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About this guidance

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 UK Parliamentary general election (UKPGE), 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, and we encourage active participation by campaigners. 

Carrying out regulated campaign activities is a valid choice for campaigners to make. 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’) and complying with limits on spending and reporting requirements.

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

Background

Background

The Elections Act 2022 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 UK Parliament. The Code applies to elections to the UK Parliament and the Northern Ireland Assembly.

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 PPERA 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 UKPGEs supplements the Code with additional information, advice and examples to help you understand the laws. We have also provided case studies of real campaigns to guide you in determining what limits or reporting apply to your campaign activities.

Where wording is from the Code this will be contained in red text boxes.

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

Who is this guidance for?

Who is this guidance for?

This guidance is for 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.

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.

Updates to our guidance

Date of updateDescription of change
May 2024

Updates to joint campaigning examples

April 2024

Updates to provide clarity on when registered non-party campaigners are required to submit pre-poll donation reports

December 2023

Updates to reflect the new spending limits

Our approach to enforcement

The Commission regulates political funding and spending in a way that is effective, proportionate and fair. We are committed to providing those we regulate with a clear understanding of their legal obligations through our guidance documents and advice service. If you are unsure of how any of the rules apply to you, please contact us for advice. We are happy to help, so please get in touch.

We use advice and guidance proactively in order to secure compliance. And we take enforcement action, using our investigatory powers and sanctions, where it is necessary and proportionate to do so in order to meet our enforcement aims and objectives. 

If you do not comply with the law, you or your organisation may be subject to civil or criminal sanctions. You can find more information about the Commission’s approach to enforcement at electoralcommission.org.uk/who-we-are-and-what-we-do/our-enforcement-work

Last updated: 24 November 2023

What is a non-party campaigner?

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. The Commission calls them non-party campaigners.

There are laws that non-party campaigners must follow on campaign spending, donations, and reporting.

Many individuals and organisations campaign in the run up to elections and meet the definition of a non-party campaigner but are not covered by the regulatory regime.

The two types of non-party campaigns

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

Local campaigns General campaigns

Campaigns for or against:

  • one or more candidates
  • in a particular constituency, or other electoral area1

Campaigns for or against:

  • one of more parties
  • parties or candidates that support or do not support particular policies
  • other categories of candidate2

Local campaigns

At UK Parliamentary general elections (UKPGEs), local campaigns are covered by the Representation of the People Act 1983 (RPA). Under the law, local campaigns are subject to a spending limit. This limit is £700 on campaigning for or against one or more candidates in a constituency3 . 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). These campaigns are regulated by the Electoral Commission.

If you are campaigning for or against political parties 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.

Last updated: 12 December 2023

Overview of the non-party campaigner requirements

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.

Your regulated spending total includes all of your regulated spending. This includes:

  • spending paid by you
  • the value of something that is provided for use in your campaign (notional spending)
  • spending by your joint campaign partners when you campaign together with others in certain arrangements (joint campaigning)
  • spending encouraging voters to support a single political party or any of its candidates (targeted spending)

For all non-party campaigners, you must 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.

How much do you plan to spend on regulated campaigning during the regulated period?Are you eligible to spend this amount?Are you required to submit a notification before spending this amount?Reporting requirements
Up to £700Anyone can spend up to £700 on regulated campaign activitiesNoNone. You must still follow the laws on including imprints on election material
Between £700 and £10,000 across the UK

Only certain individuals and organisations can spend more than £700 on regulated campaign activities

Please see Spending more than £700 on regulated campaign activities for the full list of eligible individuals and organisations

NoNone. You must still follow the laws on including imprints on election material
More than £10,000 across the UK, but up to the ‘UKPGE reporting threshold’ (£20,000 in England, or £10,000 in any of Scotland, Wales and Northern Ireland)

Only if you have a notification in force. We call non-party campaigners with a notification registered non-party campaigners

Please see Who can submit a notification? for the list of individuals and organisations eligible to submit a notification

If you are not planning to spend above the UKPGE reporting threshold, you can declare this in your notification

YesIf you make a reporting threshold declaration, and your spending remains below the reporting threshold, you will be exempt from reporting. You must still follow the laws on including imprints on election material
If you do not make a reporting threshold declaration, and your spending remains below the reporting threshold, you will be required to submit pre-poll donation reports. You must also follow the laws on including imprints on election material
More than the UKPGE reporting threshold (£20,000 in England or £10,000 in Scotland, Wales, or Northern Ireland)

Only if you have a notification in force. We call non-party campaigners with a notification registered non-party campaigners

Please see Who can submit a notification? for the list of individuals and organisations eligible to submit a notification

Yes

You will have a total amount you can spend during the regulated period as a registered non-party campaigner based on a calculation in the law

Please see Spending limits for more information

  • Pre-poll donation reports
  • Spending and donation report after the election
  • Imprints on election material

As well as the above spending limits and reporting requirements, there is a limit on the amount you can spend in a constituency.1  It is an offence to spend more than £17,553 in a constituency.2

If you are a registered non-party campaigner and you exceed the constituency spending limit, you will be required to submit pre-poll donation reports and a spending and donation report after the election.3  If you are not a registered non-party campaigner, there are no reporting requirements as these will only apply after registration.

Last updated: 22 December 2023

Who is covered by the law?

The laws on spending and donations apply to non-party campaigners who spend more than £700 on regulated campaign activity.

Who is covered by the law?

There are restrictions that apply to spending on regulated activities by individuals and organisations that are:

  • not based in the UK
  • not on a UK electoral register 
  • not registered as a non-party campaigner

who campaign in the run up to a UK Parliamentary general election.

The lowest spending limit you must be aware of for non-party campaigning at UK Parliamentary general elections (UKPGEs) is £700. If you only spend £700 or less on regulated activities, the spending and donation laws do not apply. The imprint requirements do however apply.

Only certain individuals and organisations, that are generally UK-based, can spend more than £700 on regulated campaign activities.1  These non-party campaigners can spend up to £10,000 across the UK without submitting a notification to the Commission. The full list of eligible individuals and organisations can be found on the next page.

Individuals and organisations that wish to spend more than £10,000 must submit a notification to the Electoral Commission.2  Non-party campaigners who have submitted a notification to us, which we call registered non-party campaigners, are subject to additional requirements regarding spending and reporting.

The following pages provide detail on the restrictions that apply before you submit a notification to us.

Last updated: 19 December 2023

Spending more than £700 on regulated campaign activities

Individuals and organisations that are not based in the UK or are not on a UK electoral register are not permitted to spend more than £700 on regulated campaign activity.1

A non-party campaigner can only spend more than £700 on regulated campaign activity if they are:

  • listed in section 88(2) PPERA as eligible to give a notification to the Commission or
  • an unincorporated association with the requisite UK connection.2

An unincorporated association has ‘the requisite UK connection’ if it consists of two or more persons, all of whom are registered overseas electors.3

Spending more than £700 on regulated campaign activities

You should check carefully whether you, or your organisation, are eligible to spend more than £700 on regulated activities.

Under the law, only the following types of individuals or organisations can spend more than £700 on general campaigning at UK Parliamentary general elections:

  • 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 UK
  • an unincorporated association with the requisite UK connection4

If you do not fall into one of these categories, you cannot spend more than £700.5  Registered political parties cannot spend more than £700 on regulated non-party campaigning activities. 

If you do spend more than £700 when you are not eligible, you will be guilty of an offence.6

How much can you spend before submitting a notification?

A non-party campaigner that is permitted to spend more than £700 on regulated campaign activity may spend up to £10,000 across the UK without notifying the Commission.7

Non-party campaigners intending to spend more than £10,000 on regulated campaign activity must submit a notification to the Commission following which they will appear on the register of notifications.8  Only certain types of entities can submit a notification to the Commission.

Unincorporated associations

An unincorporated association with the requisite UK connection is a type of organisation introduced under the Elections Act 2022. This category is in addition to the existing category of UK based unincorporated associations that carry on the majority of their business or other activities in the UK.

An unincorporated association has ‘the requisite UK connection’ if it consists of two or more individuals who are all registered overseas electors.9

Last updated: 19 December 2023

When do the non-party campaigner laws apply?

Spending by non-party campaigners is regulated in the period before a UKPGE and Northern Ireland Assembly elections. This is defined in PPERA as the ‘regulated period’.

UK Parliamentary general elections

The regulated period for non-party campaigners at a UKPGE is the 365 day period leading up to and including polling day.1

An election to the UK Parliament may be called at any time during the maximum five-year Parliamentary term.

Where the period of time between the announcement of an election and polling day is shorter than the length of the regulated period, the regulated period will still run for 365 days. The regulated period will be applied retrospectively and will cover a period before the election was announced.

Spending on campaign activities that take place during the retrospective regulated period, but prior to the announcement of an election, may be regulated. See section on the purpose test and the retrospective regulated period.

Where a second UKPGE is held within 365 days of the previous election, the second regulated period will start on the day after the first polling day and will run up to and including the second polling day.2

The regulated period

The regulated period

The regulated period for the 2024 UK Parliamentary general election (UKPGE) began on 6 July 2023, and runs to polling day on 4 July 2024.3   

This means that the regulated period will start well before the election is announced.

Any spending you have incurred on regulated campaign activities during the regulated period will count towards your spending limits. This includes where spending on regulated campaign activities you incurred before the start of the regulated period is treated as if you incurred it during the regulated period. By ‘incur’ we mean make a legal commitment to spend money, such as confirming an order.

It also includes any money spent on regulated activity relating to other elections other than the UKPGE that fall within the regulated period, including spending on any local elections or by-elections.

Example

A campaigner runs a campaign targeting voters in constituencies holding by-elections on the same day. They co-ordinate local events and publish material in the lead up to the by-elections that criticise the government and encourage voters to vote tactically to prevent the incumbent party from retaining the seats.

They are aware that their campaign is likely to be regulated and so they keep detailed records of what they have spent and ensure their spending remains below the threshold. This is to ensure that if a UK Parliamentary general election is called, they will know how much regulated spending they have incurred in the regulated period.

Six months after the start of the campaign, a UK Parliamentary general election is called. As the regulated period extends back 365 days before polling day, any spending by the campaigner on the by-elections has taken place in the retrospective regulated period. 

Any regulated campaign spending by the campaigner during the regulated period will count towards their spending limit at the UKPGE. Depending on how much the campaigner spends, they may be required to submit a notification and report their spending after the election.

Last updated: 23 May 2024

Regulated campaign activities

This section explains which of your campaign activities will be regulated under the law and count toward your spending limits. If you are required to report after the election, you will need to itemise your spending on these activities.

This section includes:

  • the activities that count as regulated campaign activities
  • how to assess whether an activity is regulated
  • the ‘purpose test’ and when an activity is ‘made available to the public’
  • the types of activities that are not regulated under the Political Parties, Elections and Referendums Act 2000 (PPERA)
Last updated: 24 November 2023

What are regulated campaign activities?

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

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

Controlled expenditure

Controlled expenditure is any spending incurred in respect of regulated campaign activity. Schedule 8A PPERA sets out the list of qualifying expenses that fall within the regulatory regime.

Activities that may be regulated

Activities that may be regulated

Activities that may be regulated

PPERA specifically lists the following expenses as falling within the regulatory regime: 

  • the production or publication of material which is made available to the public at large or any section of the public (in whatever form and by whatever means)
  • canvassing, or market research seeking views or information from, members of the public
  • press conferences, or other media events, organised by or on behalf of the non-party campaigner
  • transport (by any means) of persons to any place or places with a view to obtaining publicity
  • expenses in respect of the transport of such persons include the costs of hiring a particular means of transport 
  • public rallies or other public events, other than:
    • annual conferences of the non-party campaigner
    • any public procession or protest meeting, within the meaning of the Public Processions (Northern Ireland) Act 1998, in respect of which notice is given in accordance with section 6 or 7 of that Act (advance notice of public processions or related protest meetings

Expenses in respect of such events include costs incurred in connection with the attendance of persons at such events, the hire of premises for the purposes of such events or the provision of goods, services or facilities at them. But expenses in respect of such events do not include costs incurred in providing for the protection of persons or property.

Activities that may be regulated

To assess whether an activity is regulated as a qualifying expense, we look at two factors:

  • the ‘purpose test’
  • whether the activity is ‘made available to the public’

Some activities only need to meet the purpose test to be regulated, while other activities will only be regulated if they are made available to the public in addition to meeting the purpose test.

The following pages provide detail on the purpose test and activities made available to the public.

The honest assessment principle

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.

Last updated: 24 November 2023

What is the purpose test?

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

  • one or more political parties
  • political parties or candidates who support or do not support particular policies or
  • another particular category of candidates1

by influencing voters at an upcoming election to vote in a particular way. See definition of relevant elections in Annex B.

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 the following activities is regulated if (i) it occurs in relation to a general campaign during a regulated period and (ii) meets the purpose test:

  • press conferences or other media events organised by the non-party campaigner
  • transport in connection with publicising the campaign
  • production or publication of campaign 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 or other public events2

N/A

The following pages provide detail on how to apply the purpose test and examples of the above activities.

Last updated: 19 December 2023

Press conferences and media events

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.

Cost of press conferences or other dealings with the media

Cost of press conferences or other dealings with the media

This includes the cost of purchase, use or hire of any:

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

used to prepare, produce, facilitate or conduct press conferences or other media events.

Other costs

It includes the costs of any rights or licensing fee for any image used in preparation, production, facilitating or conducting press conferences or other media events.
It includes the cost of purchase and use of any equipment in connection with preparation, production, facilitating or conducting press conferences or other media events.

Press releases

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.

Example

An organisation runs a campaign focused on animal welfare. At the announcement of a UK Parliamentary general election, they compare the main political parties’ existing and proposed policies on animal welfare in the UK in a press release. In their statement, they express support for two of the party’s policies and encourage the public to vote for these parties at the upcoming UKPGE.

The campaigner sends the press release to media outlets at first, and it is not made available anywhere else. As the press release is only shared with media outlets, this is not considered a regulated campaign activity.

A week later, the campaigner shares the press release on their website and social media accounts. As the content of the press release meets the purpose test, this counts as a regulated campaign activity.

Last updated: 7 December 2023

Transport in connection with publicising your campaign

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 count as 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.

From the Code of Practice

Transport of volunteers or campaigners

It includes the cost of transporting: 

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

around an electoral area, or to and from an electoral area, including the cost of:

  • tickets for any transport,
  • hiring of any transport
  • fuel purchased for any transport
  • parking for any transport

where they are undertaking campaigning on behalf of the non-party campaigner.

Other costs

This includes the cost of use, or hire, of 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.

Last updated: 24 November 2023

Applying the purpose test

The purpose test must be applied at the time, or in the event of a retrospective regulated period as if 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 PPERA, 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 or not 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.

Last updated: 24 November 2023

The purpose test and the retrospective regulated period

The retrospective nature of the regulated period may concern campaigners due to uncertainty about whether the laws apply. However, most campaign activity undertaken before an election is announced is unlikely to meet the purpose test.

Although the regulated period is retrospective, the purpose test itself is not. This means that your campaign will only be regulated if it met the purpose test at the time it was carried out – and this is much less likely when there is no election.

First, many campaigns are purely issues-based rather than focusing on candidates or parties. Policies and issues may not be sufficiently closely and publicly associated with a party, parties or category of candidates for the campaign activity to meet the purpose test. This is especially true when the campaigns were intended to take place outside of an election period, since then they are less likely to have a call to action to voters, or even to mention parties or candidates.

Second, you are unlikely to be reasonably regarded as intending to influence people to vote in an election when you do not know or expect that the election is happening. Therefore, where this was the case, your activity is unlikely to have met the purpose test.

So for example, when there is no election and where they do not mention candidates, parties or elections:

  • campaigns on issues such as the cost of living or the NHS
  • campaigns advocating a Yes vote to industrial action

are unlikely to meet the purpose test, even if they are critical of the government. 

The likely exceptions to this are if either:

  • you ran campaigns which met the purpose test in a different election in the regulated period – for example, you campaigned in local elections earlier in the regulated period
  • you anticipated or made reference to the future election before it was announced – for example “Vote Conservative in the coming election”, or “Unseat MPs who voted for austerity”

If you spend money on campaigning like this at any time, then you will need to keep a record of what you have spent. This is so that if a UK Parliamentary general election is called, you will know how much regulated spending you have incurred in the regulated period.

Last updated: 24 November 2023

Intention

Multi-purpose campaigns

An activity that meets the purpose test, may have other aims as well as being ‘reasonably regarded as intended to influence how people vote’.

It is immaterial whether an activity can reasonably be regarded as intended to achieve another purpose or purposes if it can also be reasonably regarded as intending to influence voters to vote in a particular way.1

For example, a campaign activity is intended to achieve two purposes, purpose X and purpose Y. If purpose X meets the purpose test, it is irrelevant that purpose Y does not also meet the purpose test.

Intention

It is important to consider how a reasonable person would see your activity and whether they would think your campaign is intended to influence people to vote for or against a political party, parties or category of candidates at an upcoming election. Whatever the goals or intentions of your campaign, it may be that a reasonable person would regard it as having a different intention, or a further intention, from what you envisioned.

The primary 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

A campaign that can be reasonably regarded as having one of these intentions will not meet the purpose test unless it can also be reasonably regarded as having the intention to influence voters to vote for or against a political party or category of candidates.

Even if your primary 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 or category of candidates. 

For example, suppose your intention is 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.

Last updated: 19 December 2023

Campaigning on an issue

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.

Example: ‘Social care’ and the ‘dementia tax’ at the 2017 UK Parliamentary general election

Example: ‘Social care’ and the ‘dementia tax’ at the 2017 UK Parliamentary general election

‘Social care’ was a prominent issue at the time, but most prominent parties had a range of policies and positions on it. The general issue was not closely and publicly associated with any party or category of candidates. A campaign on social care would have been unlikely to meet the purpose test unless it specifically mentioned parties or candidates.

The ‘dementia tax’ was a particular clear and prominent policy of the Conservative and Unionist Party at the election, announced as part of their manifesto during the campaign. It was closely and publicly associated with them. A campaign against the dementia tax would have been much more likely to meet the purpose test on the balance of the factors – particularly because the very phrase ‘dementia tax’ is one that was coined and used by the Conservatives’ opponents in that election campaign.

Campaign activity before an election is announced

Campaign activity before an election is announced

An ongoing campaign on a particular issue that was carried out before an election was announced is unlikely to be reasonably regarded as intending to influence voters to vote in a particular way at an upcoming election if there is no upcoming election.

If an ongoing campaign continues unchanged once the election is announced, it is unlikely to be considered regulated campaign activity.

If activity around an ongoing campaign increases or is altered in the run up to an election in a way that means the activity meets the purpose test, i.e. the activity could now be reasonably regarded as intending to influence voters to vote in a particular way, it may be considered regulated campaign activity. From the point the campaign is considered regulated campaign activity, only the costs associated with that campaign are likely to be controlled expenditure and must be treated as such.

A campaign may still be considered regulated campaign activity where it is intended to achieve another purpose other than influencing voters if the campaign can be reasonably regarded as intending to influence voters to vote in a particular way at an upcoming election.

Last updated: 24 November 2023

What happens if the policy you have been campaigning on is adopted by a political party?

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.

Examples

Example A

An organisation runs a campaign calling for the government and political parties to commit to freezing rent to help renters during the cost of living crisis. The campaign has been running for a number of years.

Once a UK Parliamentary general election is announced, the organisation increases its spending as planned to widen the reach of its campaign. The scope of the campaign does not change during the regulated period.

During the regulated period, several parties identify the increased costs of renting as an issue for the public. Two parties include a pledge to freeze rent costs for certain renters in their manifestos, while a few others propose general policies around increasing support for renters if they are elected.

The organisation puts out a statement welcoming each party’s policy announcement and encourages other parties to follow their example.

While the campaign is positive about parties that support freezing rent by praising them for adopting policies, the purpose test is not met. The timing of the campaign and call to action aimed at political parties to change their policies, rather than targeting voters suggests the activity cannot reasonably be regarded as intended to influence voters. Spending on the activity is not regulated.

Example B

A campaigner has been campaigning on a policy area for some years. They run a digital advertising campaign on the issue, which runs during the regulated period for a UKPGE. The campaign does not mention parties or candidates and does not meet the purpose test.

During the course of the campaign, the governing party commits to abolishing a key spending commitment in that policy area. The three largest opposition parties all reaffirm their commitment to the spending, and the issue becomes a prominent one in the election. This creates a new political context.

The digital advertising campaign continues throughout. Since the campaign has not changed since it was launched before the parties adopted the issue, the purpose test does not need to be applied in the new political context. The campaign still does not meet the test.

Responding to the increased interest in their issue, the campaigner increases their media appearances and social media activity. In these they focus on the advantages of the policy and urge all parties to reaffirm their commitment. 

Because this is new activity, the purpose test needs to be applied in the new political context. However, as the campaign continues to be generic, without a specific call to action by voters, even in the new context it cannot be reasonably regarded as intended to influence voters, and the purpose test is not met.

Nearer the election, the campaigner runs a new advertising campaign with the slogan ‘Vote to save the commitment’. In the new political context, the slogan has a clear link to the election and a call to action to voters with ‘Vote’. Because the issue is prominent, a reasonable person would think that the campaigner intends to influence voters to vote against the governing party and for any of the three opposition parties who have made the commitment. Spending on the new campaign is regulated.

Last updated: 24 November 2023

Charities and other organisations with limits on their political activities

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.

Part of the UKCharity regulator
England and WalesCharity Commission for England and Wales
ScotlandOSCR
Northern IrelandThe Charity Commission for Northern Ireland

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. For example, at the UK Parliamentary general elections in 2015 and 2017, charities conducted campaigns that met the tests for regulated spending and have registered with us in accordance with the 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 advice.

Last updated: 12 January 2024

Meaning of ‘the public’

The meaning of ‘the public’ will need to be considered in relation to the following campaign activities when determining whether spending on the activity is regulated:

  • canvassing and market research of the public
  • public rallies and events
  • the production or publication of material

‘The public’ has no statutory definition and therefore needs to be considered in its ordinary meaning.

N/A

The following pages provide detail on the above activities and how you will need to consider the involvement of the public for each one.

Last updated: 24 November 2023

Canvassing and market research

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.

Services, premises, facilities, or equipment provided by others

It includes the cost of use, or hire, of any:

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

used to:

  • to prepare, produce, facilitate, conduct or co-ordinate canvassing or market research including recording or analysing or otherwise utilising the results of any market research or canvassing activity

For example, the cost of using phone banks to contact voters, including the development of scripts for use by phone bank employees that are designed to influence voters.

Example

Example

You hire a market research agency to gain insight into the voting intention of members of the public across Scotland and analyse this data for you. The aim of the market research is to use it to target your campaign at voters at the upcoming UK Parliamentary general election.

Using this data, you then hire phone banks to contact voters in the weeks leading up to an election, with the intention of influencing them to vote for parties who support a specific policy. 

As the market research and phone banking meet the purpose test and seek the views of members of the public, these costs will be considered regulated campaign activities.

From the Code of Practice

Costs of obtaining or maintaining data 

This includes the cost of accessing, purchasing, developing and maintaining:

  • IT software or contact databases
  • data sets, including the use of data analytics to facilitate or undertake market research or canvassing 

For example, it includes the cost of undertaking social media listening and analysing the result to analyse the intention of voters. 

Other costs

It includes the cost of any purchase and use of any equipment required to:

  • prepare, produce or facilitate canvassing or market research 
  • conduct or co-ordinate canvassing or market research
  • record or analyse or otherwise utilise the results of any market research or canvassing activity

For example, laptops or tablets if used for canvassing and mobile phones if used by the leader/co-ordinator of the canvassing where that equipment and/or associated costs are paid for or reimbursed by registered third party.

Canvassing

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

Last updated: 19 December 2023

Public rallies and other public events

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 provided by others

This includes the cost of use, or hire, of any:

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

used in:

  • promoting a rally or other event
  • holding or conducting a rally or other event
  • live streaming or broadcasting a rally or other event by any means

Other costs

It includes the cost of promoting or advertising the rally or event by any means.

It includes the provision of any goods, services or facilities at the event, for example the cost of hiring seating.

It includes the purchase of any equipment in connection with: 

  • holding or conducting a public meeting 
  • live streaming or broadcasting a public meeting by any means

Costs that are excluded

Reportable costs do not include the cost of providing specific security for any person appearing or attending at the event or the costs of providing general security for persons or property at the event.

Example

Example

If your organisation holds a members-only rally in a town square, or a march through a busy town centre, the event is open for any member of the public to see or join (even if only members of your organisation are taking part in the rally). The rally will count as a regulated campaign activity if it also meets the purpose test.

Similarly, if you hold a rally or event indoors, this will also be regulated if you have promoted the rally or event to any members of the public, for example, by promoting it through advertisements in the newspaper and leafleting, and it meets the purpose test.

However, if you hold a closed event for people who have signed up to volunteer for your campaign, where members of the public are unable to be involved or join, this will not be regulated.

If you provide security for attendees or property at an event, these costs will not count towards your spending limit.

What rallies and events are not regulated?

What rallies and events are not regulated?

Public rallies and events are not regulated if they are:

  • your organisation’s annual conference
  • a public procession or protest meeting in Northern Ireland, where notice has been given under the Public Processions (Northern Ireland) Act 199826
  • non-selective hustings, which are hustings that would not reasonably be regarded as intended to promote or oppose particular parties or categories of candidate
Last updated: 20 December 2023

The production or publication of material

Campaign material will only be regulated campaign activity if the material is made available to the public or any section of the public by the non-party campaigner.

Whether the material is publicly available is determined by who has access to that material:

  • Campaign material that is made available to the public or a section of the public
    • Campaign material that is made available for the public or a section of the public to hear or see will be public and will be regulated campaign activity if it also meets the purpose test and takes place during a regulated period. This applies regardless of the means by which the material is distributed.
  • Campaign material that is only made available to people who have chosen to receive the information
    • Campaign material that is only made available by the non-party campaigner to a closed group of members or people who have chosen to receive the information, will not be regulated.

Where access to campaign material is limited in such a way that the public would not be able to access that material, this is not regulated campaign activity. This applies regardless of the means by which the material is distributed, for example by print or digitally.

Where access to campaign material is restricted by the non-party campaigner to a group of people who have signed up to receive that material, those activities will not be regulated. For example, where access is restricted to members, or supporters, this will not be regulated.

Material restricted to specific people

Material restricted to specific people

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

Example

This could be campaign material in the form of a newsletter you send only to people who have signed up to receive updates from you, have joined your membership scheme or have donated to your campaign. You do not make this campaign material available anywhere else.

Websites and blogs

Websites and blogs

Website content, including blogs, will be considered made available to the public if there are no restrictions on who can access the content. It will be regulated if it:

  • contains content than can reasonably be regarded as intended to influence voters
  • is advertised (or otherwise promoted) to the public, or a section of the public, in connection with your campaign

Advertising or promoting can include:

  • giving the website address as a source for more information on other campaign material, or in other communications such as email updates
  • enhancing the website’s position in search engine result lists
  • placing links on other websites
  • organised viral marketing or similar activities

Example

You produce a graphic during the regulated period that you encourage your supporters to share on their social media accounts to bring attention to your organisation. The graphic includes a link to a public page on your website where people can find out more information about your campaign. You have assessed that both the graphic and the website meet the purpose test.

Both the website and the graphic have no restrictions on who can access them and are therefore considered made available to the public. As the material also meets the purpose test they will count as regulated campaign activities.

In contrast, if you put material on your website that is available only to people you send the link to, for example to those who have signed up to your email mailing list, this material will not be considered made available to the public. In this scenario the material will therefore not be a regulated campaign activity.

Social media

Social media

Campaign material published on social media that is available for anyone to view has been made available to the public. This includes campaign material naming or targeted at a particular section of the public, for example campaigns directed at residents of a particular area, or people who are members of specific groups or networks.

However, social media content that is restricted to a specific group of people and cannot be accessed by any member of the public, has not been made available to the public. For example, campaign material shared only on a closed Facebook group or private X (formerly Twitter) account would likely not be regulated for this reason.

To assess whether campaign material you make available to the public on social media will be regulated, you will need to consider whether it also meets the purpose test.

If spending on social media is available to the public, or a section of the public, and meets the purpose test, you must account for the cost of producing, updating and distributing this material. In many cases, the costs of posting material on a social media site, for example sending a tweet or updating a Facebook page, will be negligible.

Newspapers and periodicals

Newspapers and periodicals

The production or publication of any content – other than an advertisement – in a newspaper or periodical (including online versions of newspapers and periodicals) is not regulated campaign activity.1

However, if you advertise in a newspaper or periodical, the advertisement will be regulated if the advertisement is available to the public, or a section of the public, and meets the purpose test. An example of this would be an advertisement you place in a local newsletter encouraging the public to vote for a group of candidates.

Last updated: 20 December 2023

Case studies

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

Last updated: 24 November 2023

Activities that will not be regulated

In addition to the below, PPERA provides that reasonable expenses attributable to the protection of persons or property is not a regulated activity and will not count towards any spending limit.1 This includes, for example, hiring security or purchasing antivirus software for protecting campaign computers.

This exemption was introduced after the approval of the Code and does not form part of the Code of Practice. 

Activities that will not be regulated

PPERA specifically excludes the following expenses from the reporting requirements:

  • expenses incurred in respect of the publication of any matter relating to an election, other than an advertisement:
    • in a newspaper or periodical 
    • as a broadcast made by the British Broadcasting Corporation or by Sianel Pedwar Cymru or
    • as a programme included in any service licensed under Part 1 or 3 of the Broadcasting Act 1990 or Part 1 or 2 of the Broadcasting Act 1996 
  • expenses incurred in respect of, or in consequence of, the translation of anything from English into Welsh or from Welsh into English
  • reasonable personal expenses incurred by an individual in travelling or in providing for the individual's accommodation or other personal needs
  • reasonable expenses that are reasonably attributable to an individual's disability
  • expenses incurred in respect of the provision of an individual's own services provided voluntarily in the individual's own time and free of charge2

Translating material into or from Welsh

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.

Example

You produce a bilingual leaflet which contains Welsh and English versions of the same text and is therefore a few pages longer than if the leaflet was only produced in one language. 

The translator’s fee and the cost of designing, printing and posting the additional pages do not count towards your spending limit. Any other language translation costs will count towards your spending limits.

Personal expenses

Personal expenses

Reasonable expenses incurred by an individual on travelling, accommodation or other personal needs in relation to regulated campaign activities will not be regulated.

Example

If an individual travels to another city for the weekend to join your local campaign and pays these costs themselves, these costs will not count towards your spending limit.

However, if you reimburse an individual for their personal expenses, these expenses will be regulated campaign spending and must be reported.

Expenses incurred in relation to an individual’s disability

Expenses incurred in relation to an individual’s disability

Any additional support costs for disabled people who are working on any regulated activities, or for disabled people to access or take part in any regulated activities that you are organising, also do not count towards your spending limit.

Example

Producing a supply of Braille campaign leaflets to distribute to blind members of the public, or hiring adapted equipment so that disabled members of the public could take part in a public event.

Volunteer time

Volunteer time

You do not need to include the time volunteers spend on regulated campaign activity as regulated expenses. However, spending money on any resources that you provide for your volunteers to carry out regulated campaign activities will be covered. For example, if a minibus is hired to transport volunteers to carry out canvassing, the cost of the hire will count towards your spending limit.

Sometimes you may not be sure if someone is a volunteer or if their time should be treated as notional spending. For example, they may offer similar services professionally to the ones they are performing for you.

They are likely to be a volunteer if, for example, the time they spend on your campaign is not paid for by their employer (unless it is their usual annual leave). If they use specialist equipment or materials, you should consider whether their use is notional spending.

Party and candidate expenses

Party and candidate expenses

Spending that must be reported by a registered political party or candidate as election expenses should be reported only by that organisation or individual. It does not count towards your spending limit and must not be included in your spending return.3

Last updated: 27 March 2024

Notifications and registration

The following section covers submitting a notification to the Commission.

This includes:

  • when you need to submit a notification to us
  • which individuals and organisations can submit notifications
  • what details you need to provide in your notification
  • the responsibilities of the responsible person
  • what you need to do once you have submitted your notification
  • how long you remain on the register of notifications

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.

Last updated: 24 November 2023

When must you submit a notification to the Electoral Commission?

Non-party campaigners intending to spend more than £10,000 on regulated campaign activity must submit a notification to the Commission following which they will appear on the register of notifications.1  Only certain types of entities can submit a notification to the Commission.2

Once a non-party campaigner appears on the register of notifications, the Commission refers to them as a ‘registered non-party campaigner’.

When must you submit a notification to the Electoral Commission?

If you are eligible to submit a notification, you can submit a notification to the Electoral Commission at any time before or during a regulated period at a UK Parliamentary general election (UKPGE). 

Your notification must be in force before you spend more than £10,000 on regulated campaign activity during the regulated period. We call this limit the ‘notification threshold’.

The Commission maintains a register of notifications from non-party campaigners in the lead up to elections. Once a non-party campaigner is registered, we will publish details of their notification on our public register.3  We will not publish any personal information, such as home addresses, email addresses or phone numbers.

It is an offence to spend more than £10,000 without being on the register of notifications.4  If you are registered with us, you will have a different spending limit.

As well as the notification threshold, you must also ensure you do not exceed the constituency spending limit.

Last updated: 19 December 2023

Who can submit a notification?

Eligible non-party campaigners

Only individuals or organisations described in s.88(2) PPERA are eligible to submit a notification to the Commission.

Organisations are prohibited from registering as both a non-party campaigner and a political party.1

Who can submit a notification?

You should check carefully whether you are eligible to submit a notification.

Only the following individuals or organisations can submit a notification to 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 UK2

You should ensure you submit a notification 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 submit a notification as the entity that is doing the campaigning.

If you fall under one of these categories, and do not submit a notification, you cannot spend more than £10,000 on non-party campaigning at a UK Parliamentary general election.

Who cannot submit a notification?

Who cannot submit a notification?

You cannot submit a notification as an individual non-party campaigner if you are already the responsible person for a registered non-party campaigner.3

Under the Elections Act 2022, registered political parties are not eligible to submit a notification as a non-party campaigner. 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.4

Unincorporated associations with the requisite UK connection (unlike unincorporated associations that have their main office in the UK and carry on the majority of their business or activities in the UK) are able to spend more than £700 on regulated campaign activities but are not eligible to submit a notification to the Commission. This means an unincorporated association with the requisite UK connection cannot spend more than £10,000 on regulated campaign activity.5

If you do not fall into one of the above categories, and you are not an unincorporated association with the requisite UK connection, you can only spend up to £700 on regulated campaign activities.6

Last updated: 19 December 2023

How do you submit a notification?

You can submit a notification 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 notification, we will check that you are eligible to submit a notification, that all the necessary information is provided and confirm in writing when your notification is in force. In some cases, we may ask you to provide further information before we can process your notification.

As your notification must be in force before you spend more than £10,000 on regulated campaign activity during the regulated period, and to allow for time for the notification to be processed, you should wait until we confirm that your notification is in force before spending over this amount.

What information do you need to provide?

What information do you need to provide?

If you are making a notification as an individual, you must provide your name and home address.1

If you are making a notification 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 office2
  • the name of the ‘responsible person’3
  • the organisation’s ‘relevant details’4
  • the authorisation of the organisation’s secretary (or an individual acting in a similar capacity)5

For other organisations eligible to make a notification, you must provide:

  • the name of the organisation and the address of its registered or main office6
  • the name of the ‘responsible person’7
  • details of the organisation’s ‘relevant participators’8
  • the authorisation of the organisation’s secretary (or an individual acting in a similar capacity)9

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 notification. 

As part of your notification, 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 submitting a notification as a company, you will be asked to provide your company registration number and evidence that you are carrying on business in the UK.

Reporting threshold declaration

There are different spending, donation and reporting obligations for registered non-party campaigners depending on the declaration made in the notification.

As part of the changes introduced under the Elections Act 2022, when you submit a notification, you can declare that you intend to remain below the UKPGE reporting thresholds. These thresholds are spending more than £20,000 in England or £10,000 in any of Scotland, Wales or Northern Ireland.

If you make this declaration, and your spending remains below the reporting thresholds, you must still comply with the laws around the permissibility of donations but will be exempt from reporting obligations.

Please see Reporting thresholds for more information.

Last updated: 19 December 2023

Responsible person

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

Last updated: 19 December 2023

Relevant participators and relevant details

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

OrganisationRelevant participators1
Registered companyDirectors of the company
Trade unionOfficers of the trade union
Building societyDirectors of the society
Limited liability partnershipMembers of the limited liability partnership
Friendly societiesMembers of the society’s managing committee
Industrial and provident societiesMembers of the society’s managing committee or other directing body
Unincorporated associationsWhere the unincorporated association has more than 15 members and has officers or a governing body, those officers or members of the governing body. Otherwise, the body’s members.

Relevant details

OrganisationRelevant details2
Bodies incorporated by Royal CharterThe body’s officers or members of its governing body
Scottish partnershipsThe partners
UK charitable incorporated organisationThe charity trustees
Last updated: 20 December 2023

What do you need to do after your notification is in place?

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

After the election, you may need to provide us with a statement of accounts covering the regulated period.

In addition, if your spending meets the reporting thresholds, you must also:

  • report certain donations you receive for spending on regulated campaign activity before and after the election
  • report your spending on regulated campaign activity to us after the election

More information about donations and reporting requirements after the election 

Making changes

If you want to change any of your details, you can amend your notification at any time using Form TP2.1

Last updated: 19 December 2023

How long does your notification remain on the register?

You will remain on the register of non-party campaigners for 15 months from the date on which you delivered a notification to us.1  If your notification 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 notification to remain registered, you must send us Form TP3 no sooner than one month prior to the 12-month anniversary of your original notification 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 notification lapses, it remains your responsibility to submit a renewal notification within the deadline if you wish to remain registered.

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

Last updated: 19 December 2023

Reporting thresholds

Registered non-party campaigners who spend more than:

  • £20,000 in England, or
  • £10,000 in Scotland, Wales or Northern Ireland

must record and report their spending and donations.1  These are known as the reporting thresholds. They are defined as the ‘lower tier spending limits’ in PPERA.

Notifying the Commission

All non-party campaigners who submit a notification to the Commission are subject to the reporting requirements when their spending meets the reporting thresholds.

Non-party campaigners that meet the notification threshold but do not intend to spend more than the reporting thresholds, may, at the time of notification, submit a declaration to that effect.2

If no statement is made by the non-party campaigner at the time of notification, the non-party campaigner will be subject to the reporting requirements if they meet the reporting thresholds.3

Non-party campaigners taking part in a joint campaign may meet the reporting thresholds as a result of the rules on joint campaigning, without incurring spending directly themselves. See section on joint campaigning.

Non-party campaigners without the reporting threshold declaration

Non-party campaigners without the reporting threshold declaration

As a registered non-party campaigner, you can only accept donations over £500 from permissible sources and you are required to submit reports of your donations in the lead up to the election (pre-poll reporting). These donation requirements apply regardless of the amount you spend.

In addition, if you meet the reporting threshold in any part of the UK, you will be required to submit spending and donations after the election.

If your spending does not meet the reporting threshold in any part of the UK, you will be exempt from reporting spending and donations after the election. However, as a registered non-party campaigner, you will still be required to submit donation reports to us in the lead up to the election.

Non-party campaigners who have declared they intend to remain below the reporting thresholds

Non-party campaigners who have declared they intend to remain below the reporting thresholds

Non-party campaigners who have declared they intend to remain below the reporting thresholds

Registered non-party campaigners who include a declaration that they do not intend to spend more than the reporting thresholds are not required to report their spending or donations as long as their spending does not exceed the reporting thresholds. They are still subject to the law on permissibility of donations.

Non-party campaigners who have declared they intend to remain below the reporting thresholds

You will not need to report any spending or donations to us either in the pre-poll period or after the election, if both:

  • you declare you intend to remain below the UK Parliamentary general election (UKPGE) reporting thresholds in your notification
  • your spending remains below the reporting thresholds

You must still comply with the laws on donations and only accept donations over £500 from permissible sources, even if you are not required to report to us.

Your declaration will only remain in place if your spending remains below the reporting thresholds. If you spend over the reporting thresholds, you will no longer be exempt from the reporting requirements and must report your spending and donations to us. It is also an offence to spend over the reporting thresholds with the declaration in place.4

Removing the reporting threshold limitation

Removing the reporting threshold limitation

Removing the reporting threshold limitation

Once a non-party campaigner is registered, they may withdraw their statement that they do not intend to spend more than the reporting thresholds if their spending intentions change following registration.5

It is an offence to incur controlled expenditure in excess of the reporting thresholds if the non-party campaigner has notified the Commission that they would not spend more than those limits.6  Any non-party campaigner doing so would also become subject to the reporting requirements.7

Removing the reporting threshold limitation

If you wish to amend your notification to remove the spending limitation, you can amend your register entry at any time by submitting Form TP2.8  Your amendment must be in effect before you spend over the reporting thresholds.

We will inform you in writing when your notification has been amended.

Last updated: 19 December 2023

Examples

Example A: Regulated campaign spending below the reporting threshold

A registered non-party campaigner, Save the Trees, chose to include a declaration that they would not exceed the reporting threshold at UK Parliamentary general elections (UKPGEs) when they submitted their notification to register with us. 

During the regulated period for a UKPGE held after November 2023, they spent a total of £33,000 across England, Scotland and Wales on regulated campaign activities. Save the Trees spent £18,000 in England, £9,000 in Scotland and £6,000 in Wales on campaigning activities at the election. 

As a registered non-party campaigner, Save the Trees was required to:

  • ensure they complied with the laws on receiving and accepting permissible donations over £500 
  • ensure they did not spend more than the reporting threshold before withdrawing their declaration with the Commission (which, in this case, they did not need to do) 

As Save the Trees had a reporting threshold declaration in place and did not exceed the reporting threshold in any part of the UK, they did not need to submit quarterly or weekly pre-poll donation reports in the regulated period or report their spending and donations after the election.

Example B: Regulated campaign spending above the reporting threshold

Example B: Regulated campaign spending above the reporting threshold

Alex Smith, an individual who is on the electoral register, has a budget of £33,000 to spend at a UKPGE in December 2024. They intend to use this money supporting their parties of choice through political adverts and wish to spend £25,000 in England and £8,000 in Northern Ireland. 

As Alex intends to spend more than £10,000 in the UK, they must submit a notification to us before spending this amount. Their notification cannot include a reporting threshold declaration, as they intend to spend more than £20,000 in England, which is above the reporting threshold. Once their notification is in place, Alex will be subject to the requirements of registered non-party campaigners.

After Alex spends more than £20,000 in England, they will have spent more than the reporting threshold. As an overview, they must:

  • ensure they complied with the laws on receiving and accepting permissible donations over £500 
  • submit donation reports in the lead up to the election
  • keep records of spending and ensure this remains within the respective limits
  • report their spending and donations after the election
Last updated: 24 November 2023

Authorising and paying campaign spending

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

Incurring spending

For all registered non-party campaigners, only the ‘responsible person’ registered with us, and people authorised in writing by the responsible person can incur costs related to regulated campaign activities.1  By ‘incur’ we mean make a legal commitment to spend money, such as confirming an order.

Making payments for spending

There are additional restrictions on making payments for non-party campaigners that have either:

  • not declared that they will spend below the reporting thresholds in their notification
  • declared that they will spend below the reporting thresholds but have in fact spent above the thresholds.2

Only the responsible person registered with us, and people authorised in writing by the responsible person can incur costs and make payments for regulated campaign activities.3

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

All payments over £200 must be supported by an invoice or receipt.4

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.5

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.

Last updated: 19 December 2023

Spending limits

Under the Political Parties, Elections and Referendums Act 2000 (PPERA), there are limits on how much you can spend as a registered non-party campaigner during the regulated period for a UK Parliamentary general election (UKPGE).

There are limits on:

  • spending on regulated campaigning activity in each part of the UK
  • spending on regulated campaign activity in a particular parliamentary constituency

All regulated campaign spending must be attributed where it has an effect: to one or more parts of the UK and one or more constituencies. This means that all your spending will count towards a limit for a part of the UK and a constituency limit.

There is also a limit on spending on regulated campaign activity that can reasonably be regarded as intended to influence voters to vote for one particular registered political party or any of its candidates. This is called targeted spending.

The spending limits are as follows. Please note that we have rounded down these limits to the nearest pound for ease of use.

Limits on spending in each part of the UK

These limits are:1

Part of the UKSpending limit
England£586,548
Scotland£81,571
Wales£54,566
Northern Ireland£39,443

Spending on UK-wide campaigns

The combined total of the spending limits for each part of the UK is £762,130. However, because of the way these spending limits work, the maximum you can spend on purely UK-wide campaigns is £702,130. Any further UK-wide spending or spending in England would take you over the spending limit for England. 

You can only reach the combined total of the spending limits for each part of the UK if you have separate campaigns in Scotland, Wales and Northern Ireland where no additional spending needs to be attributed to England.

If you are planning substantial UK-wide campaigns and additional campaigning activity in England, please contact us for advice on how to apply the attribution rules to your campaigns.

Limits on spending in each constituency

During the regulated period for a UKPGE, a non-party campaigner cannot spend more than £17,553 on regulated campaign activity in a particular parliamentary constituency.2  This limit applies to all non-party campaigners, before you submit a notification, and while you are registered.

It is an offence to spend more than £17,553 in a constituency during the regulated period.3  If you spend more than the constituency limit while registered, you will be required to submit pre-poll donation reports and report your spending and donations after the election.

Limits on targeted spending

If the registered political party which you want to influence people to vote for does not authorise you to incur an amount of targeted campaign spending, you may only spend up to the following amounts (‘targeted spending limits’) on regulated campaign activity targeting a particular party during the regulated period:4

Part of the UKSpending limit
England£58,654
Scotland£6,157
Wales£3,456
Northern Ireland£1,944

Please see Targeted spending for more information.

Last updated: 30 January 2024

Attributing your spending

If you are a registered non-party campaigner, there are requirements in law on how your spending must be attributed to:

  • parliamentary constituencies
  • parts of the UK

We refer to these as the ‘attribution rules’. The purpose of the attribution rules is to assign your spending on regulated campaign activity to each part of the UK and each constituency in which it has an effect.

The spending attributed to each part of the UK counts towards the spending limit for that part. The spending attributed to each constituency counts towards the spending limit for that constituency. All spending will count towards the limits for at least one part of the UK and at least one constituency.

You should first identify where your spending has an effect. A campaign may be made up of multiple items of spending whose effect is limited to particular constituencies or parts of the UK. For example, a leafleting campaign across multiple constituencies where you know the amount spent on delivering leaflets in each constituency. Where possible, you should identify and split up items of spending whose effect is limited to separate areas.

You must then apply the attribution rules below.

Constituencies

You must split your spending equally between all constituencies in which it has an effect.1  For instance, you must attribute spending on a UK-wide campaign equally to each of the UK's 650 constituencies.

If you are campaigning across the whole of one part of the UK, you must attribute spending equally to each constituency in that part.2

If you spend the entire limit on constituency campaigning in a particular constituency, you will breach the constituency spending limit if you then incur any other regulated campaign activity that must be attributed to that constituency.

Parts of the UK

You must split your spending between the parts of the UK in which your spending has effect:

  • If your spending only has effect in one part of the UK, you must attribute it to that part.3
  • If your spending has effect in more than one part of the UK, you must attribute it to each part in proportion to how many constituencies there are in each part.4

The constituencies used are those that will be in place at the next general election. The number of constituencies in each part of the UK are as follows:

Part of UKNumber of constituencies5
England543
Scotland57
Wales32
Northern Ireland18
Total650
Last updated: 30 January 2024

Examples of attributing spending

Campaigning in one part of UK:

For example, you spend £35,000 on producing election material and distribute it throughout the whole of England.

Spending in each constituency

As the spending had an effect across the whole of England, you must attribute the spending to each of the 543 constituencies in England equally:1

£35,000 ÷ 543 = £64.46

You have spent £64.46 towards the constituency limit of £17,553 in each constituency in England.

Spending in each part of the UK

You must attribute the spending on the campaign to the part of the UK in which it had an effect. As this spending only had an effect in England, you have spent £35,000 towards the £586,548 limit on regulated spending in England.2

Campaigning across more than one part of the UK:

Example 1

For example, as part of a wider campaign, you hold an election rally in London and another rally in Edinburgh and spend £30,000 on each rally. Each rally focuses on encouraging voters to support a party in the English and Scottish context respectively and has been widely advertised all over that specific part.

Spending in each constituency

Although the rallies took place in a particular constituency, the spending has an effect across the whole of England and Scotland. Therefore, the spending on each rally must be attributed to all constituencies in that part of the UK. The spending must be attributed equally to each constituency it has an effect in:3

  • spending on the rally in London must be attributed equally across all 543 constituencies in England
  • spending on the rally in Edinburgh must be attributed equally across all 57 constituencies across Scotland

You must make the following calculations:

Share of spending attributed to each of 543 constituencies in England:

£30,000 (spending on the London rally) ÷ 543 = £55.25

Share of spending attributed to each of 57 constituencies in Scotland:

£30,000 (spending on the Edinburgh rally) ÷ 57 = £526.32

You have spent £55.25 towards the constituency limit of £17,553 for each constituency in England and £526.32 towards the constituency limit for each constituency in Scotland.

Spending in each part of the UK

The spending on each rally must be attributed to the part (or parts) of the UK it had an effect in. Although the rallies were part of a wider campaign, the London rally had an effect only in England, and the Edinburgh rally only had an effect in Scotland. Therefore, you must attribute the spending on each rally fully to England and Scotland respectively.4

Therefore, you have spent £30,000 towards the £586,548 limit on regulated campaign spending in England, and £30,000 towards the £81,571 limit on regulated campaign spending in Scotland.

Example 2

For example, you run a social media campaign costing £20,000 targeting voters in England and Wales. You cannot identify how much of the spending has an effect in England or Wales; you only have the total figure.

The spending has an effect across England and Wales and therefore must be attributed to both parts of the UK in proportion to the number of constituencies in each part and to all of the constituencies in England and Wales equally.5

As this is one campaign across more than one part of the UK, we calculate the amount that should be attributed to each constituency first before calculating the amount that can be attributed to each part of the UK.

Spending in each constituency

The spending has an effect in each of the 543 constituencies in England and 32 constituencies in Wales – 575 constituencies in total.

Share of spending attributed to each of 575 constituencies in England and Wales:

£20,000 ÷ 575 = £34.78

You have spent £34.78 towards the constituency limit (£17,553) in each of the constituencies in England and Wales.

Spending in each part of the UK

The spending must be attributed to each part of the UK it has an effect in, in proportion to the number of constituencies in each part.

You can do this using the following calculation:

Total spending × (number of constituencies in that part of the UK ÷ total number of constituencies the spending has an effect in)

Amount of spending attributed to England:

£20,000 × (543 ÷ 575) = £18,886.96

Amount of spending attributed to Wales:

£20,000 × (32 ÷ 575) = £1,113.04

You have spent £18,886.96 towards the £586,548 limit on regulated campaign spending in England, and £1,113.04 towards the £54,566 limit on regulated campaign spending in Wales.

Campaign across the whole of the UK:

For example, your organisation carries out a UK-wide campaign encouraging voters to support parties who are in favour of a particular policy. You spend £75,000 on producing and distributing election material on social media. 

Spending in each constituency

The spending has an effect across the whole of the UK. You must attribute the spending equally to each of the UK's 650 constituencies:6

£75,000 ÷ 650 = £115.38

You have spent £115.38 towards the £17,553 limit in each constituency.

Spending in each part of the UK

The spending must be attributed to each part of the UK in proportion to the number of constituencies in each part.7

You can do this using the following calculation:

Total spending × (number of constituencies in that part of the UK ÷ total number of constituencies the spending has an effect in)

In this example this is:

England share of the UK-wide campaign:

£75,000 × (543 ÷ 650) = £62,653.85

Scotland share of the UK-wide campaign:

£75,000 × (57 ÷ 650) = £6,576.92

Wales share of the UK-wide campaign:

£75,000 × (32 ÷ 650) = £3,692.31

Northern Ireland share of the UK-wide campaign:

£75,000 × (18 ÷ 650) = £2,076.92

The proportion of UK-wide campaigning attributed to each part will count against the spending limit for that part.

Campaigning in a single constituency:

If you are campaigning in a single constituency, it is likely that this will be local campaigning. This is campaigning for or against one or more candidates in a particular constituency, or other electoral area. If this applies to your campaign, you should read our guidance for local campaigners at UK Parliamentary general elections.

If you are campaigning for or against political parties or categories of candidates in a single constituency, you must attribute the regulated campaign spending that has an effect in that constituency to your constituency limit in this constituency. This spending will also count towards your spending limit in the part of the UK where the constituency sits.

Campaign across multiple constituencies in one part of the UK:

For example, you carry out a social media campaign targeting voters across 10 constituencies in Wales. You spend £5,000 on this campaign. You cannot identify spending that only has an effect in each constituency.

Spending in each constituency

The spending has an effect in 10 constituencies in Wales. You must attribute the spending on the campaign equally to each of the constituencies:8

£5,000 ÷ 10 = £500

You have spent £500 towards the constituency limit (£17,553) in each of the 10 targeted constituencies.

Spending in each part of the UK

You must attribute the spending on the campaign to the part of the UK in which it had an effect. As this spending only had an effect in Wales, you have spent £5,000 towards the £54,566 limit on regulated spending in Wales.9

Campaign across multiple constituencies in more than one part of the UK:

In most cases, for this type of campaign you will be able to identify spending either that has an effect in each part of the UK or in each constituency. 

For example, you carry out a campaign delivering leaflets in five constituencies, two in Wales and three in England. You spend £1,500 on 2,000 leaflets, of which you distribute half in Wales and half in England. Spending on leaflets distributed in Wales is £750 and in England is £750.

Spending in each constituency

The spending for the leaflets in Wales has an effect in two constituencies in Wales. You must attribute the spending on the campaign equally to each of the constituencies:10

£750 ÷ 2 = £375

The spending for the leaflets in England has an effect in three constituencies in England. You must attribute the spending on the campaign equally to each of the constituencies:

£750 ÷ 3 = £250

You have spent £375 towards the constituency limit (£17,553) in each of the constituencies in Wales and £250 towards the limits in each of the constituencies in England.

Spending in each part of the UK

You must attribute the spending on the campaign to the part of the UK in which it had an effect. The leaflets distributed in Wales only had an effect in Wales, and the leaflets distributed in England only had an effect in England. Therefore, you must attribute the spending for each set of leaflets to Wales and England, respectively.11

You have spent £750 towards the £54,566 limit on regulated campaign spending in Wales, and £750 towards the £586,548 limit on regulated campaign spending in England.

Last updated: 30 January 2024

Notional 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.

Last updated: 24 November 2023

What is notional spending?

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’.

What is notional spending?

You may incur notional spending in circumstances 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 to help you undertake regulated campaign activities, the value of what you use may count towards your spending limit and may be reportable in your spending return. Under the law, only transactions that meet certain criteria will be treated as notional spending.

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?

What spending is treated as notional spending?

What spending is treated as notional spending?

Items or services used by or on behalf of a non-party campaigner will be treated as notional spending if:

  • the property, services or facilities are provided free of charge or at a discount of more than 10% of the commercial rate for the use or benefit of the non-party campaigner, or in the case of the transfer of property it is transferred free of charge or a discount of more than 10% of market value1
  • the difference in value between the commercial rate and what is paid by the non-party campaigner is over £2002
  • they are made use of by or on behalf of the non-party campaigner and
  • if the expenses had been incurred by or on behalf of the non-party campaigner in respect of that use, they would have been controlled expenditure.3  

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

The non-party campaigner 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:

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

Donations

Donations

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.

Donations

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.

Last updated: 19 December 2023

Valuing and reporting notional spending

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 notional spending needs to be reported?

Where an item is treated as notional spending, an ‘appropriate amount’ must be reported by the non-party campaigner as controlled expenditure.

Where the notional spending is property transferred to the non-party campaigner, the appropriate amount is the proportion that is reasonably attributable to the use of the item, of either:

  • its market value (where it is transferred free of charge) or
  • the value of the discount.2

Where the notional spending is property, services or facilities used by the non-party campaigner, the appropriate amount is the proportion that is reasonably attributable to the use of the item, of either: 

  • the commercial rate (where is it provided free of charge) or 
  • the difference in value between the commercial rate for an item or service and the price that was actually paid by the non-party campaigner.3

Working with registered political parties

Non-party campaigners may also work with a registered political party, and provide property, services or facilities free of charge or at a non-commercial discount.

If the registered political party use the goods, services or facilities during their campaign, this must be treated as notional spending on behalf of the political party.4  This will also be treated as a donation by the non-party campaigner to the political party.5

It must be reported by the registered political party and will count towards the party’s spending limit.

It will not count towards the non-party campaigner’s spending limit and must not be recorded in the spending return for the non-party campaigner.

Last updated: 19 December 2023

Examples of notional spending

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)

Seconded staff

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

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

Last updated: 24 November 2023

Joint campaigning

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

Joint campaigning

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.

Last updated: 19 December 2023

What is joint campaigning?

A non-party campaigner takes part in joint campaigning where the following circumstances are all present:

  • they enter into a plan or other arrangement with one or more other non-party campaigners
  • all non-party campaigners involved intend to incur controlled expenditure in pursuance of that plan or arrangement
  • one or more of the non-party campaigners involved actually incurs controlled expenditure in pursuance of the plan or arrangement and
  • that plan or arrangement can reasonably be regarded as intending to achieve a common purpose.1

What is joint campaigning?

You cannot be incurring joint spending if you are not planning on spending money – for example if the work is going to be done by volunteers.

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 the course of 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.

Last updated: 19 December 2023

Key principles of joint campaigning

There must be more than one non-party campaigner

An existing umbrella organisation that makes decisions about their campaign activity independently will not be joint campaigning unless they enter into a plan or arrangement with other non-party campaigners in which they all intend to incur controlled expenditure, whether that expenditure is to be incurred by, or on behalf of, each non-party campaigner.

A new organisation set up to carry out campaign activity that constitutes a group of other organisations and then spending money is not joint campaigning.

There must be an agreed understanding that controlled expenditure will be incurred to achieve the common purpose

If there is no intention to incur expenditure there is no joint campaigning. For example, if it is agreed 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.

There must be an agreed understanding between the non-party campaigners that each of them will incur controlled expenditure to achieve the common purpose, whether that expenditure is to be incurred by, or on behalf, of the non-party campaigner in question

All controlled expenditure incurred in pursuance of the plan or arrangement will fall within the joint campaigning rules.

Joint campaigning is not simply

  • transferring or lending items to another campaigner or
  • providing money to another campaigner

This must be treated as notional spending or a donation and dealt with in accordance with the appropriate rules.

Even if one of the non-party campaigners involved in the plan or arrangement does not incur their share of agreed expenditure, any expenditure incurred will still be joint campaigning and must be reported by all non-party campaigners involved.

Any controlled expenditure incurred by a non-party campaigner that goes beyond or is incurred outside of the agreed plan or arrangement, is not part of the joint campaign but will still count towards the spending limit of the non-party campaigner incurring the expenditure.

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.

Activities that are joint campaigning

Activities that are joint campaigning

Activities that are joint campaigning

Non-party campaigners who engage in the following, non-exhaustive list of activities are likely to be joint campaigners:

  • a joint advertising campaign, whether digital, electronic or via other means, involving joint leaflets or joint events
  • a co-ordinated campaign; for example where it is agreed which areas are to be covered, which issues raised or which voters targeted
  • joint working where one party can veto or must approve another party’s material

Example

Example

Two organisations run similar campaigns calling for proportional representation in the UK Parliament. The first organisation’s campaign focuses on targeting swing voters in marginal constituencies and the second campaign aims to encourage the public to support only candidates and parties in who are in favour of adopting proportional representation in UK elections.

In the lead up to a UK Parliamentary general election, the two campaigners decide to launch a campaign together with the purpose of promoting parties in favour of proportional representation. For the purposes of this example, this planned campaign consists of regulated campaign activities. They each raise £1,000 with the intention of spending this money together on the campaign.

They plan the campaign by agreeing on five key goals and a timeline for the campaign, which consists of a social media campaign on both of their platforms and in-person events they run together. The teams behind the campaigns both agree on the content of the material before it is published.

Activities that are not joint campaigning

Activities that are not joint campaigning

Activities that are not joint campaigning

Non-party campaigners who engage in the following, non-exhaustive list of activities are unlikely to be joint campaigners:

  • endorsing another campaign by allowing your logo/brand to be used without any financial commitment or further involvement
  • adding your signature to a letter alongside other non-party campaigners without any financial commitment
  • speaking freely at an event organised by another non-party campaigner without any financial commitment
  • holding discussions about areas of common interest without coordinating campaign activity
  • making a donation to another non-party campaigner is not joint campaigning. See sections on notional spending and donations.

Examples

Example A

Two organisations run similar campaigns calling for proportional representation in the UK Parliament. The aim of both organisations is to encourage political parties to adopt proportional representation.

The first organisation sets up a petition in which they ask people to add their name to call on the UK Parliament to adopt proportional representation. They ask the second organisation to sign the petition and share it with their supporters. After the petition is closed, they also ask the second organisation to add their name to an open letter they place in newspapers which calls on voters to support parties in favour of alternative voting systems at the upcoming general election.

In this scenario, although the open letter is regulated activity, the organisations have not entered into a plan or arrangement together and there is no intention for both campaigners to incur spending. Therefore, this is not joint campaigning.

Example B

Two organisations run similar campaigns calling for proportional representation in the UK Parliament. The first organisation’s campaign focuses on targeting swing voters in marginal constituencies and the second campaign aims to increase public awareness of the benefits of proportional representation.

After a by-election is called in a marginal constituency, the first organisation organises events in the constituency to reach voters. They ask the second organisation to talk at one of the events and publicise the events on their social media. There is no financial commitment between the organisations or any co-ordinated spending. This is not joint campaigning.

Example C

Two organisations run similar campaigns calling for the government to adopt particular policies on climate change. The first organisation calls on voters to vote for parties who have committed to the issues they have identified, and the organisation asks the second organisation to share their material and promote their campaign on X/Twitter and other social media accounts. The second organisation agrees to publicise the first organisation’s work but does not carry out any co-ordinated spending or any regulated campaigning themselves.

In this scenario, the first organisation is carrying out regulated campaign activities by influencing voters to vote in a particular way at the election. The second organisation must assess whether they have spent any money on regulated campaign activities. Even though the second organisation has shared the first organisation’s election material to their followers, the organisations have not entered into a plan or arrangement to incur spending on regulated campaigning together. Therefore, this is not joint campaigning.

Example D

An organisation runs a campaign encouraging voters to vote for parties who have pledged to introduce laws to protect tenants. They identify campaigners and a charity with shared aims and promote these organisations to their supporters and publicly on their social media accounts. They also make a donation to one of the other campaigners that is supporting tenants.

In this scenario, the organisation is carrying out regulated campaign activities by influencing voters to vote in a particular way at the election. Even if the other organisations they have promoted also spend money on regulated campaign activities, there is no financial commitment or co-ordinated spending between any of the campaigners.

In addition, a donation does not mean campaigners are working (or spending money) together. Each organisation would be required to individually assess whether they are spending money on any regulated campaign activities. Therefore, this is not joint campaigning.

Last updated: 15 May 2024

Establishing a new organisation

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 submit a notification to the Electoral Commission? for more information.

Last updated: 19 December 2023

Your joint campaign – spending and reporting

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.

Last updated: 24 November 2023

Ordinary joint campaigns

Where there is a joint campaign, all of the spending on that joint campaign counts towards the spending limit of each of the non-party campaigners involved in the joint campaign.

Ordinary joint campaigns

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 submit a notification to the Electoral Commission.

If you do not submit a notification, 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 and you spend more than the reporting thresholds, 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.

Example

You and another non-party campaigner each agree to spend £8,000 on an ordinary joint campaign in Scotland. The total spending for the joint campaign is therefore £16,000. 

Both of you must count £16,000 towards your regulated spending total. 

Since this total is over £10,000, which is both the notification threshold UK-wide and the reporting threshold in Scotland, you and the other campaigner must submit notifications to the Commission before spending over this amount. As you are planning on spending over the reporting threshold, the notifications cannot include the reporting threshold declaration.

Each campaigner must report their own spending in their spending return. They should also report a total of their joint campaign partner’s spend.

Last updated: 24 November 2023

Lead and minor campaigners

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

Where a group of campaigners jointly spend over the notification threshold but some of those campaigners do not reach the notification threshold, the lead/minor campaigner laws allow one campaigner, the lead campaigner, to submit a notification to the Commission and report all of the spending on the joint campaign. The minor campaigners do not have to submit a notification.

Spending by lead and minor campaigners

Spending by lead and minor campaigners

Spending by lead and minor campaigners

All spending on the joint campaign, whether by the lead campaigner or the minor campaigner(s) will count towards the lead campaigner’s spending limit during the regulated period.3

Spending by lead and minor campaigners

If you are a lead campaigner, your spending and any spending incurred by your minor campaigners as part of the joint campaign will count towards your spending limit during the regulated period. We call minor campaigners who have agreed to you reporting on their behalf ‘your minor campaigners’.

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

If you are a minor campaigner, then none of the spending on the lead/minor joint campaign counts towards your spending total. This applies to: 

  • your own spending on the joint campaign
  • the lead campaigner’s spending on the joint campaign
  • any other minor campaigner’s spending on the joint campaign

Therefore, for your own spending total, you only need to count:

  • your own spending outside of any joint campaign 
  • any spending by your partners in an ordinary joint campaign

Spending by lead and minor campaigners

For the purpose of determining whether a minor campaigner meets the notification or reporting threshold, spending on the joint campaign must not be included when determining the limits if:

  • the spending is part of a joint campaign that has been notified to the Commission (in which case the minor campaigners’ spending on the joint campaign will be treated as incurred by the lead campaigner and will count towards the lead campaigner’s spending limit), and
  • the non-party campaigner is a minor campaigner at the time of incurring the spending, and
  • the total amount of spending by the non-party campaigner, excluding any spending on the joint campaign, is less than the reporting thresholds4

Reporting by lead and minor campaigners

This allows minor campaigners to remain unregistered, even in situations where the total joint campaign spend is over the notification threshold.

Reporting by lead and minor campaigners

If you are a lead campaigner, you must report:

  • your own spending on the joint campaign 
  • any spending on the joint campaign by your minor campaigners 
  • any other regulated spending you incurred separate from the joint campaign. 

Your spending return must also include receipts or invoices for any spending over £200 incurred by you and your minor campaigners.5

This means you should ask all your minor campaigners:

  • to let you know how much they have spent on the joint campaign in each part of the UK
  • to provide you with receipts and invoices for any spending over £200 on the joint campaign

If you are a minor campaigner, and you spend up to £10,000 (the notification threshold), and the constituency limit, on regulated campaign activities unconnected with the joint campaign during the regulated period, you do not have to submit a notification or report any of your spending.

The lead campaigner is responsible for reporting your spending on joint campaigning to us. To enable the lead campaigner to fully report the joint campaigning, you should:

  • agree with all other non-party campaigners involved in the joint campaign how much you can spend
  • tell your lead campaigner how much you have spent in each part of the UK
  • tell your lead campaigner how much you have spent in each constituency
  • provide receipts and invoices for regulated campaign spending over £200 to your lead campaigner

Example

Save the Rivers and three other campaigners decide to work together as part of a joint campaign in Wales. They have all agreed that they will each spend £9,000 on the joint campaign. Save the Rivers also plans on spending an additional £5,000 on regulated campaign activities unconnected to the joint campaign. The three other campaigners do not spend any other money on regulated campaign activities.

The reporting threshold for spending in Wales is £10,000. Since the total spend on the joint campaign will be £36,000 (which is over the reporting threshold), if this campaign is run as an ordinary joint campaign then all four campaigners will have to register and report the spending individually.

As Save the Rivers is planning to spend the most money on campaigning, and to lessen the regulatory burden on the other three campaigners, they decide to become the lead campaigner. Before any spending is incurred, they submit a notification without a reporting threshold declaration. Save the Rivers do not make the reporting threshold declaration with their notification because their intended regulated spend total (£41,000 comprised of the total spend on the joint campaign of £36,000, plus their own regulated campaign spending of £5,000) is above the reporting threshold.

Save the Rivers also notifies the Commission that they are the lead campaigner, and that the three other campaigners are minor campaigners in the joint campaign.

As the three other campaigners have been notified as minor campaigners, and outside of the joint campaign they have not exceeded the notification threshold (£10,000) or the constituency limit, they do not need to submit a notification to us or report their spending on the joint campaign.

As the lead campaigner, Save the Rivers must report spending of £36,000, which is the total of their spending and the three minor campaigners’ spending on the joint campaign after the election. They must also report the additional £5,000 they spend outside of the joint campaign.

The three minor campaigners provide details of the spending alongside receipts and invoices for any spending they incurred over £200 to Save the Rivers so they can include this in the return.

Last updated: 20 December 2023

How to become a lead campaigner or a minor campaigner

A non-party campaigner involved in a joint campaign who agrees to report all of the joint campaign spending must:

  • notify the Commission that they are part of a joint campaign, and they will be the lead campaigner, and
  • inform the Commission of the minor campaigners involved in the joint campaign.

A non-party campaigner may notify the Commission of their lead campaigner status, or the involvement of minor campaigners, at any time before the end of the regulated period.1

How to become a lead campaigner or a minor campaigner

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 submits a notification (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.

Last updated: 19 December 2023

Targeted spending

Under the law, there are restrictions on how much registered non-party campaigners can spend in support of one particular political party or its candidates during a UK Parliamentary general election (UKPGE) regulated period. This is called ‘targeted spending’.

This section provides guidance on:

  • what spending counts as targeted spending 
  • how much you can spend on targeted spending
  • authorising and withdrawing authorisation for targeted spending
  • reporting targeted spending
Last updated: 24 November 2023

Targeted spending

Regulated campaign spending by all registered non-party campaigners during the regulated period for a UKPGE that is aimed at promoting the electoral success of one particular registered political party or any of its candidates is called targeted spending.1

Targeted spending will count towards the overall spending limit for a non-party campaigner and is subject to the general laws on regulated campaign activity.

What is targeted spending?

What is targeted spending?

What is targeted spending?

Spending on campaign activity will not be considered targeted spending unless the campaign identifies the political party or its candidates.

  • Campaign activity that names a single political party or its candidates in a way that can be reasonably regarded as intended to influence voters to vote for only that political party or its candidates will count as targeted spending.
  • Campaign activity that identifies a single political party or its candidates in such a way that it can be reasonably regarded as intended to influence voters to vote for only that political party or its candidates, will be considered targeted spending. This could be by using a campaign slogan, party logo, or a policy so synonymous with only one political party.

What is targeted spending?

To count as targeted spending, spending must reasonably be regarded as intending to influence voters to vote for only one political party or any of its candidates. It will not be targeted spending if it is also intended to influence voters to vote for any other party or any of its candidates.

What does not count as targeted spending?

What does not count as targeted spending?

What does not count as targeted spending?

A negative campaign aimed at influencing voters not to vote for a particular political party or any of its candidates is not targeted spending.

Donations to a registered political party do not fall within the definition of targeted spending.

Last updated: 19 December 2023

Limits on targeted spending

The amount you can spend on targeted spending depends on your arrangement with the political party. 

Spending not authorised by the political party

Under the law, the limits for unauthorised targeted spending are calculated proportionally to the spending limits at each UK Parliamentary general election (UKPGE). There are different limits for targeted spending incurred in each part of the UK.1

Part of the UKSpending limit
England£58,654  
Scotland£6,157  
Wales£3,456  
Northern Ireland£1,944  

If you are not authorised to incur targeted spending, all of your targeted spending will count towards your regulated campaign spending total and must be reported in your spending return. 

Spending not authorised by the political party

Any spending in excess of the targeted spending limits must be authorised by the relevant registered political party.

Spending not authorised by the political party

You must not spend over the legal limits on unauthorised targeted spending without authorisation from the party. The unauthorised targeted spending you incur must also not exceed the limit on how much you can spend in each part of the UK, or the constituency limit. Please see Spending limits for more information on your overall spending limits.

Spending not authorised by the political party

It is an offence for non-party campaigners to spend in excess of the targeted spending limit without authorisation from the relevant registered political party.2

Spending that is authorised by the political party

Spending that is authorised by the political party

While you can incur targeted spending without authorisation, registered parties can authorise you to spend up to an amount they specify on targeted spending.

If targeted spending has not been authorised, the spending must stay within the legal limits on unauthorised targeted spending set out above. With authorisation from the party, you may instead spend up to the amount they authorise.

Spending that is authorised by the political party

Any targeted spending in excess of the targeted spending limit up to the amount authorised by the relevant political party will also count towards the registered political party’s campaign expenditure.3

Spending that is authorised by the political party

Spending you incur above the targeted spending limits up to the authorised amount is treated as if it was incurred by you and the political party. For this reason, this spending will count towards both your spending limit and the party’s spending limit at the election and must be reported in both of your spending returns.

Any targeted spending you incur must not exceed the limit on how much you can spend in each part of the UK, or the constituency limit. These limits apply to all your spending on regulated campaign activities, even if the amount a party has authorised you to spend is more than these limits. Please see Spending limits for more information on your overall spending limits.

Spending that is authorised by the political party

It is an offence for non-party campaigners to spend in excess of the amount authorised by the relevant registered political party.4

Last updated: 23 January 2024

How to authorise targeted spending

If a political party wishes to authorise you to incur targeted spending up to a set limit, it must provide an authorisation to us.

How to authorise targeted spending

Authorisation by a registered political party:

  • must be in writing
  • must be signed by either the treasurer or the deputy treasurer of the party
  • must specify the parts of the UK in which the targeted spending may be incurred 
  • may set a limit on the amount of targeted spending authorised.1

The registered political party must give a copy of the written authorisation to the Commission. The authorisation has no effect until a copy has been given to the Commission.2

How to authorise targeted spending

An authorisation by a political party can be made using form TP5.

 

The political party should also give a copy of the authorisation to you confirming that you can incur targeted spending.

If a political party gives you a copy of an authorisation to incur targeted spending, you should ask for confirmation that they have sent the original authorisation to us. You can check this by looking at our register of notifications.

Withdrawal of authorisation

Withdrawal of authorisation

A political party can withdraw an authorisation at any time by giving us notice in writing.

Withdrawal of authorisation

The withdrawal:

  • must be in writing
  • must be signed by the treasurer or deputy treasurer of the party.3

The withdrawal of authorisation has no effect until the registered political party has given a copy to the Commission.4

Withdrawal of authorisation

The political party should also give a copy of the withdrawal notice to you confirming that you cannot incur any further targeted spending. The withdrawal notice takes effect on the date it is received by the Electoral Commission.

If the party withdraws its authorisation, you must not incur any further targeted spending above the targeted spending limit. You should make sure that the political party keeps you informed of any changes to the authorisation.

If you have already spent more than the targeted spending limit when the authorisation is withdrawn, you must stop all further targeted spending.

Withdrawal of authorisation

When authorisation is withdrawn, no retrospective offence will have been committed by the non-party campaigner in relation to targeted spending incurred in accordance with the authorisation that was in effect at the time.

Last updated: 19 December 2023

Reporting authorised spending

If a political party authorises you to incur targeted spending:

  • you should keep a record of the total of the targeted spending
  • all targeted spending incurred by you will count towards your total campaign spending and must be reported in your spending return
  • any amount of targeted spending over the targeted spending limit and up to the amount specified in the political party’s authorisation will also count towards the party’s campaign expenditure and must be reported in the political party’s spending return
  • the political party must declare how much you have spent on targeted spending and how much they have authorised you to incur
Last updated: 24 November 2023

Apportioning spending

You may need to apportion the costs of some items of spending, so that you can record and report the value spent on your regulated campaign activities correctly. Sometimes we call this splitting spending.

This may include:

  • spending on activities before the start of the regulated period
  • items and services used before the regulated period begins and during the regulated period
  • activities which count as regulated campaign spending and those that don’t

The honest assessment principle

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.

You should apply the guiding principle to all situations where you need to apportion campaign spending.

This will be straightforward for many items. However, for some it will be more complicated. The examples in this section should help you understand how you should approach your assessment.

Last updated: 24 November 2023

Spending during and outside of the regulated period

Apportioning spending

Where spending on an item or activity was incurred partly in connection with regulated campaign activity and partly in connection with non-regulated activity, the amount that must be reported is the proportion that reasonably reflects the amount spent in connection with the regulated campaign activity.

Only the regulated campaign spending must be reported in the spending return.

Spending during and outside of the regulated period

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 during the regulated period are reportable and will count towards your spending limit.

Example A: Canvassing during and after the regulated period

You carry out canvassing two months before the regulated period and two months after the regulated period. Only the costs associated with the canvassing you undertake during the regulated period will count as regulated campaign spending. 

As you spent an equal amount of time canvassing, to find out the cost you need to report, you should divide the total spending on canvassing over this period in half. You must include the costs associated with canvassing during the regulated period in your spending return.

Example B: Website costs before and during the regulated period

Before the regulated period begins, you create an area of your organisation’s website that can reasonably be regarded as intended to influence voters to vote for parties who do not support a proposed local development. You continue to use and update it during the regulated period. 

As only the spending incurred during the regulated period is reportable, you will need to apportion the costs of the design, web hosting and other relevant costs between the two periods.

If the design and other costs amount to £9,000, and you use it over a six-month period, the cost per month is £9,000 ÷ 6 = £1,500 a month. 

If the regulated period covers the final 4 months, then the total costs during the regulated period is 4 × £1,500 = £6,000. 

Last updated: 20 December 2023

Use of items

If you purchase items or services before the regulated period, and use these during the regulated period, the spending will count as regulated campaign activity.

Use of items

Re-using items paid for and used at a previous election

Non-party campaigners may re-use items from previous elections. Spending on items that were paid for and used at a previous election and were reported in full in a previous spending return do not need to be reported again in the spending return for the same non-party campaigner at the current election if they are used again without alteration. All new costs relating to their re-use, including storage, cleaning, or the cost of altering the items must appear in the spending return.

Apportionment of items for subsequent elections

Items that have been paid for and used during a regulated period cannot be apportioned or reported solely on the basis that they will be used again during a subsequent regulated period. The full value of the spending must be reported in the spending return.

Unused items

Items that have been paid for by a non-party campaigner, but have not been used during the regulated period, do not need to be reported in the spending return.

If those items are then used at a future election, the spending would need to be reported in relation to that election, as an item paid for prior to the commencement of the regulated period.

Items paid for prior to the commencement of the regulated period

Where spending was incurred prior to the start of a regulated period on items that are used during the regulated period, the spending on those items must be reported in the spending return.1

Example

Example

If you hire an agency to create posters and digital adverts for an upcoming UK Parliamentary general election (UKPGE), which you then publish during the regulated period, the associated costs of this service must be reported.

Last updated: 19 December 2023

VAT, overheads, and staff costs

VAT

Spending must be reported inclusive of VAT where applicable, even where VAT can be recovered.

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

The Commission considers that the cost of water, gas and council tax are not costs that need to be reported as they are not sufficiently closely connected to the regulated activity.

Example

Example

During the regulated period a campaigner purchases additional computers, office equipment and phones to support their team with producing campaign material and canvassing. With these purchases, the campaigner’s electricity and internet bills increase beyond their normal spending.

As the spending on overheads has increased beyond the normal spending of the campaigner as a result of regulated campaign activities, these overheads costs will be regulated.
 

Staff costs

Staff costs

Staff costs that are directly attributable to regulated activity must be reported. Only staff costs that are incurred as a result of regulated campaign activity need to be reported.

Where staff costs can only be partially attributed to regulated activity, the costs must be apportioned and only the portion attributed to regulated activity must be included in the spending return.

Where an apportionment of a staff member’s time is necessary, an aggregated figure for all staff time attributed to regulated activity is sufficient to meet the reporting obligations.

The Commission considers that the childcare costs of staff members are not expenses that need to be reported as they are not sufficiently closely connected to the regulated activity.1

Example

If you have a member of staff working on regulated campaign activity as well as on unregulated activities, you will need to count a proportion of the staff salary which reflects the time spent working on regulated campaign activities.

Example

A staff member is working on your organisation’s election campaign at the same time as your day-to-day business.

If your organisation already has an established way of apportioning these costs for other work, you may decide to calculate staff costs incurred in relation to regulated campaign activities in the same way. 

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

To help you plan your spending, you and the staff member should agree a reasonable estimate of the time they are likely to spend on regulated campaign activities. You should ask the staff member to keep track of the time actually spent on regulated campaign activity and update you if they spend a significantly longer time than originally agreed. This should help you ensure that you do not breach the spending limit. 
 

Last updated: 21 March 2024

Donations

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
Last updated: 24 November 2023

What is a donation?

All registered non-party campaigners must comply with the donation controls in Schedule 11 PPERA that set out who can donate to non-party campaigners.

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?

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 before and during 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.

Certain registered non-party campaigners must also report certain donations to the Electoral Commission. We publish details of these donations on our public register. These details do not include the addresses of individuals who donate.

Last updated: 19 December 2023

Which donations are not covered by the law?

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

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.

Last updated: 20 December 2023

What do you need to do when you receive a donation?

When a non-party campaigner receives a donation of more than £500, they must promptly check whether the donation is from a permissible source. 

Where a donation is received via an agent, the non-party campaigner must be able to identify the identity of the true donor.1  The agent must provide details of the true donor.2

Donations from impermissible or unidentified donors must be returned within 30 days of receipt of the donation.3  Non-party campaigners must keep records of the donations that are received, as well as donations that have been returned. These details must be included when the donation is reported to the Commission.

Checks on donations

Checks on donations

Donations can only be accepted from certain sources, which are mainly UK-based . 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 source4

How long do you have to check permissibility?

When you receive a donation, you have 30 days to conduct permissibility checks 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.

Last updated: 19 December 2023

Donations on behalf of others and from unidentified sources

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.

Last updated: 19 December 2023

When do you receive and accept 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

Last updated: 19 December 2023

Who can you accept donations from?

Non-party campaigners can only accept donations from individuals or organisations that are based in the UK.1  The list of permissible sources is set out in s.54(2) PPERA.

Non-party campaigners must not accept donations from a registered political party.2

Who can you accept donations from?

A permissible source is:

  • an individual registered on a UK electoral register, including overseas electors and those leaving bequests 
  • a UK-registered company which is incorporated in the UK and carries on business within the UK 
  • a UK-registered trade union 
  • a UK-registered building society 
  • a UK-registered limited liability partnership (LLP) that carries on business in the UK 
  • a UK-registered friendly, industrial or provident society
  • a UK unincorporated association that is based and carries on business or other activities in the UK

You can also accept donations from some types of trusts.3  Please contact us for advice on how to confirm the permissibility of trusts.

You must not accept donations from a political party.4

Although you can legally accept donations from charities as long as they are permissible donors under electoral law, charities are not usually allowed to make political donations under charity law. 

If you know that a potential donor is a charity, you should make sure that they get advice from the Charity Commission for England and Wales, Office of the Scottish Charity Regulator or the Northern Ireland Charity Commission before they make the donation.

What must you record?

If you accept a donation over £500, you must record these details: 

  • the required details for the type of donor 5 (these are set out on the following pages)
  • the amount of the donation (if monetary) or nature and value (if non-monetary)6
  • the date on which you received the donation
  • the date on which you accepted the donation7

You must record the donor’s address as it is shown on the relevant statutory register.

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

Last updated: 19 December 2023

Individuals

What makes an individual permissible?

Individuals must be on a UK electoral register at the time of the donation.1  This includes overseas electors. 

If you are left a bequest, and the individual was on the electoral register at any time five years before their death, you can accept the donation.2

How do you check permissibility?

You can use the electoral register to check if an individual is permissible. Registered non-party campaigners are entitled to a free copy of the full electoral register.

A new version of the electoral register is usually published on 1 December every year, and it is updated regularly. 

You should contact the Electoral Registration Officer at the relevant local council in writing for your copy, explaining that you are asking for it as a registered non-party campaigner.3  You should also ask them to send you all the updates.

You will receive the register in electronic form unless you request a printed version of the register.4

You can find contact details for local councils through our postcode search.

You must check the register and updates carefully to make sure that the person is on the register on the date you received the donation. 

In special circumstances, people have an anonymous registration. If the individual is anonymously registered, you must provide a statement that you have seen evidence that they have an anonymous entry on the register.5  Evidence will be in the form of a certificate of anonymous registration. You must submit a copy of the certificate with your report.6

You must only use the register for checking if an individual is permissible, or for electoral purposes. You must not pass it on to anyone else.7

What do you need to record? 

You must record: 

  • the individual’s full name  
  • the address as it is shown on the electoral register, or if the person is an overseas elector, their home address8

You may find it helpful to note the person’s electoral number, as a record of your check.

If you have received a bequest, please contact us for advice on checking permissibility and the reporting requirements.

Last updated: 19 December 2023

Companies

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, using the free Webcheck service. 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
Last updated: 19 December 2023

Limited liability partnerships

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, using the free Webcheck.

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.

Last updated: 19 December 2023

Unincorporated associations

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

Unincorporated associations that are permissible donors are not the same as unincorporated associations with the requisite UK connection. An unincorporated association with the requisite UK connection will only be a permissible donor if it also meets the permissibility requirements.

How do you check permissibility?

There is no register of unincorporated associations. Permissibility is a matter of fact 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. 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 address2
Last updated: 15 February 2024

Other sources

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
Last updated: 19 December 2023

How do you value a donation?

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 for the purposes of PPERA.

When a non-party campaigner receives a donation of more than £500, they must promptly check whether the donation is from a permissible source. 

How do you work out the value of 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.

Last updated: 19 December 2023

Goods and services received or provided by your organisation

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.

Last updated: 19 December 2023

Crowdfunding

What is crowdfunding?

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. At the end of that time, the funds raised, minus a fee paid to the provider, are passed to the donee.

Transparency

You should ensure that it is clear on the crowdfunding web page who the money is being donated to and what the money is being donated for. The webpage should also contain information that explains that permissibility checks will be undertaken in compliance with the rules and that information about donations, including donor details, may be published by the Commission.

We also recommend that you include an imprint on your crowdfunding page. There is separate imprints guidance for non-party campaigners in Northern Ireland, England and Wales and in Scotland.

Permissibility

You must only accept donations over £500 from a permissible source.

As with all types of donations, you have 30 days to carry out permissibility checks and decide if you can accept the donation. The date of receipt is the date you receive the funds from the crowdfunding site.

Money donated via a crowdfunding webpage to a non-party campaigner that is £500 or less is not a donation under the Political Parties, Elections and Referendums Act 2000 (PPERA) and is not reportable.

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

You should ensure that you have sufficient information from the crowdfunding provider and maintain your records in a way that enables you to ascertain if multiple donations have come from the same source.

You must collect sufficient information from every donor to ensure that you can properly check that each donation is from a permissible source. You should be clear on the webpage that this is the reason you are collecting any information. If you are uncertain who the actual donor is, you must not accept the donation. You cannot accept anonymous donations of over £500.

You must also collect sufficient information to comply with reporting requirements.

Cryptocurrencies

Cryptocurrencies are digital currencies that operate independently of any central bank or authority.

The same rules apply to donations received in cryptocurrencies as any other donations. Sufficient information must be collected to check permissibility. There must be a means of valuing the donation given in any cryptocurrency.

Last updated: 19 December 2023

Valuing a donation by sponsorship

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).

Last updated: 19 December 2023

How much of what you receive is a donation?

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.

Treatment of VAT

Where a sponsorship payment includes VAT, the question of whether the VAT element should be reported as part of the sponsorship will depend on the facts. For instance, if the party would have been liable for the VAT if it had not been paid, then its payment is a benefit to the party and should be reported as sponsorship.

Sponsorship by companies

Where a company makes a payment that is treated as sponsorship, the entire amount is considered a donation under electoral law.

Companies will therefore need to ensure that they have complied with any applicable controls on making a political donation under company law.

Last updated: 24 November 2023

What do you do if you receive a donation from an impermissible or unidentifiable source?

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.

Last updated: 19 March 2024

When do you report donations?

Certain non-party campaigners must report donations both in the run-up to a UK Parliamentary general election, which we call ‘pre-poll reporting’, and after the election in the spending and donations return.

Registered non-party campaigners (unless they have declared that they will spend below the reporting thresholds) are required to report donations at three different times:

There are different reporting requirements in each type of report.

The following pages provide details on the different types of donation report and the respective requirements.

Last updated: 6 February 2024

Pre-dissolution period: Quarterly pre-poll reports

When a UK parliamentary term reaches its fourth anniversary, registered non-party campaigners who meet the reporting threshold, must submit quarterly donation reports to the Commission.1

The quarterly report must include details of all reportable donations. If a non-party campaigner has not received any reportable donations during the relevant reporting period, no quarterly report is required.2

Pre-dissolution period: Quarterly pre-poll reports

Under the law, some registered non-party campaigners must report certain donations they have accepted or returned on a quarterly basis (every three months) during the pre-dissolution period. This is called ‘quarterly pre-poll reporting’.

Which non-party campaigners are required to submit quarterly pre-poll reports?

Registered non-party campaigners, unless they have declared they will spend below the reporting thresholds, are required to submit quarterly pre-poll reports.3  With this declaration, you will remain exempt if your spending remains below the reporting threshold.4

If you do not receive any reportable donations during a reporting period, you do not need to submit a report for that quarter.5

When is the pre-dissolution period?

Dissolution is the official term for the end of a UK Parliament. When the UK Parliament is dissolved, every seat in the House of Commons becomes vacant until after the general election.

The pre-dissolution period begins on the fourth anniversary of a UK parliamentary term and ends the day before Parliament is dissolved.6  The fourth anniversary of the current parliamentary term will be 17 December 2023.

The duration of the pre-dissolution period depends on the date Parliament is scheduled to be dissolved. Under the Dissolution and Calling of Parliament Act 2022, if it is not dissolved earlier, the UK Parliament will dissolve automatically on the fifth anniversary of a parliamentary term.7  The pre-dissolution period can therefore last up to a year.

If Parliament is dissolved before the fourth anniversary of a parliamentary term, there will be no pre-dissolution period and no quarterly reporting requirements for that election.

What donations must you report?

The donations that are reportable in each quarterly report are:

  • all donations from impermissible or unidentifiable donors dealt with during the reporting period8
  • where there are no donations accepted from the donor that were reportable in a previous quarterly report:9
    • all donations accepted with a value of more than £7,500 during the reporting period10  
    • all donations accepted from the same donor during the pre-dissolution period that add up to more than £7,500 (aggregated donations)11
  • where the donor has made a donation that was reportable in a previous quarterly report:12
    • all donations accepted with a value of more than £1,500 during the reporting period13
    • all donations accepted from the same donor within the pre-dissolution period that add up to more than £1,500 and were not reportable in an earlier quarterly report (aggregated donations)14

received for the purpose of meeting spending on regulated campaign activity.

If you do not receive any reportable donations during a reporting period, you do not need to submit a report for that quarter as nil returns are not required.15

If you are required to submit a report, you must also report the total value of all other donations you have accepted during the pre-dissolution period with a value between £500 and the above thresholds.16  You do not need to provide any more information about these donations. 

What details must you report?

For donations you have accepted that meet the above thresholds, you must report:

  • the required details for the relevant type of donor17   (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-monetary18
  • the date you received the donation
  • the date you accepted the donation19

For donations from impermissible or unidentifiable donors you must report:

  • the name of the source, if known, or the manner in which the donation was made20
  • the amount of the donation, if monetary, or the nature and value of the donation if non-monetary21
  • the date you received the donation22
  • the date you returned the donation23
  • the action you took to return the donation (for example, the person or institution you returned it to)24

What are the deadlines for submitting quarterly pre-poll reports?

Each quarterly pre-poll report must be submitted to the Electoral Commission within 30 days of the end of each reporting period.25

The table below sets out the reporting periods and deadline dates the quarterly reports must be received by us.

Reporting period26 Pre-poll report due by27
17 December 2023 - 16 March 202415 April 2024
17 March 2024 - 29 May 202428 June 2024

You can submit your reports on PEF Online. Alternatively, you can download the reporting forms below and submit the completed forms to us by email at pef@electoralcommission.org.uk or you can post these to us. 

Last updated: 23 May 2024

Dissolution of Parliament until polling day: Weekly pre-poll reports

In the period between the dissolution of Parliament for a general election and polling day, registered non-party campaigners must also submit weekly donation reports to the Commission.1  The weekly donation report must include details of any relevant donations received with a value of more than £7,500 (a ‘substantial donation’).2

If a registered non-party campaigner does not receive any substantial donations during the relevant reporting period, no weekly report is required.3

Dissolution of Parliament until polling day: Weekly pre-poll reports

If you are campaigning in the run-up to a UK Parliamentary general election, you must report donations you receive over a certain value between the dissolution of Parliament and polling day, on a weekly basis. This is called ‘weekly pre-poll reporting’.

Which non-party campaigners are required to submit weekly pre-poll reports?

Registered non-party campaigners, unless they have declared they will spend below the reporting thresholds, are required to submit weekly pre-poll reports.4  With this declaration, you will remain exempt if your spending remains below the reporting threshold.5

If you do not receive any reportable donations during a reporting period, you do not need to submit a report for that week.6

What donations must you report?

In each weekly report you must report details of all donations with a value of more than £7,500 received by your organisation during the weekly reporting period that were received for the purpose of meeting spending on regulated campaign activity.7

This does not include aggregated donations.

You must report all donations over this value that you have received even if you have not yet accepted them – you may receive a donation but subsequently refuse it if, for example, it does not come from a permissible donor.

If you do not receive any reportable donations during a reporting period, you do not need to submit a report for that quarter as nil returns are not required.8

What details must you report?

For donations you have accepted that meet the above thresholds, you must report:

  • the required details for the relevant type of donor9  (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-monetary10
  • the date you received the donation11

What are the deadlines for submitting weekly pre-poll reports?

Each weekly pre-poll report must be submitted to the Electoral Commission within seven days of the end of each reporting period.12

Reporting period13 Pre-poll report due by14
30 May 2024 – 5 June 202412 June 2024
6 June 2024 – 12 June 202419 June 2024
13 June 2024 – 19 June 202426 June 2024
20 June 2024 – 26 June 20243 July 2024
27 June 2024 – 3 July 202410 July 2024
4 July 2024 (less than 7 days)11 July 2024

You can submit your reports on PEF Online. Alternatively, you can download the reporting forms below and submit the completed forms to us by email at pef@electoralcommission.org.uk or you can post these to us. 

Last updated: 23 May 2024

After the election

This section covers what you need to report after the election as a registered non-party campaigner.

This includes:

  • which non-party campaigners are required to report to us after the election
  • what you need to report to us
  • when you must receive and pay for invoices
  • the deadlines for reporting to us
Last updated: 24 November 2023

Reporting requirements after the election

What non-party campaigners are required to report spending and donations after the election?

If you have registered with the Electoral Commission as a non-party campaigner, you must report your donations and spending to us after the election if during the regulated period:

  • you spend more than £20,000 in England or £10,000 in any of Scotland, Wales or Northern Ireland
  • you spend more than £17,553 in a particular constituency (which is an offence)

Constituency limit

Under the Political Parties, Elections and Referendums Act 2000 (PPERA), you must not spend more than £17,553 in constituency as a non-party campaigner as you will be guilty of an offence.1  However, if you do exceed this limit when registered you are required to submit a spending return under the law.2

What must you report?

Your spending and donations must be reported to us by submitting a spending return.

You can submit your return on PEF Online. Alternatively, you can download the form below and submit the completed form to us by email at pef@electoralcommission.org.uk or you can post these to us. 

 

You must also submit a statement of accounts if you do not currently have to produce them under another law.

Alongside your spending return, the responsible person must declare that:

  • the return is complete and correct3
  • all payments were paid by them, or a person they authorised4
  • all accepted donations were received from permissible donors5
  • no other reportable donations were accepted by the non-party campaigner6

It is an offence for the responsible person to make a false declaration knowingly or recklessly.7

The following pages provide details on the reporting requirements for spending and donations, and when a statement of accounts is required.

Last updated: 5 April 2024

Spending

In your spending return you must include:

  • details of any spending incurred by you accompanied by invoices or receipts for any payment over £2001
  • a list of all constituencies where you spent more than £14,0422
  • an itemised list of expenses that have been incurred in those constituencies3
  • details of any notional spending (no invoices or receipts are required)
  • details of any unpaid or disputed claims4

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 that you spent the money
  • the date the claim for payment was made (if applicable)
  • the date the payment was made (if applicable)

You can submit your return on PEF Online. Alternatively, you can download the form below and submit the completed form to us by email at pef@electoralcommission.org.uk or you can post these to us. 

Auditor’s report

If during the regulated period you have spent over £250,000 on your regulated activity, you will also need to send us a report on your spending return by a qualified auditor.5

Last updated: 5 April 2024

Donations

Registered non-party campaigners who are required to submit a spending return must include any donations received for the purpose of meeting spending on regulated campaign activity.1

Donations

As a registered non-party campaigner, you must also report donations to us after each election as part of your spending return.

After the election you must report details of:

  • all donations from impermissible or unidentifiable donors2
  • all accepted donations with a value of more than £7,5003
  • all accepted donations from the same donor that add up to more than £7,500 (aggregated donations)4

received for the purpose of meeting spending on regulated campaign activity.5

You must also report the total value of all other donations accepted between £500 and £7,500 received for the purpose of meeting spending on regulated campaign activity.6  You do not need to provide any more information about these donations.

There is no specific reporting period for donations in your spending and donations return. Under the law you must include any donations you received towards your spending on regulated campaign activity in your return. This includes any donations already reported in your pre-poll reports.

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

You can submit your return on PEF Online. Alternatively, you can download the form below and submit the completed form to us by email at pef@electoralcommission.org.uk or you can post these to us. 

Last updated: 5 April 2024

Statement of accounts

A registered non-party campaigner who meets the reporting threshold at a UKPGE, must prepare a statement of accounts for the regulated period unless:

  • the non-party campaigner is an individual
  • the non-party campaigner has prepared a statement of accounts for another legal purpose that covers the regulated period1

Statement of accounts

After the election, you may also need to send us a statement of accounts for the regulated period.

You will be exempt from submitting a statement of accounts to us if:

  • you are already legally required to submit a statement of accounts that we are able to inspect
  • that statement of accounts contains an account of your organisation’s income and expenditure for the regulated period, and assets and liabilities for the end of the regulated period2

You will also be exempt if you are registered with us as an individual non-party campaigner.3

Auditor’s report

An auditor’s report will be required on the statement of accounts if any of the following was over £250,000 during the regulated period:4

  • your spending on regulated activity
  • your gross recorded income from all sources
  • your total expenditure, including on activity that was not regulated
Last updated: 20 December 2023

Time limits for receiving and paying invoices

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.

Invoices received after this deadline are called unpaid claims. You must record unpaid claims in your spending return.2

Paying invoices from suppliers

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

Invoices received in time but remaining unpaid after this deadline are called disputed claims. You must record disputed claims 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.

Latest date to
Receive your invoices Pay your invoices
5 August 2024 (6 August in Scotland)2 September 2024

Leave to pay

You must not pay unpaid or disputed claims unless there is a court order or judgement enabling you to do so.6  This is known as leave to pay. It is an offence to make a payment for an unpaid or disputed claim without obtaining leave to pay.7

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.

Last updated: 24 May 2024

Reporting deadlines

The date you must report to us by will depend on how much you spend on your campaign:

  • If your campaign expenditure is £250,000 or below, you must submit your return within three months of the election1
  • If your campaign expenditure is above £250,000, you must submit your return and the auditor’s report within six months of the election2

If you are required to submit a statement of accounts, you must submit this within six months of submitting your spending return to us.3

You may be liable for a penalty if you don’t submit your return or statement of accounts on time.4  We may contact you to ask which date applies to your return. 

Campaign expenditure of £250K or belowCampaign expenditure of over £250K
4 October 20244 January 2025
Last updated: 23 May 2024

Key terms we use in this guidance

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.

Constituency spending limit

During the regulated period for a UK Parliamentary general election (UKPGE), a non-party campaigner cannot spend more than a set limit (£17,533) on regulated campaign activity in a particular parliamentary constituency.2  

This limit applies to all non-party campaigners, both before submitting a notification and while registered.

See Spending limits 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.3  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.4

Notification threshold 

Non-party campaigners intending to spend more than £10,000 on regulated campaign activity must submit a notification to the Commission.5  After submitting the notification, they will appear on the register of notifications.

Permissible

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

Pre-poll reporting

Registered non-party campaigners that campaign in the lead up to a UKPGE, unless exempt, must report certain donations to the Commission before polling day.

This includes donations reports on a quarterly basis during the pre-dissolution period (quarterly pre-poll reporting) and on a weekly basis between the dissolution of Parliament and polling day (weekly pre-poll reporting).

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 submit a notification to the Commission. In law these are known as the organisation’s ‘relevant participators’ or ‘relevant details’.6

See Relevant participators and relevant details for more information.

Reporting thresholds

The reporting thresholds are:

  • £20,000 in England
  • £10,000 in Scotland, Wales or Northern Ireland

If a registered non-party campaigner spends over the reporting threshold in any part of the UK, they must report their spending and donations to us after the election.7

See Reporting thresholds 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.8

See Responsible person for more information.

Targeted spending

Spending on regulated campaign activity that can reasonably be regarded as intended to influence voters to vote for one registered political party or any of its candidates.9

See Targeted spending for more information.

Last updated: 20 December 2023