that must all be met for an item (goods, a facility or a service) to count as notional spending:

1. it is transferred to you, or provided for your use or benefit
2. it is transferred or provided for free or at a non-commercial discount of more than 10%1
3. the difference in value between the commercial rate and what is paid by the non-party campaigner is over £2002
4. it is made use of by or on behalf of the non-party campaigner
5. it would have been a regulated campaign activity if you had incurred the spending3

The items or services are only used on behalf of the non-party campaigner if that use is directed, authorised or encouraged by the non-party campaigner or the responsible person.4

You must record both: 

• the value of the notional spending
• the total amount that was paid.

Items or services will not be treated as notional spending if:

• it was received at a discount of 10% or less
• the value of the discount is £200 or less.

Donations

The goods, services or facilities must be provided or transferred to the non-party campaigner to be treated as notional spending. This means that any notional spending will also be a donation to the non-party campaigner.

The difference in value between the market value or commercial rate, and the price paid, if any, must be dealt with in accordance with the laws on donations to non-party campaigners and may need to be reported to the Commission.

Notional spending with a value of more than £500 will also be a donation to the non-party campaigner. Please see How do you value a donation? for more information on non-monetary donations.

Seconded staff

If an employer seconds a member of staff to your campaign, you must record their gross salary and any additional allowances as notional spending.

You do not need to include the employer’s national insurance or pension contributions.5

How do you value notional spending?

To work out the value of notional spending, and to assess whether something is notional spending, you must first work out the commercial rate or market value of the item, goods or service you received. The commercial rate or market value means the price that would reasonably be expected to be paid for the item, goods or service, if it were on sale in the open market.1

The guiding principle is that, in all cases, you should make an honest and reasonable assessment of the value of the items, goods or service you have received. You should keep a record of how you reached your valuation and keep copies of any quotes you receive.

If the supplier is a commercial provider, you should use the rates they charge other customers. Alternatively, if the exact or similar options of the item or service is available on the market, you should use the rates charged by other providers to guide you in making a valuation.

If there are no exact or similar options of the goods or service available on the market, you should base your assessment on the market rates of a reasonable equivalent.

What needs to be reported as notional spending?

The value of notional spending will be the difference between the commercial rate or market value of what you have received and the amount (if any) you pay for it. 

For example, where an item is given to you free of charge, the value of notional spending is the market value of the item. If services are provided for your use at a non-commercial discount (of more than 10%), the notional spending will be the difference between the commercial rate of the service and the price you paid. 

It is good practice to include any evidence you have of the value of notional spending when you submit your return.

Items received free of charge

You are provided office accommodation from which to run your campaign free of charge, which you use for three out of four months of the regulated period.

You must report an appropriate amount of notional spending based on the use made of the office:

• Normal cost of rent per month for the office: £1,200
• Amount you were charged: £0
• Notional spending to be reported: £3,600 (3 × £1,200)

Items received at a discount

In the case where you have received an item, goods or service at a non-commercial discount, the value of the discount must be reported as notional spending and the amount you pay reported as a payment made by the non-party campaigner. The total of the two values will be the total value of the item.

For example, you are provided with campaign consultancy services at a non-commercial discounted rate. The provider offers you a discount of 15% off the rate they charge other clients, and you use their services during the regulated period.

You must report an appropriate amount of notional spending based on the use of the consultancy services:

• Commercial rate for the consultancy services: £8,000
• Amount you were charged and to be reported as payment made by the non-party campaigner: £6,800 (£8,000 - £1,200)
• Notional spending to be reported: £1,200 (£8,000 × 0.15)

Non-party campaigners may decide to work together on a campaign. Where the non-party campaigners work together on regulated campaign activity, the rules on joint campaigning may apply.

The rules on joint campaigning apply to registered and un-registered non-party campaigners.1

There are specific laws that apply when you want to work with another non-party campaigner as part of a joint campaign. When you spend money as part of a joint campaign, that spending may count towards the limits for each campaigner involved. This is to stop people getting around the spending limits by coordinating several campaigns at the same time.

You may choose to work with one or more campaigners on a joint campaign, perhaps in order to make the overall campaign more effective. 

The law sets out spending limits and reporting arrangements that apply if you or a campaigner that you are working with spends money on regulated campaign activity as part of a coordinated plan or arrangement. We call these the ‘joint campaign’ rules.

This section sets out the principles of joint campaigning, how these campaigns can be structured and how spending on joint campaigns should be accounted for and reported.

A non-party campaigner takes part in joint campaigning when the following key principles apply:

• they enter into a plan or other arrangement with one or more other non-party campaigners
• all non-party campaigners involved intend to spend money on regulated campaign activities in pursuance of that plan or arrangement
• one or more of the non-party campaigners involved actually incurs spending on regulated campaign activities as part of the plan or arrangement and
• that plan or arrangement can reasonably be regarded as intending to achieve a common purpose.1

We recognise that campaigners may come together to campaign in a variety of ways, both formal and informal, and that the ways campaigners interact with other campaigners may change during a campaign.

If you are thinking about starting a joint campaign and would like advice, or you are unsure whether you and another campaigner are working together as part of a joint campaign, you can email or call us for advice.

There must be more than one non-party campaigner

For the joint campaigning controls to apply, there must be more than one non-party campaigner involved.

Being part of a group or umbrella organisation where the organisations make decisions about their campaign activities independently is not joint campaigning as there is no plan or arrangement between non-party campaigners. 

Establishing a new organisation or group of non-party campaigners to spend money on campaigning will not be joint campaigning unless the key principles outlined above apply. More information on this can be found in Establishing a new organisation.

There must be an agreed intention to spend money on regulated campaign activities as part of the arrangement

If there is no intention to spend money on regulated campaign activities, there is no joint campaigning. For example, if you agree that all activity will be carried out by volunteers no spending will be incurred and there will be no joint campaigning.

There must be an agreed understanding as to the scope and purpose of the campaign

Non-party campaigners who happen to campaign about similar or related issues are not joint campaigners.

One or more of the non-party campaigners must incur spending on regulated campaign activities as part of the plan or arrangement, which is treated as spending on behalf of all campaigners involved

All spending on regulated campaign activities incurred as part of the plan or arrangement will fall within the joint campaigning rules. Even if one of the campaigners involved in the plan or arrangement does not incur their share of agreed spending, any spending incurred will still be joint campaigning and it may be reportable by all non-party campaigners involved.

Only spending that was agreed as part of the joint campaign counts towards the spending limit of the other non-party campaigners involved in the joint plan. Any spending that goes beyond or is incurred outside of the agreed plan or arrangement will not be counted as joint campaigning.

Activities that are joint campaigning

Non-party campaigners who engage in the following activities are likely to be joint campaigners:

• running a joint advertising campaign, involving joint leaflets or joint events
• running a co-ordinated campaign. For example, where it is agreed which areas are to be covered, which issues are raised or which voters to target
• joint working where one party can veto or must approve the other campaigner’s material

If you work with a number of other non-party campaigners, you may decide to establish a new body or organisation to conduct a campaign. The new body could be, for example, a company, a charity or an unincorporated association.

Provided that the new body is separate and distinct from the organisations that created it, then the body is treated as a different organisation from the campaigners that created the new body. As an organisation, the new body must be able to make decisions independently. This will be the case even if members of organisations that created the new body are part of its managing structure.

Campaign activity undertaken by the new body will not be part of a joint plan unless the new organisation works together with other non-party campaigners. Making a donation to the new body is not joint campaigning.

If the new organisation spends or plans to spend more than £10,000 on regulated campaign activity during the regulated period, it must make a notification to us and follow the laws regarding donations, spending and reporting. See When must you register with the Electoral Commission? for more information.

How joint campaigns can be structured

There are different ways you can structure your joint campaign:

• you can be working with other campaigners as an ‘ordinary joint campaigner’
• you can be involved in a joint campaign as either a ‘lead campaigner’ or a ‘minor campaigner’. We call a campaign that has a lead campaigner a ‘lead campaign’
• your joint campaign could be a combination of the two 

The way you structure your joint campaign can affect which spending counts towards your spending limit, and what you have to report.

If non-party campaigners work together as part of a joint campaign without a lead campaigner, we call that an ‘ordinary joint campaign’.

If you are a non-party campaigner in an ordinary joint campaign, you must record the combined regulated spending on the joint campaign as it will count towards the spending limits for each non-party campaigner involved, including yourself. 

If you want to spend more than £10,000 on regulated campaign activity across the UK, including joint campaigning, you must register with the Electoral Commission.

If you do not register, you cannot spend more than more than £10,000 during a regulated period on regulated campaign activity, including joint campaign spending by your joint campaign partners.

If you are a registered non-party campaigner involved in a joint campaign, you must report your own spending on the joint campaign. You do not have to report the spending by your joint campaign partners, but that spending does count towards your regulated spending total. You should report a total of what your partners spent on the joint campaign.

Where there is a joint campaign, one of the registered non-party campaigners may agree to report all of the joint campaign spending by each of the non-party campaigners involved in the joint campaign.

The registered non-party campaigner who agrees to report all of the joint campaign spending is known as the lead campaigner.1  A non-party campaigner whose joint campaign spending is reported by a lead campaigner is known as a minor campaigner.2

For example, three campaigners work together as part of a joint campaign. The campaigners each plan to spend £5,000 on the joint campaign, £15,000 in total.

If this was an ordinary joint campaign, the combined joint campaign spending would count towards each of the campaigners’ spending limits. This would require all three campaigners to register with the Commission, as a campaigner cannot spend more than £10,000 without being registered.

Instead, one campaigner can register, notify us that they are the lead campaigner, and report all of the spending on the joint campaign. The spending on the joint campaign will only count towards the lead campaigner’s spending limit and the other campaigners (the minor campaigners) can remain unregistered.

There is no limit on the number of lead campaigners in a joint campaign. There is also no limit on the number of minor campaigners who can work with any one lead campaigner in a joint campaign. However, a minor campaigner cannot also be a lead campaigner in the same campaign.

Lead campaigners must be registered, while minor campaigners must be unregistered. 

If a minor campaigner registers with us (for example because they incurred £10,000 of their own regulated spending outside of the joint campaign) then they cease to be a minor campaigner. Any joint campaign they are in, with a lead campaigner or with any other minor campaigners, reverts to being an ordinary joint campaign.

You should use Form TP7: Notification of Lead Campaigner, to notify us of the appointment of a lead campaigner and any minor campaigners.

This section of the guidance covers the laws regarding the donation requirements for registered non-party campaigners. 

This includes:

• what counts as a donation to registered non-party campaigners
• which donations can be accepted
• how to check if a source is permissible
• how to value a non-monetary donation
• how to return impermissible or unidentifiable donations
• when you need to report donations

You can find guidance on which donations are reportable after the election in Completing your return.

The laws on donations only apply to donations that are given to registered non-party campaigners, specifically towards their spending on regulated campaign activity. The laws do not cover money that is received for the organisation’s general purposes.

For the purposes of donations to non-party campaigners, a donation is:

• money, goods, property or services1
• given for the purpose of regulated campaign activity2  and
• without charge or on non-commercial terms and with a value of more than £500.3  

Anything with a value of £500 or less is not a donation for the purposes of PPERA.

Which donations are covered by the law?

Under the Political Parties, Elections and Referendums Act 2000 (PPERA), there are restrictions on the donations a registered non-party campaigner can accept. The law covers all donations that are given towards a registered non-party campaigner’s spending on regulated campaign activity. This includes donations for regulated campaign spending that are received outside of the regulated period.4

Some examples of donations include: 

• a gift of money or property 
• sponsorship of an event or publication 
• a subscription or affiliation payment 
• free or specially discounted use of an office

All registered non-party campaigners must keep records of donations they receive and check they can accept these donations.

The responsible person is responsible for making sure that your organisation follows the laws on donations.

The law does not cover money that you receive towards spending that is not regulated under the Political Parties, Elections and Referendums Act 2000 (PPERA).1  For example:

• donations given towards activities conducted before the regulated period, such as leaflets you produce and use before the regulated period begins
• donations given towards unregulated campaign activities

Money given to you or your organisation for general purposes, rather than specifically to fund regulated campaign activity, is not covered by electoral law.

For example, if you hold a fundraising event to raise money to support your organisation’s general activities or have regular donors who donate money on this basis, these contributions will not be covered by the laws on donations to registered non–party campaigners.

Donations of £500 or less

Donations of £500 or less are outside the scope of PPERA and you do not need to record or report them.2

However, you must be alert to situations where it appears that a donor is attempting to evade the permissibility requirements under PPERA. It is an offence to attempt to evade the restrictions on accepting donations.3  For example, if a number of donations of £400 are made from the same source in similar circumstances in an attempt to evade the permissibility requirements.

If you think this may be happening, you should contact us for advice.

You can only accept donations from certain sources, which are mainly UK-based.1  Please see Who can you accept donations from? for details on which sources are permissible.

Before you accept any donation of more than £500, you must take all reasonable steps to:

• make sure you know the true identity of the donor
• check that the donation is from a permissible source2

Where you receive a donation on behalf of someone else, we call the individual or organisation giving the donation to the campaigner an agent. The agent must provide you with the necessary details of the true donor so you can check the permissibility and report the details.3

If it is not completely clear who you should treat as the donor, you should check the facts to make sure.

How long do you have to check permissibility?

When you receive a donation, you have 30 days to check that the donor is permissible and return it if it is impermissible.

Even if you have made a permissibility check in connection with an earlier donation from the same source, you should make a fresh check for each subsequent donation. This is because the status of donors can change, particularly if a previous donation was some time ago.

You should keep a record of all your permissibility checks to show that you have followed the law.

If the donation isn’t from a permissible donor, or for any reason you can’t be sure of the true identity of the source, please read What do you do if you receive a donation from an impermissible or unidentifiable source? for further guidance on the actions you must take.

Donations on behalf of others

If you are given a donation on behalf of someone else, the person giving you the donation (the agent) must tell you: 

• that the donation is on behalf of someone else
• the actual donor’s details1

If you think that someone might be acting as an agent, you should find out the facts so that you can make the right checks. If you are not sure who you should treat as the donor, please contact us for advice.

It is an offence if the agent fails to provide you with the actual donor’s details without a reasonable excuse.2

If you are unable to confirm who a donation of more than £500 is from, or that it is from a permissible source, you should record it and return it.3

Donations from unidentified sources

If any interest has been gained on the donation your organisation can keep it, as it is not treated as a donation.4

Please see What do you do if you receive a donation from an impermissible or unidentifiable source? for guidance on how to return a donation.

When do you receive a donation?

You usually ‘receive’ a donation on the day you take ownership of it.

For example:

• if you are given free leaflets, you receive the donation when the leaflets are handed over to you
• if you are given a cheque, you receive the donation on the date that the cheque clears
• if a donation is transferred directly into your bank account, you receive the donation on the date that it is received into your account1

When do you accept a donation?

You accept a donation on the day you agree to keep the donation. For non-money donations, if you use the donation, you have thereby accepted it.

If your organisation keeps a donation after the 30-day period, you are also deemed to have accepted it.2

What makes a company permissible?

A company is permissible if it is:

• registered as a company at Companies House
• incorporated in the UK, and
• carrying on business in the UK1

You must be sure that the company meets all three criteria.

How do you check company registration?

You should check the register at Companies House. You should look at the full register entry for the company.

How do you check if the a company is carrying on business in the UK?

You must be satisfied that the company is carrying on business in the UK. The business can be non-profit making.

Even if you have direct personal knowledge of the company, you should check the Companies House register to see if:

• the company is in liquidation, dormant, or about to be struck off
• the company’s accounts and annual return are overdue

A company may still be carrying on business if it is in liquidation, dormant or late in filing documents, but you should make extra checks to satisfy yourself that this is the case.

For any company, you should consider looking at:

• the company’s website
• relevant trade, telephone directories or reputable websites
• the latest accounts filed at Companies House

If you are still not sure if the company is carrying on business in the UK, you should ask for written confirmation of its business activities from the company’s directors.

What do you need to record?

You must record:

• the name as it is shown on the register 
• the company’s registered office address 
• the registered company number2

What makes a limited liability partnership permissible?

A limited liability partnership (LLP) is a permissible donor if it is:

• registered as an LLP at Companies House
• carrying on business in the UK1

How do you check permissibility?

You should check the register at Companies House. You should look at the full register entry for the company.

How do you check if a limited liability partnership is carrying on business in the UK?

You must be satisfied that the LLP is carrying on business in the UK. The business can be non-profit making.

Even if you have direct personal knowledge of the LLP, you should check the Companies House register to see if:

• the LLP is in liquidation, dormant, or about to be struck off
• the LLP’s accounts and annual return are overdue

An LLP may still be carrying on business if it is in liquidation, dormant or late in filing documents, but you should make extra checks to satisfy yourself that this is the case.

For any LLP, you should consider looking at:

• the LLP’s website
• relevant trade, telephone directories or reputable websites
• the latest accounts filed at Companies House

If you are still not sure if the LLP is carrying on business in the UK, you should ask for written confirmation of its business activities from the LLP’s directors.

What do you need to record?

You must record:

• the name as it is shown on the register
• the LLP’s registered office address2

You should also record the LLP’s registered number.

What makes an unincorporated association permissible?

An unincorporated association is a permissible donor or lender if:

• it has more than one member
• the main office is in the UK
• it is carrying on business or other activities in the UK1

How do you check permissibility?

There is no register containing all unincorporated associations. You will need to check the details of the unincorporated association in each case.

In general, an unincorporated association is an association of two or more individuals who have come together to carry out a shared purpose.

An unincorporated association has an identifiable membership which is bound together by identifiable rules or an agreement between the members. These rules set out how the unincorporated association is to be run and managed.

Sometimes the rules might be formalised, for example in a written constitution. However, they do not need to be formalised.

For example, members’ clubs are sometimes unincorporated associations.

If you are not sure that an association meets the criteria, you should consider whether the donation is actually from individuals within it (rather than the association) or if someone within the association is acting as an agent for others.

If you think this is the case, you must check the permissibility of all individuals who have contributed more than £500 and treat them as the source.

You can find more information on carrying on business in the previous section How do you check if a company is carrying on business in the UK?

If an unincorporated association makes political donations amounting to more than £37,270 in a calendar year, you should make them aware that they have to report this to us.2  Please see our website for more information on unincorporated associations.

What do you need to record? 

You will need to record:

• the name of the unincorporated association
• the association’s main office address3

Trade unions

A trade union must be listed as a trade union by the Certification Officer to be permissible.1  You should check the official list of active trade unions on the Certification Officer’s website.

Building societies

A building society must be a building society within the meaning of the Building Societies Act 1986 to be permissible.2  You should check the list of building societies registered by the Financial Conduct Authority on the Mutuals Public Register.

Friendly societies, and industrial and provident societies

Friendly societies, and industrial and provident societies must be registered under the Friendly Societies Act 1974, the Co-operative and Community Benefit Societies Act 2014, or the Industrial and Provident Societies Act (Northern Ireland) 1969 to be permissible.3  You should check the Mutuals Public Register maintained by the Financial Conduct Authority.

What do you need to record?

You will need to record: 

• the name of the donor
• the address, as shown on the relevant register4

Non-party campaigners must put a value on any non-monetary donation. The value of a donation is the difference between the value of what is received, and the amount, if any, that the non-party campaigner pays for it.1  

Items that are received for free or at a non-commercial discount, where the difference in the commercial value and what was actually paid for it is more than £500, is a donation.

How do you work out the value of a donation?

If your organisation receives or provides an item, goods or service, you must work out its market value. The market value means the price that would reasonably be expected to be paid for the item, goods or service, if it was on sale in the open market.2

Working out the market value is needed to determine whether a donation has been made and what the value is. Any commercial income you gain from these transactions is not a donation.3

The following section provides guidance on how to assess the market value of goods and services, determine whether a donation has been made, and calculate the value of the donation.

Valuing a donation where your organisation receives goods or services

As well as receiving donations of money, you may also receive donations of goods and services. If you receive goods or services free of charge, or at a non-commercial discount, you must ensure these are valued at a comparable market rate.

Non-commercial discounts are special discounts that your organisation, specifically, is given by suppliers. These are different to commercial discounts available to all customers, such as discounts for bulk orders or seasonal reductions. The donation regulations only apply to non-commercial discounts.

If you are given goods or services, this will count as a donation if:

• the market value of the goods or services, if given free of charge, exceeds £500 , or1
• the amount of the non-commercial discount exceeds £5002

The donation is the difference between the market value of what you receive and the amount (if any) you pay for it.3

As with all types of donations, you must also ensure any donation you accept over £500 is from a permissible donor.4

Valuing a donation where your organisation hosts an event or provides goods or services

If your organisation hosts an event, or provides goods or services, you must ensure these are also valued at a comparable market rate. Any money received over and above the market value for the costs of the event (or the goods or services) to your organisation, constitutes a donation.5

It is important you are aware of the market value of the goods and services you sell because if someone pays more than the market value, the difference between what they pay you and the market value will be a donation if this amount exceeds £500.6

This is because any additional payment will be received on non-commercial terms, and the laws on donations will apply. The market value, or commercial income, is not a donation.7

The value of any donation will be the amount of money over and above the market value of the costs of the event (or the goods or services) received by your organisation from each donor.

You should work out how much it costs the organisation for each person attending the event, or for each person receiving goods or services. Then, deduct this amount from what each person paid you to find the value of the donation. This will be a donation if this amount is more than £500.8

The guiding principle

The guiding principle is that, in all cases, you should make an honest and reasonable assessment of the market or commercial value of the goods or services you have received or provided.

If the exact or similar options of the item or services are available on the market, you should use the rates charged by other providers to guide you in making a valuation. For example, if the donor is a commercial provider, you should use the rates they charge other similar customers.

If there are no exact or similar options of the goods or services available on the market, you should base your assessment on the market rates of a reasonable equivalent. If you are still not sure how to value a particular donation, please contact us for advice.

You should keep a record of how you reached your valuation.

Selling exclusive services

When trying to ascertain the market value, you may also wish to consider the appropriate level in the market of what you are selling.

For example, in some instances it may be reasonable to use a higher end market valuation. This is especially the case where the services are exclusive and/or where you have a degree of monopoly in the market.

Crowdfunding is the use of a web-based platform to collect donations. The platform is generally managed by a third-party provider and each individual fundraising campaign has a page on the site. 

Campaigns usually run for a set period of time. The fundraiser will often choose a deadline for reaching a fundraising goal. At the end of that time, the funds raised, minus a fee paid to the provider, are passed to the fundraiser.

There are different ways that crowdfunding platforms can pass funds to fundraisers. Some platforms may let you withdraw funds while your campaign is still running. Other platforms will only transfer funds to you once your campaign has ended. 

If you are collecting donations by crowdfunding, you must comply with the law on donations. The same requirements apply to these as with other donations you receive. The following pages provide detail on good practices you should follow if you are considering crowdfunding donations.

Before you create a crowdfunding page, you should check the features of the crowdfunding platform. You should make sure that you will have the tools and information you need to follow the law on donations.

You should collect sufficient information from donors to ensure that you can:

• Properly check that each regulated donation over £500 is from a permissible source
• Identify whether multiple donations have come from the same source
• Accurately record the donations you have received 

You should choose a crowdfunding platform that allows you to return donations which are not permissible.

Private crowdfunding donations and anonymous donations

In this guidance, we will refer to both private crowdfunding donations and anonymous donations. These terms are defined in the table below:

You should check that, as the fundraiser, you will be given access to the information you need on your donors. 

You must not accept donations made anonymously, or if you are unable to identify who the donor is.

You may accept private crowdfunding donations, provided you have the details required to check their permissibility. However, you may wish to consider whether you want to allow private crowdfunding donations for your campaign.

Accessing the funds raised

There are different ways that crowdfunding platforms can pass funds to fundraisers. Some platforms may let you withdraw funds while your campaign is still running, while others will only transfer funds to you once your campaign has ended. 

The length of time it takes to receive funds after the deadline may also vary depending on which crowdfunding platform you are using.  

It is important for you to understand when you can access funds. Once funds are received, you must carry out permissibility checks on relevant donations and keep records to meet reporting requirements. We recommend planning your crowdfunding campaign so that you will receive your donations with enough time to complete the required checks ahead of any relevant reporting deadlines.

You should make sure that your crowdfunding page provides information about what the money is being donated for. The laws on donations only apply to donations that are given to registered non-party campaigners, specifically towards their spending on regulated campaign activity. 

You should make clear whether the funds are being raised for spending on regulated campaign activity. This is important because the laws do not cover money that is received for the organisation’s general purposes.  You can find more information about the activities that count and how to assess whether an activity is regulated in How do you know whether spending is regulated?

You should make sure that the page contains information to explain that permissibility checks will be undertaken in compliance with the law. You should be clear about the reasons why you are collecting any information.

Your crowdfunding page should also explain that donation and donor information, including private donations, may be reported to the Electoral Commission and published. You can find a definition of the term ‘private crowdfunding donation’, in Choosing a crowdfunding platform.

We recommend you are clear and explain that if a donor cannot be identified, or if they are an impermissible donor, then the donation may have to be returned. If you do not receive enough information about a donor, you may need to contact them to ask for further details.

We recommend that you include an imprint on your crowdfunding page. You can find more information on digital imprints, in Imprints.

If you are planning to create a crowdfunding campaign and you are unsure about which requirements apply, or how to plan your campaign to meet requirements, you can reach out to us for advice.

There are restrictions on the donations a registered non-party campaigner can accept. The laws on donations only apply to donations over £500 that are given to registered non-party campaigners, specifically towards their spending on regulated campaign activity. The laws do not cover money that is received for the organisation’s general purposes.

You must only accept donations over £500 from a permissible source.1  You can find more information about permissible sources and how to check the permissibility of different types of donor, in Who can you accept donations from?

Money donated via a crowdfunding webpage that is £500 or less is not a donation in electoral law and is not reportable.2

You must not accept a donation with a value of over £500 if you cannot identify who the actual donor is, or if the donation is anonymous.3  An anonymous donation is where no donor information is provided to the person or organisation that has received the donation.

You must not accept donations from a political party.4

When accepting donations, you must be aware of situations where it appears a donor is attempting to evade the law on permissibility, for example if someone makes multiple donations of £500 or less. It is an offence to attempt to evade the controls on donations.5  If you think this may be happening, please contact us for advice.

Checking permissibility

Once a donation is received, you have 30 days to carry out permissibility checks and decide whether to accept or return it.6  The date of receipt is the date you receive the funds from the crowdfunding site. This may be different to the date that the donation was made. When you receive the funds will depend on whether the crowdfunding platform lets you make withdrawals during your campaign, or once it has ended.

You must comply with donation laws for any donation given towards your spending on regulated campaign activity, regardless of whether this was received before or during the regulated period.

You should record information for all of the donations you check, as you may need to report these details in your return.

Checking private donations

A private crowdfunding donation is where the donor’s details are not visible on a public crowdfunding page, but this information is provided to the person who created the page. 

You may accept private crowdfunding donations, provided you have the details required to check the donor’s permissibility.

When you receive a private crowdfunding donation over £500 towards your spending on regulated campaign activity, you should make sure that you have enough information on the donor to carry out permissibility checks. 

For example, you receive a donation of £600 from an individual towards the cost of a public rally, however the donor has only provided a name and email address. You should contact the donor to request their home address, which you will need to check whether the individual is on the UK electoral register, and therefore a permissible donor.

If you cannot check the donor is permissible from the information you have, you must return the donation.

Returning impermissible donations

If you cannot identify who the donor is, or if the donor is impermissible, then you must return the donation within 30 days of receipt.7  The crowdfunding platform you are using may allow you to return the donation directly to the donor.

If you cannot return the donation to the donor, you should return it to the financial institution used to transfer the donation. This could be the crowdfunding platform you are using, or the bank which has transferred the donation on behalf of the platform.

If it is not possible to return the donation to the donor or the financial institution, please contact us as you must send the donation to the Electoral Commission. We will pay it into the Consolidated Fund which is managed by HM Treasury.8  Please contact us to arrange for the transfer of these funds.

Registered non-party campaigners must report details of their spending on regulated campaign activities and details of any reportable donations they received towards this spending to us after the election. We call this report a spending and donations return. 

Before you complete and submit your spending and donations return, you should make sure that you have carried out permissibility checks on all regulated donations over £500.

There is no specific reporting period for donations in your spending and donations return. Under the law you must include donations you received as a registered non-party campaigner towards your spending on regulated campaign activities at any time, where the following reporting criteria is met. This includes donations for regulated campaign spending that you received outside of the regulated period.

Permissible donations

You must report donations whenever the total amount accepted from the donor towards meeting your spending on regulated campaign activity exceeds £7,500. This may be a single donation of more than £7,500, or multiple donations (over £500) which add up to more than £7,500.1  You must only include donations over £500 when adding together multiple donations from the same donor.

You must also report the total value of any other donations you accepted between £500 and £7,500 received for the purpose of meeting spending on regulated campaign activity.2  These are donations that are not reportable individually as the total does not exceed £7,500. You do not need to provide any more information about these donations.

Impermissible donations

You must report all donations over £500 from impermissible or unidentifiable donors received for the purpose of meeting spending on regulated campaign activity. You do not need to add together impermissible donations.

What details must you report?

For donations you have accepted that are (or add up to) over £7,500, you must report:

• the required details for the type of donor3  (please see Who can you accept donations from? for guidance on the details you must record for each donor type)
• the amount of the donation, if monetary, or the nature and value of the donation if non-monetary4
• the date you received the donation
• the date you accepted the donation5

For donations from impermissible or unidentifiable donors you must report:

• the name of the donor, if known, or the way the donation was made6
• the amount of the donation, if monetary, or the nature and value of the donation if non-monetary7
• the date you received the donation8
• the date you returned the donation9
• the action you took to return the donation (for example, the person or institution you returned it to)10

Crowdfunding platform fees

Crowdfunding platforms may charge fees for donation transactions, transfers of funds, and for using their platform. These fees count as an election expense, and you must report them in your return under the accommodation and administrative costs category. 

These fees may be a percentage of the donations you receive. You must report the full value of donations received11  and report the fees separately as election spending. It is acceptable for these fees to be aggregated and reported as one line of spending in your return.

After the election

You will need to report these details in your return. You can find more information about the return, and when you need to submit it, in Completing your return.

If you are unsure about which reporting requirements apply, you can contact us for advice.

A non-party campaigner decides to raise money on a crowdfunding website to spend on a campaign it will run before an upcoming Senedd election. The campaign is aimed at encouraging voters to support political parties and candidates that agree with the non-party campaigner’s position on a particular issue.

The non-party campaigner plans to spend the money it raises on regulated campaign activities. Based on previous campaigns it has run in the past, the organisation expects to spend over £10,000 in Wales during the regulated period and therefore registers with the Electoral Commission.

The election will take place on 7 May. For non-party campaigners, the regulated period begins on 7 January and ends on polling day. 

The non-party campaigner creates a crowdfunding page with a deadline of 24 March.

They choose a crowdfunding platform that collects enough information from donors to ensure they can complete their recording and reporting obligations, and allows donations to be returned if they are impermissible.

The non-party campaigner includes the following information on their crowdfunding page:

• what the money will be used for – “We are raising money to spend on [xxxxxx] for our upcoming campaign ahead of the Senedd election on 7 May”
• advice that permissibility checks will be undertaken for donations made over £500
• advice that if a donor cannot be verified, or is an impermissible source, their donation will be returned
• advice that details of donations may be reported to the Electoral Commission, and made publicly available
• a valid imprint

By the deadline, the campaigner has raised £24,750. The funds, minus the platform’s fees, are transferred to the non-party campaigner five working days later. The donations include:

• Donation A: £8,000 made on 2 February, donor name and home address received
• Donation B: £1,000 made on 12 April, donor name and home address received
• Donation C: private donation of £6,500 made on 14 April, donor name and email address received
• Several contributions between £500 and £7,500 made over the crowdfunding period
• Several contributions below £500 made over the crowdfunding period

The campaigner receives the funds on 31 March and downloads information on the donors from the crowdfunding platform. Their 30-day window for permissibility checks starts on 31 March, because this is the date of receipt.

Donation A is accepted after permissibility checks are carried out.

The campaigner carries out permissibility checks on Donation B and finds out that the donation was from an impermissible source. The candidate returns the donation to the donor through the crowdfunding platform.

The campaigner receives only the name and email address of the donor for Donation C. This information is not enough to check permissibility. The campaigner contacts the donor to request their home address, but doesn’t receive a response. The campaigner must reject the donation and return it to the donor.

When the non-party campaigner completes their spending and donations return, they record:

• Donation A, as it was above the £7,500 reporting threshold
• Donations B and C which were returned
• The total value of all other donations accepted between £500 and £7,500. These donations are checked for permissibility but only the total is reported in the return.

Contributions under £500 are not recorded or checked for permissibility.

What is sponsorship?

When support is given to a non-party campaigner to help them meet certain costs, this is defined as sponsorship. Under the law, different rules apply to these donations.

Sponsorship is support given to a non-party campaigner that helps them meet the costs of:

• any conference, meeting or other event (including digital conferences or events)
• the preparation, production, or distribution of a publication (print or digital), or 
• any study or research1

Are there any exemptions to the sponsorship rules?

The following costs do not count as sponsorship:2

• admission charges for conferences, meetings or other event
• the purchase price of any publication
• commercial rate payments for adverts in publications

The exemption only applies up to the commercial value of adverts which appear in publications. An example of this exemption is a publication which sets out a non-party campaigner’s aims, such as a manifesto ahead of an election.

Payments for any other type of advertising, such as banners at an event or digital advertising at a virtual event, should be treated as sponsorship if they help meet the cost of the event.

Advertising payments that do not help to meet the costs of an event or publication in any way do not count as sponsorship. For example, if you sell advertising space for your online event and do not incur any direct costs for the event.

However, if someone pays more than the commercial value of an advert, the difference between what they pay, and the commercial value will be a donation. Any amounts paid for adverts in publications above the commercial rate will not be exempt and will be considered a donation if the value exceeds £500.3

Where a payment does not amount to sponsorship, it may still be a donation if it meets the definition of a donation under the Political Parties, Elections and Referendums Act 2000 (PPERA).

When calculating the value of sponsorship, the full amount of the payment received should be taken into account and reported when it meets the reporting thresholds.

No deduction for any commercial value, or any benefit to the sponsor, should be made.

Fundraising events and dinners

If an event is hosted by or on behalf of your organisation, support to help meet the costs of the event must be treated as sponsorship.

For example, for payments for a place or table at a dinner, the difference between the value of the dinner and the amount paid is a donation.

If you receive a donation and it isn’t permissible, you must return it within 30 days. If your organisation keeps the impermissible donation after the 30 days, you are deemed to have accepted it. 

If your organisation accepts an impermissible donation, you may be subject to civil sanctions. The campaigner and the responsible person may also have committed criminal offences. Any potential breach will be dealt with in accordance with our Enforcement Policy.

If you’ve accepted an impermissible donation, you should tell us as soon as possible.

You must record:

• the name of the source, if known
• the amount of the donation, if money, or the nature and value of the donation if non-money
• the manner in which the donation was made
• the date you received the donation
• the date you returned the donation
• the action you took to return the donation (for example, the person or institution you returned it to)

You must include all impermissible donations in your quarterly report.

How do you return an impermissible donation?

If you know who the donor is, you must return it to them within 30 days of receiving the donation.1

If the donation is from an unidentified source (for example, an anonymous £600 money donation), you must return it within 30 days of receiving the donation to: 

• the person who transferred the donation to you; or 
• the financial institution used to transfer the donation2

If you cannot identify either, you must send the donation to the Electoral Commission.3  We will pay it into the Consolidated Fund, which is managed by HM Treasury.4  Please contact us to arrange for the transfer of these funds so we can provide you with our bank details.

If any interest has been gained on the donation before you return it, you can keep it. This is not treated as a donation and it does not need to be reported.5

What must you record?

If you receive a donation from an impermissible source, you must return it and must record these details:6

• the amount (for a monetary donation) or nature and value (for a non-monetary donation)
• if you could not establish the donor’s identity, details of how the donation was made
• if you have established the donor’s identity, but the donor was not permissible at the relevant time, the donor’s name and address
• the date you received the donation
• the date you returned the donation
• the action you took to return the donation (for example, the person or institution you returned it to)

You will need these details when you report the returned donation to us.

There are time limits by which the responsible person must receive all invoices for your campaign spending.

Receiving invoices from suppliers

You must obtain all your invoices for your campaign spending from suppliers within 30 days of the election.1

If you do not get an invoice within 30 days, you must not pay it after that time without getting a court order to do so. You should make your suppliers aware of this.

You must record details of invoices that haven’t been received by this deadline in your spending return.2

Paying invoices from suppliers

You must pay all your invoices from suppliers within 60 days of the election.3

Similarly, if you do not pay an invoice received on time within 60 days, you must not pay it after that time without getting a court order to do so. You should make your suppliers aware of this.

You must record details of items that haven’t been paid by this deadline in your spending return.4

Please note that if the deadline for any of the above falls on a weekend or public holiday, the deadline will move to the next working day.5  This is included within the following deadline calculations.
 

Leave to pay

Obtaining a court order to pay invoices received late or remaining unpaid after the deadline is known as leave to pay. It is an offence to make a payment for these claims without obtaining leave to pay.6

Leave to pay may be obtained by you or the supplier applying to the relevant court to obtain a court judgement or order for payment.

If you are registered as a non-party campaigner, you must report your donations and spending to us after the election if you spent more than £10,000 on regulated campaign activities during the regulated period.1

The deadline for submitting your spending and donations return is Friday 7 August 2026.

We provide a template form for you to use to help you keep records and complete your return. We recommend you use our template to ensure you are providing the details required by law.

You can download the form below and submit the completed form to us by email at [email protected] or you can post this to us.

Alternatively, you can submit your return on PEF Online. If you are submitting your spending and donations on PEF Online, please note that the spending return and donations report are separate.

If you are posting your return, we recommend that you post it in time to arrive no later than the last working day before the deadline.

Spending

In your return you must include:

• details of any spending incurred by you accompanied by invoices or receipts for any payment over £2002
• details of any notional spending (no invoices or receipts are required)
• details of any invoices not received by the deadline or items not paid by the deadline3
• details of any joint campaigning, where required

For each item of spending, you must report:

• what the spending was for, for example, leaflets or advertising
• the name and address of the supplier
• the amount or value of spending incurred
• the date the spending was incurred
• the date the claim for payment was made (if applicable)
• the date the payment was made (if applicable)

Donations

In your return you must report donations you received after you registered as a non-party campaigner. You only need to include donations of a certain value that you received towards your spending on regulated campaign activities. This includes donations towards your regulated campaign spending that you received before the start of the regulated period, if you were already registered.

We publish details of these donations on our public register. These details do not include the addresses of individuals who donate.

Permissible donations

You must report donations whenever the total amount accepted from the donor towards meeting your spending on regulated campaign activity exceeds £7,500. This may be a single donation of more than £7,500, or multiple donations (over £500) which add up to more than £7,500.4  You must only include donations over £500 when adding together multiple donations from the same donor.

You must also report the total value of any other donations you accepted between £500 and £7,500 received for the purpose of meeting spending on regulated campaign activity.5  These are donations that are not reportable individually as the total does not exceed £7,500. You do not need to provide any more information about these donations.

Impermissible donations

You must report all donations over £500 from impermissible or unidentifiable donors received for the purpose of meeting spending on regulated campaign activity.6  You do not need to add together impermissible donations.

What details must you report?

For donations you have accepted that are (or add up to) over £7,500, you must report:

• the required details for the type of donor7  (please see Who can you accept donations from? for guidance on the details you must record for each donor type)
• the amount of the donation, if monetary, or the nature and value of the donation if non-monetary8
• the date you received the donation
• the date you accepted the donation9

For donations from impermissible or unidentifiable donors you must report:

• the name of the donor, if known, or the manner in which the donation was made10  
• the amount of the donation, if monetary, or the nature and value of the donation if non-monetary11
• the date you received the donation12
• the date you returned the donation13
• the action you took to return the donation (for example, the person or institution you returned it to)14

Declaration

Alongside the return, the responsible person must declare that:

• the return is complete and correct15
• all payments were paid by them, or by a person they authorised16
• all accepted donations were received from permissible donors 17
• no other reportable donations were accepted by the non-party campaigner18

It is an offence for the responsible person to make a false declaration knowingly or recklessly.19

Donation

Under the Parties, Elections and Referendums Act 2000 (PPERA), a donation is money, goods or services given to a registered non-party campaigner 

• without charge or on non-commercial terms
• for the purpose of meeting spending on regulated campaign activities
• with a value of over £500.1

Some examples of donations include: 

• a gift of money or property 
• sponsorship of an event or publication 
• subscription or affiliation payments 
• free or specially discounted use of an office

See What is a donation? for more information.

Leave to pay

You must receive and pay invoices for regulated campaign spending within certain deadlines. If invoices remain unpaid after the deadline, you, or the supplier, must obtain a court order or judgement enabling you to pay it.2  This authorisation is known as leave to pay.

See Time limits for receiving and paying invoices for more information.

Market value

The price that might reasonably be expected to be paid for an item, goods or service if the item was on sale in the open market.3

Registration threshold 

Non-party campaigners intending to spend more than £10,000 on regulated campaign activity must register with the Commission.4  After registering, they will appear on the register of non-party campaigners.

Permissible

We use the term permissible to refer to donations that registered non-party campaigners are allowed to accept under PPERA.

Relevant participators/details

Under the law, some organisations must provide the names of the people that make up their governing bodies or committees when they register with the Commission. In law these are known as the organisation’s ‘relevant participators’ or ‘relevant details’.5

See Relevant participators and relevant details for more information.

Responsible person

The individual responsible for ensuring the registered non-party campaigner follows the laws on spending, donations and reporting set out in PPERA.6

See Responsible person for more information.