This guidance has been produced to support Electoral Registration Officers (EROs) in planning for and delivering well-run electoral registration services. 

It has been developed in close consultation with colleagues across the electoral community including the Society of Local Authority Chief Executives (SOLACE), the Association of Electoral Administrators (AEA), the Scottish Assessors Association (SAA), the UK Electoral Coordination and Advisory Board (ECAB), the Elections, Registration and Referendums Working Group (ERRWG) and the Welsh Electoral Practitioners Working Group (WEPWG).

It reflects the ERO’s legal obligations and what we, and colleagues across the electoral community, believe that EROs should expect of their staff in planning for and delivering well-run electoral registration services.

Performance Standards

In addition to our role in providing advice and guidance, we set standards and monitor the performance of EROs through our performance standards framework.

Our guidance to support the delivery of your functions includes what we expect EROs will need to have in place and what we would expect to see for the key outcomes of the standards to be delivered. You should be mindful of this framework in the planning and delivery of your registration functions.

For more information on the framework see our performance standards guidance for EROs.  

How to use this guidance

The guidance is directed towards the ERO and the duties they carry out. As these duties may, in practice, be carried out by deputies and/or appointed staff, we use the term ‘you’ throughout this guidance to mean the ERO and whoever is carrying out the ERO’s functions on their behalf. 

Throughout this guidance we use ‘must’ to refer to a specific legal requirement and ‘may / should’ for recommended practice.

To help you use this guidance we have produced a Q&A document that should answer any initial queries you may have. 

As Electoral Registration Officer (ERO) you are responsible for compiling and maintaining the register of electors.

This guidance covers the appointment of EROs, your duties to conduct an annual canvass and to maintain the register throughout the year, and the resources required to support you in your duties.  

How are Electoral Registration Officers appointed? 

In order to be able to vote in elections in Scotland, a person’s name must be included in a register of electors. As ERO you are responsible for compiling the register of electors. 

The local authority, or a combination of local authorities must appoint an officer of that council or an officer of an adjoining council to be the ERO.

The ERO is typically the local Assessor, and should undertake relevant training to ensure they have, and maintain, the skills required for the role.

What are the duties of an Electoral Registration Officer?

The statutory functions, including the duties of the ERO, are set out in legislation. Further duties can be imposed by a direction of the Secretary of State. 

The Secretary of State has a power to direct EROs in the discharge of their functions in relation to UK Parliamentary elections and combined elections, but can only exercise this power of direction on, and in accordance with, a recommendation of the Electoral Commission. This power is held by Scottish Ministers in relation to Scottish Parliamentary and local government elections.1

The convener of the Electoral Management Board may also give directions to EROs about the exercise of their functions in relation to a particular Scottish parliamentary or local government election.2

The local authority that appointed you as ERO must provide the resources needed to discharge your statutory functions. Any expenses properly incurred by you in performance of your functions must be paid by the local authority that appointed you.3
 

Maintaining the register

The electoral register

As ERO you have a duty to maintain:

• a register of parliamentary electors
• a register of local government electors1   

These registers contain details of those who are registered to vote and must be combined as far as is practicable. Any reference to the register in our guidance should be taken as a reference to the combined registers unless otherwise stated.

The franchise for Scottish Parliamentary and local government elections includes 16 and 17 year olds. This means that the local government register will include 16 and 17 year olds as full electors. Additionally 14 and15 year olds are entitled to be included on the local government register as attainers.2  An attainer is someone who turns 16 by the end of the twelve months following the 1 December after the relevant date.
 
The combined register will need to make clear the date on which those who are under 18 years of age will become 18 years old in order to clearly show their eligibility to vote in different elections.

No information on those aged under 16 must be included on any version of the register published or otherwise made available, except in very limited circumstances. For further information, see our guidance on access and supply of the register.

The franchise for Scottish Parliamentary and local government elections has been extended to qualifying foreign nationals and also to prisoners convicted to a term of 12 months or less.3
 
The entry in the combined registers of any person who is registered only as a local government elector by virtue of being a qualifying foreign national or a prisoner must give an indication of that fact.

The edited register

You must also produce an edited (or open) version of the register.4  We use the term edited register, as this is the technical term used in the legislation. Open register is used to describe the edited register to members of the public to make it easier to understand the purpose of this register and how it is used. Where we mention the edited register in this context, we will refer to the edited register as the open register.

The edited register contains only the names and addresses of those on the full register who have not opted out of their details appearing on the edited register.

A person under 16 years old is automatically opted out of the edited register.

Absent voting records

In addition to maintaining the register, you have a duty to process absent vote applications, maintain the absent voting record and produce the lists of absent voters for an election.5  More information can be found in our guidance on absent voting.

Ensuring registers are accurate and complete

You need to publish registers that are as accurate and complete as possible.

By accurate we mean that there are no false entries and by complete we mean that every person who is entitled to have an entry in an electoral register is registered.

You have a duty under Section 9A of the Representation People Act 1983 (as amended by the Electoral Registration and Administration Act 2013) to take all necessary steps to comply with your duty to maintain the electoral register, and to ensure, as far as is reasonably practicable, that all those eligible (and no others) are registered in it.1  

The steps required under Section 9A include:

• sending at least one canvass communication to any address
• sending a canvass form more than once
• making on one or more occasions house to house inquiries
• making on one or more occasions contact by telephone
• making contact by such other means as the registration officer thinks appropriate with persons who do not have an entry in a register
• inspecting any records held by any person which he is permitted to inspect under or by virtue of any enactment or rule of law
• providing training to persons under his direction or control in connection with the carrying out of the duty

You must actively consider each of the steps listed and take all such action that you consider necessary in order to fulfil your duty to maintain the register of electors. The steps do not need to be taken in any particular order.

If you fail to take these steps, you may be in breach of official duty, which on summary conviction can result in a fine not exceeding level 5 on the standard scale.2

While the Section 9A duty to take all necessary steps to ensure your registers are accurate and complete still applies, the requirement to carry out house-to-house enquiries as part of the annual canvass has not been extended to 14 and 15 year olds. 
 
You are also required by law to take specified steps to follow up on particular canvass non-responses, including making contact with the property or an individual. 

Any potential new electors identified will also need to be sent an Invitation to register (ITR) and a registration application form, and you will need to take the specified steps – issuing two reminders and a personal visit - to follow up with any ITR non-responders.3 These processes will not all be linear and will need to be carried out concurrently.

These duties apply throughout the year and not just during the canvass period.

We provide more guidance to help you with production of the ITR and registration form in our forms and letters guidance.

A personal visit to 14 or 15 year olds who have not responded to an ITR is not required at any time during the year.4

If you do not make a visit to the household, you should consider what other mechanisms you can use to encourage a response from those in this age group. For example, you could contact under 16's by email if you hold their email address. Also, as part of any canvass follow-up activity, there may be an opportunity to remind any adults living at an address that 15 year olds and some 14 year olds are now entitled to register and to ask them to encourage any 14/15 year olds at the address to apply to register online.

You should also consider working with partners that specifically work or have influence with young people and reflect this in your plans. For further information, see Planning for registration and public engagement throughout the year.   

We have produced a resource about engaging with young people and attainers.

Encouraging participation

You have a duty to take such steps as you think appropriate to encourage the participation of electors in your area in the electoral process. In doing this, you must have regard to any guidance issued by the Electoral Commission.1  You also have a duty to encourage participation in any referendum held throughout Scotland in pursuance of a provision made by or under an Act of the Scottish Parliament.2

Throughout the year you should work to identify people who are not registered and encourage them to register. You should also have specific plans to carry out registration activity in advance of scheduled elections or referendums.

You should have a public engagement strategy and registration plan which sets out your approach to identifying and targeting potential new electors.
 
Further information about encouraging participation is contained in our guidance on planning for registration and public engagement throughout the year. 

Local authorities have a specific duty to promote awareness of how to register as local government electors for children that are looked after by that council (who can be up to the age of 18) and to provide assistance to help such young people to register.3  You need to engage with other departments and staff in local authorities and other bodies with responsibilities of care to promote these arrangements. Looked after children are children that:4

• the council is providing living accommodation for because no-one has parental responsibility for the child, the child is lost or abandoned, or the person who had previously been caring for the child cannot provide suitable accommodation or care
• the council is required to supervise under a supervision requirement of a children’s panel or a sheriff
• the council has responsibilities for under a legal order, authorisation or warrant, issued in Scotland by a children’s hearing or sheriff, or, in the rest of the UK, by a court

What resources do Electoral Registration Officers need to carry out their role?

It is important that you are supported to fulfil your role, given the range of statutory duties, and the seriousness of any breaches.1
 
The local authority that appointed you must provide the resources needed to discharge your statutory functions. Any expenses properly incurred by you in performance of your functions must be paid by the local authority that appointed you.2  

Appointing a Depute

You should ensure that your council approves the appointment of one or more Depute EROs who can carry out the duties and powers of the ERO if you are unable to act personally. 

Any deputes appointed should have the skills and knowledge required to carry out the functions that they have been assigned. Appointments should be made in writing and include clear details of the full or particular powers that the depute is authorised to exercise on your behalf. In particular, it may be useful to appoint deputes to undertake quasi-judicial procedures, such as hearings of registration applications, objections and reviews. The acceptance of any such appointment should also be made in writing.

Unlike Returning Officers, the ERO cannot appoint a depute themselves, unless the power to do so has been delegated to them by the council.3
 
If the position of ERO is vacant or the ERO is incapable of acting, any of the duties and powers of the ERO may be carried out by the proper officer of the council.4  

The electoral registration team

The local authority that appointed you must provide officers to assist you in your statutory functions.5 You should consider how the authority can provide the support required for your registration plans to be delivered. In particular, you should ensure that you have enough staff with the right skills in your team. For guidance on planning, training and recruitment of staff, see planning for registration throughout the year. 

Budgeting for registration activity

As part of your annual planning process, you will need to consider what budget you require in order to carry out your statutory functions. The budget for registration should be settled between you and the local authority which appointed you, and that should be sufficient to allow you to fulfil your duty to maintain the register. 

This should include all activity involved in conducting the annual canvass. For further details on the necessary activities see our guidance on delivering the annual canvass.

You also need sufficient resources to maintain the register throughout the year to ensure that it remains complete and accurate. For further details see our guidance on planning for registration throughout the year.

If you are acting on behalf of more than one local authority, each local authority should contribute to the registration budget.

You should properly account for the expenses of registration you incur and liaise with the authority to agree a suitable accounting process and budget.

While we recognise the increasing budget pressures facing local authorities which force difficult choices between competing statutory services, a lack of resources does not exempt you from complying with the law.

Checking the audience for public engagement

Eligible electors in your area will fall into distinct groups in relation to registration. 

Unregistered / new electors

Any new electors will need to make a registration application and provide their personal identifiers in order to register to vote.

Those who are not on the register, including typically unregistered groups, remain a target for registration activity. The groups that are less likely to join the register and the barriers that stop them doing so will vary by area, creating unique local challenges. There is an ongoing challenge in identifying local issues and taking action in response to these to ensure that as many people are registered as possible.

Social groups needing additional engagement activity 

Research has shown that certain groups are more likely to be absent from the register or not registered at their current address. 

The reasons for particular groups being absent from the register are diverse – for example, they may be transient in where they live, they may be disengaged with politics, or they may be unaware of their rights. This means that these groups need to be reached in different ways, using different channels, and that they will be motivated by different messages. 

From the profile data you have gathered, you will have identified the specific social groups in your area that are less likely to join or be on the register, either because they are typically under-registered, or because they do not typically respond to communications from the ERO. These groups will need additional targeted engagement activity to increase the likelihood that they will join the register. 

These groups may include: 

• Private renters 
• Home-movers and mobile population 
• Young people (under 35s) 
• Attainers 
• Commonwealth citizens 
• Qualifying foreign nationals
• Some black and minority ethnic groups (African, Mixed, Bangladeshi) 
• People resident at their property for less than 2 years 
• People who have lived in the UK for less than 5 years 
• Low level of English fluency 
• Unemployed 
• Young people with no qualifications
• Students at term-time address

Some challenges may not be audience-specific but may be particular to your area. For example you may have geographical barriers, or you may have low levels of broadband connection that mean people will find it harder to access online registration. Your strategy should also consider how to address these considerations.

You will have identified the groups that need particular engagement activity in your public engagement strategy. After reviewing the profile of your registration area, you should review the particular groups identified to ensure that they remain relevant. Your resources might need to be re-directed, you might need to continue your work but refine your approach, or another group might have emerged requiring particular engagement, such as attainers. 

Electors who are already registered

These electors will have their names included on communications sent out as part of the canvass. They will need to know what to do if any changes are required to their registration information.

Example target audiences and opportunities for reaching them are set out below:

Hard to reach groups

Research has shown that certain groups are more likely to be absent from the register or not registered at their current address. 

You will have identified the specific social groups in your area that are less likely to join or be on the register, either because they are typically under-registered, or because they do not typically respond to communications from the ERO. These groups will need additional targeted engagement activity to increase the likelihood that they will join the register.

The table below sets out some of the challenges and opportunities for reaching these hard to reach groups.

Training public-facing staff to deal with enquiries

You should provide updated face-to-face briefings or written information to local authority staff who deal with the public to ensure they have the information they need to be able to respond to any queries they may receive.

This means thinking about likely queries and developing scripts and lines to help employees responding to enquiries to answer questions or refer callers to the right place. 

We have provided an FAQ resource to support you. 

Staff will also need to be prepared to deal with enquiries from, and relating to the registration of 14-17 year olds and qualifying foreign nationals, who may have no experience of the registration system.

To inform your planning, you should consider the level and type of enquiries you received during the last canvass and at Scottish Parliamentary and local council elections, and the channels through which these were received.

How can partnerships help to raise public awareness?

Partnerships can help you to raise public awareness by:

• sharing messages - for some social groups, messages are more likely to be acted upon if they come from someone they trust and know – for example, a respected community leader or organisation
• extending the reach of your advertising – for example, a dentist may put posters in their waiting room, you could also place them in community buildings or on public notice boards 
• including information in the communications they already send out
• increasing your capacity by answering people’s questions and supporting them to fill in forms - for example charitable organisations

Other partnership activities could include:

• providing registration forms for estate agents to attach to rental contracts
• identifying a charity whose volunteers are willing to help people fill in forms
• working with a large local employer who is keen on supporting community causes
• providing materials for or working together to deliver a workshop on democracy and registration

Partners may also be able to identify other opportunities that you have not yet considered.

When selecting appropriate partners to engage with those who are under 16 you should consider obtaining advice from your local education services and child protection departments. 

Data protection considerations when working with partners

You need to be able to demonstrate that all information obtained, whether from internal or external partners, complies with the principles of processing personal data, ensuring that it is processed lawfully, fairly and in a transparent manner.

You should ensure that any partners assisting electors to complete applications are aware of data protection principles before handling any personal data. 

External organisations from whom you are obtaining personal data, for example, universities and care homes, will hold personal data on their students and residents respectively and are likely to be data controllers in their own right. 

Although data protection legislation does not require a written agreement when sharing data between data controllers, it is strongly recommended that you agree with your partner a data sharing agreement to help you both demonstrate that you are acting in accordance with data protection legislation

Our guidance on data protection for EROs and ROs contains further information and a checklist to support you in developing a data sharing agreement.

How the Commission can support you with public engagement

There are a range of resources available on the Commission’s website which could be used or developed for future campaigns. You can also subscribe to our voter registration newsletter - Roll Call, which contains the latest information about promoting voter registration and our partnership work.

Our resources will be updated ahead of scheduled polls as appropriate, but the general guidance and suggestions continue to be relevant and may be helpful throughout the year.

Direct one-to-one support also continues to be available through our Scotland office.

You can contact them by:

• Telephone: 0333 103 1928
• Email: [email protected]

Your registration plan

While your public engagement strategy will help you identify the registration challenges in your area and a general approach for tackling them, your registration plan should be informed by it and capture the detailed actions of everything that needs to be done to maintain electoral registers that are as accurate and complete as possible – not just throughout the canvass period, but throughout the year.

What should a registration plan include?

Your registration plan should capture all registration activity throughout the year, including in the lead up to scheduled polls and during the canvass. 

We have produced a template registration plan you can use to support your planning for the delivery of electoral registration services. You do not have to use the template provided.

It is important that you treat your registration plan as a living document and keep it under regular review using available data to monitor progress and to identify where any amendments need to be made.

At a minimum, your registration plan should cover: 

• a timetable of deliverables and tasks which should demonstrate how you intend to carry out the necessary steps under Section 9A, both during the canvass and throughout the year
• details of planned partnership activity
• details of how you will implement your strategy for engaging with 14-17 year-olds in your area.
• details on how you will manage the processes you are required to follow to verify the identity of 14 and 15 year olds, including how you will access and use educational records and any other records for these purposes.
• objectives and success measures
• resource requirements
• review of internal processes to ensure they remain relevant, including what measures you have put in place to ensure data protection requirements are met
• identification of training needs, both for external and internal sources of training
• mechanisms for tracking and evaluating progress and for recording amendments
• processes to identify any patterns of activity that might indicate potential integrity problems, including what steps are to be taken to deal with any such problems

You will need systems in place that enable you to track your progress towards ensuring that as many eligible residents as possible are included on the register. This should include processes to track responses from individuals and households to monitor, evaluate and target resources to identify where amendments to your plans are required.

You also need to maintain a risk and issues register, identifying any risks to the effective delivery of your registration plan and corresponding mitigating actions.

We have developed a template risk and issues register that you can use to record any risks you identify. It contains examples that you will need to consider and, if necessary, mitigate, as well as a log to record any issues that emerge and that you will need to address. Alternatively, you may wish to include risks including our examples in any risk management documentation you have already developed.

What resources are needed to deliver your registration plan?

You will need to identify what work you need to do to engage with residents, and consequently, what resources you will need to do this. Keeping your plan and activity under review will enable you to understand whether your local challenges are being met and enable you to target your resources where they are most needed.

You will need to consider what resources, including staffing resources, are needed to process applications from 14-16 year olds. Staff will need to be given appropriate training and guidance relating to handling and storing the personal data of 14 and 15 year-olds. 

You should also liaise with your local education services department to obtain data that will help to refine your assumptions further. If you have not already done so, you should consider developing a data sharing agreement to facilitate the secure and timely sharing of data. 

Key departments and individuals you will need to involve, may include:

• the local authority’s IT department 
• the local authority’s finance team
• data holders
• the data protection officer at the local authority
• the local authority’s call centre / reception manager
• the communications / media manager at the local authority (if there is one)
• the local authority’s HR manager
• representatives of local authority teams/individuals and local organisations who work with under-registered groups in your area, such as local education departments

When working with key departments you should remember that subject to limited exceptions, only EROs and their staff will be able to use the data relating to these individuals. The Returning Officer at a Scottish Parliamentary or local government election will have access to the data relating to those 15 year olds who will attain voting age on or before polling day. A young person’s data may also be disclosed to the young person themselves, and in certain other prescribed circumstances. For further guidance on access to the information included in the electoral register, see Who can be supplied with the register?

Your plan should cover how you will be engage these departments/individuals and how often you will meet with them. Consider:

• whether you should personally chair the group
• who should be involved
• what the terms of reference will be
• how actions will be recorded and taken forward

What records can you inspect to assist you with identifying potential new electors throughout the year?

Your registration plan should include detail of data sources available to you and a schedule of when checks of those records are to be carried out. 

As ERO you can by law, for the purpose of meeting your registration duties, inspect and make copies of records kept in whatever form by any council which appointed you.1

These local data sets will include:

• registrar of births, deaths and marriages 
• any person, including a company or organisation, providing services to, or authorised to exercise any function of, the council including any providing outsourced services under any finance agreement 

Where the ERO requests to inspect and/or take copies of the records listed above, a statutory or other restriction, including the GDPR, cannot be used to refuse disclosure of those records.2 For example, if a private contractor has been appointed to collect council tax on behalf of your local authority, as ERO for that authority, you are entitled to access the data held by that contractor.

In addition to this, the council which appointed the ERO is permitted to disclose to the ERO, for certain registration purposes, information contained in records held by the council.

There are three purposes:

• to verify information relating to a person who is registered in a register maintained by the officer, or who is named in an application for registration
• to ascertain the names and addresses of people who are not registered but who are entitled to be registered
• to identify those people who are registered but who are not entitled to be registered

Disclosure can only be made in accordance with a written agreement between the council and the ERO processing of the information, including its transfer, storage, destruction and security.

You should also ensure that you are making full use of all the records available to you to check entries on the register, taking steps to remove those electors who are no longer entitled to remain registered.

You should record the number of electors removed from the register and the reason for the removal.

For more information on what types of other records can also be used to identify changes and those who may no longer be entitled to be registered at a particular address see our guidance on managing amendments, reviews, objections and deletions throughout the year.

You will need to use information sources available to identify and target new electors, and ensure that all necessary steps are taken to add them to register.  

While records may assist you in identifying who does not have an entry in the register, any potential new elector who is identified must always make a successful application before they can be added to the register. You should record the number of electors added to the register and how these applications originated. For example, whether the application was unsolicited or was it following information included in a canvass communication.

The following records may help you maintain your register throughout the year: 

• Council tax: These records may indicate new residents have moved into a property. However, the person named on council tax records is not always eligible to register to vote, for example owners of properties that do not reside there. Also, council tax records will not necessarily tell you all of the people resident at the address who you may need to invite to register. Council tax records can be used as evidence that a property is empty or that it is not someone’s main residence, which may affect their entitlement to register. Access to these records should include any supplementary notes, which may assist with clarifying who is resident.
• Council tax reduction (formerly council tax benefit): These records may alert you to others living at a property. 
• Housing: The records of arms-length management organisations and housing records where the council maintains the housing stock can be inspected for tenants details.
• Housing benefit: Housing benefits are paid directly to an individual and as such can be helpful in identifying new electors.
• Register of households in multiple occupation (HMOs): You should consider using these records to make contact with landlords or managing agents who are likely to be able to provide names of new residents. 
• Records held by registrars of deaths and marriages: Information received about marriages and civil partnerships could indicate an additional resident at a property. It may also alert you to a change of name of an existing elector. Or in the case of deaths indicate where an existing elector may need to be removed.
• Lists of residential and care homes / shelters / hostels: Social services (or equivalent department) will be able to provide lists of residential and care homes, as well as shelters and hostels. Wardens of these accommodations may be able to provide information on changes of residents. We have developed assisted applications guidance which details what one person can do to support another to register.

• Lists of disabled people receiving council assistance: Social services (or equivalent department) may be able to provide details of certain disabled people living at home, such as those who are blind, deaf, etc., which should also enable you to tailor the service you provide to such individuals.
• Registers of Scotland: Can be used to find information on sales of property, which can provide information on changes, particularly as the name of the buyer is given.
• Planning and building control: Inspection of building control records and liaising with house builders can give an indication of the progress of new developments and whether they are ready for residential occupation. Instead of liaising with planning and building control directly, you may be able to gain the necessary information from the local Assessor.
• List of new British citizens held by the registrar: The registrar will have information on who has become a British citizen. You are entitled to inspect and make copies of these records, and could use them to identify potential new electors. Information on applying to register to vote could be given to the registrar to include packs they make available to those receiving British citizenship. Depending on their previous/other nationality, someone who has become a British citizen may already be on the electoral register, but information should be provided in any case to ensure that they have the correct franchise.
• Local authority education data: This data may provide information to assist with the identification of potential electors aged under 18 who may be eligible to be registered as attainers or electors.

You separately have the power to require information from a person who is not the elector. You can use this power where it is required for the purposes of maintaining the register.3  For example, you can use it to require those in charge of multiple occupation establishments or care homes to provide you with information on residents.

To comply with data protection legislation, you need to demonstrate that all information obtained complies with the principles of processing personal data, ensuring that it is processed lawfully, fairly and in a transparent manner. Therefore, you should maintain details of:

• the records to be checked
• a schedule of when those checks are carried out
• the lawful basis on which you are processing that information. For example, Section 9A places an obligation on you, the ERO, to inspect these records as part of your duty to maintain the electoral register, therefore providing the statutory basis by which you are processing that personal data the security in place to protect the data. For example, encrypting/password protecting data whenever it is transmitted, and using secure storage
• action taken on the basis of the information you have obtained
• retention and secure disposal of data (in accordance with your document retention plan)

Eligibility to register to vote

In order for a person to be eligible to register to vote in Scotland they must meet the eligibility criteria on the relevant date. There are three aspects to the entitlement to be registered:1  

• the application is made by someone who appears to be the person named on the application
• any statutory requirements in relation to the application, including how it may be made and the information it must contain, are met
• the person named on the application appears to the ERO to meet the eligibility criteria for registration and is not disqualified from registering

At what age can someone register to vote?

A person aged 16 or over on the relevant date who meets the residency and nationality qualifications and is not subject to any legal incapacity to vote is entitled to be included on the local government register, however an elector must be 18 to be included on the UK Parliamentary register.

This means that the local government register will include 16 and 17 year olds as full electors,1 16 and 17 year olds are entitled to vote in local government and Scottish Parliamentary elections.2

Additionally, 14 and 15 year olds are entitled to be included on the local government register as attainers3 . 

The combined register must make clear the date on which those included on it that are under 18 years of age will be 18 years old in order to clearly show their eligibility to vote in different elections.

Information on those aged under 16 must not be included on any version of the register published or otherwise made available, except in very limited circumstances. 

What are the residency requirements for registration purposes?

A person must be resident, on the relevant date, at the address at which they want to be registered.1  Residence has a particular meaning in electoral law and is not equivalent to residence for other purposes such as income tax or council tax.

Normally a person is resident at an address for electoral purposes if it is their permanent home address.

When making a determination on someone’s residence, you need to consider the circumstances of the applicant, including the purpose they are present at a particular address for and/or the reasons they are absent.

What is a qualifying address for electoral registration purposes?

The qualifying address is the address a person is entitled to be registered at. The applicant or elector must be deemed resident at this address in accordance with electoral legislation.

The register must include the qualifying addresses of those persons registered in it,2  subject to certain exceptions, including overseas and anonymous electors. More detailed information on these exceptions is available in our guidance on special category electors.

Which electors are exempt from the residency requirement?

Certain categories of electors have special provisions entitling them to register despite not meeting the residence requirement. These electors include:

• service voters 
• anonymous electors
• overseas electors
• prisoners serving a term of less than 12 months

On submission of the relevant declaration together with their application to register to vote, such electors will be deemed to meet the residence requirement. Our guidance on special category electors provides further information on these types of electors and the process by which they can register.

Does unlawful occupation of grounds or a property prevent registration?

Unlawful occupation of grounds or a dwelling does not disqualify a person from registering there if it is determined that this is their permanent residence. As a result any issue regarding tenancy, ownership or legal occupation of the property by the applicant must be disregarded in determining whether or not the residence requirement has been met.

Can someone register to vote without a fixed address? 

A person who does not have a fixed or permanent address may register at the place where they spend most of their time, or to which they have a local connection. In some cases they will need to register by making a declaration of local connection.

More information on making and processing declarations of local connection can be found in our guidance on special category electors.

How can merchant seamen register?

Merchant seamen who are not resident in the UK but would be if not for their employment are entitled to be treated as resident at either an address at which they would normally be resident, or at a hostel or club which provides accommodation for merchant seamen and at which they would commonly stay in during the course of their occupation.1  

How can gypsy and traveller communities register?

Some members of gypsy or travelling communities may not have a permanent address, although they may settle for a period of time at sites designated by the local authority. When present at those sites for a substantive time, they may be considered to be resident there and may register as ordinary electors.

The local authority, who are responsible for maintaining any sites and ensuring appropriate education is provided for the children, may be able to assist you in assessing the situation in the local area and helping facilitate the registration of any gypsies or travellers who meet the entitlement.

Where there is no address where a particular gypsy and traveller community can be considered resident, they cannot register as ordinary electors. They may instead register by making a declaration of local connection at the place where they spend most of their time, or to where they have a local connection.2  

You should consider the presence of any gypsy or travelling communities in your area and decide on the best approach to take locally.

How can people living on narrow boats and other movable residences register? 

Any person living permanently on a boat, houseboat or similar residence which has a permanent mooring in Great Britain can be treated as being resident at that address and should be registered as an ordinary elector. 

When a person lives on a boat or other similar residence without a permanent mooring, they cannot be treated as being resident at any particular address. They will be entitled to make a registration by declaration of local connection at a place where they spend the most of their time (whether during the day or night).3 This may, for example, be a boatyard used for maintenance.

How can homeless people register?

A homeless person will not have a permanent home address and therefore will not be able to register as an ordinary elector. They may make an application to register by local connection at an address where they spend a substantial part of their time, whether during the day or night.4 It may, for example, be a bus shelter, a park bench or the doorway to a high street store.

How do looked after children and children in secure accommodation register?

Those under 16 years old who are, or have been, looked after children, or are currently being kept in secure accommodation, are entitled to register by making a declaration of local connection.5  

Looked after children are children (who can be up to the age of 18) that:

• the council is providing living accommodation for because no-one has parental responsibility for the child, the child is lost or abandoned, or the person who had previously been caring for the child cannot provide suitable accommodation or care
• the council is required to supervise under a supervision requirement of a children’s panel or a sheriff
• the council has responsibilities for under a legal order, authorisation or warrant, issued in Scotland by a children’s hearing or sheriff, or, in the rest of the UK, by a court.

Can prisoners register to vote?

Convicted persons serving a prison sentence of 12 months of less meet the criteria to register to vote. However any prisoner serving a sentence that exceeds 12 months is legally incapable of voting. There are some other limited circumstances where a prisoner may meet the criteria to register to vote, for example they may be able to register if they are released on temporary licence.

Can a prisoner serving a sentence of less than 12 months register?

Prisoners are entitled to register to vote as local government electors if they have been convicted for a total term of 12 months or less.

Where a person is already included on the electoral register before their conviction, they may continue to be registered at that address, providing they intend to return to live there following their release and they are not prevented from doing so by any court order. 1 Alternatively, a person can be deemed to have continued residence at an address if it is a permanent place of residence and the person would be in actual residence if it were not for their detention.2

If a person is not deemed to have continued residence at their registered address, they may register by means of a declaration of local connection:3  

• at the address in Scotland at which they would be living if they were not convicted, or 
• if they cannot give such an address:
  • at an address in Scotland where they used to live before they were convicted, or 
  • if they were previously homeless, an address in Scotland where, or which is nearest to a place where, they commonly spent a substantial amount of time, or 
  • if they cannot give any address as described above, or can only give an address at which they are prevented from returning to live because of a court order:
  • at the penal institution

In the case of prisoners registered as local government electors through a declaration of local connection, although their declaration is valid for 12 months, their restricted franchise only applies for the duration of their detention.
 
Upon release, a new application is required in order for them to be added to the register of UK Parliamentary electors, and you should invite them to make a new application upon their release.

Can a prisoner on remand register?

A person who has been remanded in custody (but is not a convicted prisoner) who is detained in a penal institution or some other place for custodial purposes, may be deemed to be resident there for registration purposes, if the period of detention is sufficient to enable them to be regarded as being resident there.4
 
A remand prisoner may also choose to register by making a declaration of local connection at:5

• the address at which they would be living if they were not a prisoner on remand
• an address where they used to live before they became a prisoner on remand

A remand prisoner may still be considered resident at their permanent home if their stay at their place of custody is not long enough for them to be able to be regarded as resident there or for them to be able to register through a declaration of local connection.6

Can a convicted prisoner released on temporary licence register?

It is possible that in some limited circumstances, convicted prisoners who have been released on temporary licence may meet the criteria to register to vote. In these cases, the person’s place of residence should be determined in the ordinary way. 

Our guidance provides further information on the registration options available for prisoners on remand and patients in mental hospitals.
 

What are the nationality requirements to register to vote?

General provisions

An individual’s citizenship is one of the factors that determines which, if any, elections in the UK a person is entitled to be registered to vote at.

If an applicant is unsure regarding any aspect of their nationality, they should be advised to contact the Home Office. You should point out to them that they need to be sure of their nationality before applying – knowingly providing false information on an application is an offence, punishable on summary conviction by up to six months imprisonment and/or a fine not exceeding £5,000.1

How should an elector with dual nationality be registered?

Some applicants may have more than one nationality. You should always process an application in accordance with the nationality that provides the higher level of franchise.

For example, an application stating that the applicant is a dual German and British citizen should be registered as a British citizen, as this gives them the wider franchise.
 

Can a citizen from the British Overseas Territories register to vote?

British Overseas Territories citizens have the same status as Commonwealth citizens and are entitled to register as electors in respect of all elections, provided that they also fulfil the age and residence requirements for such registration and are not subject to any other legal incapacity.

British Overseas Territories citizens are not eligible to register as overseas electors, unless they also hold British citizenship, in which case they would be eligible providing they also meet the relevant eligibility conditions.

How do you process an application from a citizen from Hong Kong?

Following its transfer to Chinese sovereignty on 1 July 1997, Hong Kong was deleted from the list of British Overseas Territories. As a result, former residents of Hong Kong are not automatically qualifying Commonwealth citizens.

Only those previous residents of Hong Kong who hold a British Overseas Territories, British Nationals (Overseas) or British Overseas passport meet the nationality criterion for all elections in the UK. Any previous resident of Hong Kong who only has a Chinese Special Administrative Region passport is Chinese and may not register as a qualifying Commonwealth citizen. They may, however, be eligible to register as a qualifying foreign national.

If an elector declares their nationality to be Hong Kong Chinese then you should exercise your powers to require evidence of the elector’s actual nationality and confirm the type of passport that they hold.
 

Can a foreign national register to vote?

Electors of any nationality are eligible to register to vote in local government and Scottish Parliamentary elections, providing they meet with the age and residency requirements and that they are not legally incapable of voting.

A qualifying foreign national is a person who is not:

• a Commonwealth citizen, or
• a citizen of the Republic of Ireland

and who has or does not require leave to remain or is treated as having leave to enter or remain in the UK.1  

Subject to meeting the age, residency and legal capacity requirements, citizens from the Republic of Ireland and the Commonwealth are eligible to register to vote in UK Parliamentary elections.

Which nationalities can vote at which elections?

UK Parliamentary elections

All British, Republic of Ireland and qualifying Commonwealth citizens meet the nationality requirement to register to vote in UK Parliamentary elections.1  

Local government elections

British citizens, Irish citizens and qualifying Commonwealth citizens all meet the nationality requirement to register to vote in local government elections.2  

Qualifying foreign nationals are entitled to be registered in the register of local government electors.3

Scottish Parliamentary elections

The local government election franchise is also used as the basis for elections to the Scottish Parliament.4

We have produced a resource outlining the nationality requirements for each type of election.

If you are not satisfied as to any applicant or elector’s nationality, you have the power to require the applicant or elector to provide documentary evidence confirming their nationality. You can ask for the following evidence:1

• a birth certificate
• a certificate of naturalisation
• where a person has made an application to register as an overseas elector, further evidence as to their status as a British citizen
• a document showing that someone has become a Commonwealth citizen
• a statutory declaration that they are a qualifying Commonwealth citizen, a citizen of the Republic of Ireland or a relevant citizen of the European Union

In order to be entitled to register to vote a person must be legally resident in the UK. If you are in any doubt as to whether an applicant or elector is legally resident, you can request checks of a person’s immigration status against Home Office records.

Further guidance on this process and contact details are available by contacting the Home Office: [email protected] (Opens in new window). You will be asked to complete a template which will be provided – please complete and return the section below the heading ‘Subject 1’ to the same email address. The Home Office have requested one template per subject per email, and that ‘ER’ be added to the subject header for each email to ensure that it goes into the correct folder for a response. The Home Office will respond within five working days unless a file is required, in which case it will respond within ten working days. The fact that you may require additional evidence of an applicant’s nationality, and may request checks of a person’s immigration status against Government records is included on the registration application form approved by the Minister and made available to you by the Commission.
 

How does legal incapacity affect the right to register to vote?

A person subject to a legal incapacity to vote cannot be included on the register of electors.1

Peers

Peers who are members of the House of Lords2 are disqualified from voting at UK Parliamentary elections and therefore are not entitled to be registered in the UK Parliamentary register of electors. They do, however, qualify to be registered in the local government register of electors as they are not disqualified from voting in local government elections.3

A full list of members of the House of Lords can be found on the House of Lords website. Alternatively, the Information Office at the House of Lords will be able to assist with enquiries by email or can be contacted by telephoning 0800 223 0855 or 020 7219 3107.

Detained convicted prisoners

Detained convicted prisoners who are serving a sentence of more than 12 months and who have been found guilty of an offence (excluding contempt of court) and are detained (except for detention in consequence of non-compliance with a non-custodial sentence) are not legally capable of voting and therefore not eligible to be included in the register of electors. This applies whether the person is in prison or unlawfully at large.4

It is possible in some limited circumstances, convicted prisoners who are released on temporary licence may meet the criteria to register to vote, given that such prisoners may not be detained within the meaning of section 3 RPA 1983.

Convicted offenders detained in a mental health hospital

Convicted offenders that are detained in a mental health hospital (or are unlawfully at large) are not legally capable of voting and therefore cannot be included in the register of electors.5

Persons found guilty of electoral offences

Persons found guilty of:

• the corrupt practice of personation
• found guilty of a corrupt practice relating to applications for postal and proxy votes

are legally incapable of being registered to vote for five years from the date of the conviction or the report of an election court.6

Persons found guilty of:

• knowingly voting or applying to vote when subject to a legal incapacity to vote
• knowingly appointing a proxy who is subject to a legal incapacity to vote
• knowingly voting as proxy on behalf of someone who is subject to a legal incapacity to vote
• multiple voting (both as an elector or a proxy)

are legally incapable of being registered to vote for three years from the date of the conviction or election court report:7

There may be some occasions where a court does not impose any further incapacity to register to vote or mitigates or ends any existing incapacity. You will therefore need to make a determination on a case-by-case basis, having regard where possible to any judgments or court reports. A successful appeal against a conviction would also remove the legal incapacity.

How does mental capacity affect the right to register to vote?

A lack of mental capacity is not a legal incapacity to vote.1 Persons who meet the other registration qualifications are eligible for registration regardless of their mental capacity.

Voting rights

While electors with any level or no level of mental capacity may be registered to vote, the decision as to whether and how to vote at an election must be made by the elector themselves and not by any other person on their behalf. Those who care for or who otherwise make decisions on behalf of a person may not make decisions on voting.

For more information on the registration of patients in mental hospitals see our guidance.

Special category electors

Special arrangements apply to some electors, including those who do not meet the usual residence qualification.    

These are:

• overseas electors, i.e. British citizens living outside the UK
• HM forces service voters (and their spouses or civil partners)
• people under 18 years old and living with a parent or guardian who is a member of HM forces. They must be living in Scotland or would be living in Scotland if their parent or guardian were not based overseas
• Crown servants and British Council employees (and their spouses or civil partners)
• people under 18 years old and living with a parent or guardian who is a Crown servant or British Council employee serving abroad provided they would be living in Scotland if their parent or guardian were not based overseas
• electors who have a declaration of local connection, who include people living in the UK but who have no permanent address or fixed address 
• people under 16 who are, or have been, looked after by a local authority or are currently being kept in secure accommodation (they must have previously resided at an address in Scotland)
• anonymously registered electors, i.e. those who can register anonymously because their safety would be at risk if they appeared on the register using their name
• patients in mental health hospitals whose stay at the hospital is sufficient for them to be regarded as resident there
• remand prisoners whose stay at a penal institution is sufficient for them to be regarded as resident there
• prisoners convicted to a term of 12 months or less, who cannot register as a local government elector at their previous address and who make a declaration of local connection

As well as providing the same information as ordinary electors in their application to register, they must provide additional specific information, through a declaration, to register as a special category elector.

ITR Reminders

The duty to send a second and third invitation to non-responding new potential electors and the duty to make at least one personal visit does not apply where someone has made an application1 :

• under Section 7(2) or 7A(2) of the RPA 1983 
• by making a declaration of local connection, service declaration or overseas elector’s declaration 
• to register anonymously

Data protection

Data protection legislation requires you to have a policy document in place when processing special categories of personal data, which includes nationality data received as part of an application to register.

We have produced guidance on the requirement to have a policy document when processing special categories of personal data, including what it must contain.

British citizens (which includes eligible Irish citizens and citizens of the Crown Dependencies)1 may register as overseas electors if they are now living abroad, providing they are: 

• a person who was previously registered to vote in the UK, either before they left the UK or as an overseas elector – known as the previously registered condition
• a person who was previously resident in the UK (including those who left the UK before they were old enough to register to vote) – known as the previously resident condition

Applicants must apply to register as an overseas elector in respect of the address where they were last registered to vote in the UK2 or if they have never been registered, the last address at which they were resident in the UK.

Previously registered condition

An applicant must use the previously registered condition if they have at any point been previously registered to vote in the UK.

If an applicant has been previously registered at more than one address, they should apply in respect of the one they were most recently registered at. 

If an applicant was previously registered in respect of more than one address simultaneously then the elector must pick which one of those addresses to register in connection with.

Examples of individuals who may be eligible to register under this condition include:

• a person who, before they left the UK, was registered to vote as an ordinary elector
• a person who has previously been registered as an overseas elector and whose declaration has expired 
• a person who left the UK but who was on a local government register in Scotland as an attainer or pre attainer
• a person last registered on the basis of a declaration of local connection, merchant seaman or a service voter

Previously resident condition

To be eligible under the previously resident condition an applicant must have been previously resident3 in the UK but never been registered. This includes:

• a person who was resident in the UK but not registered
• a person who was too young to register when they left the UK
• a person who was of no fixed abode when they left the UK and who would have been eligible to make a declaration of local connection or who left the UK before 2001 (when declaration of local connection provisions were not in force)

An application to register as an overseas elector must contain all the following:

• the applicant’s full name1
• the applicant’s date of birth or, if they are unable to provide this, the reason why and a statement as to whether the applicant is under 18 years old2
• the applicant’s National Insurance number or, if they are not able to provide this, the reason they are not able to do so3  
• an indication of whether their name should be omitted from the edited register4
• if the application is accompanied by an application for an anonymous entry, a statement of that fact5
• a declaration that the contents of the application are true6
• the date of the application7
• the appropriate declaration (the details of the content of the declaration are listed below)

The declaration must include:8

• the full name of the person making the declaration9
• the applicant’s present address (to be used for correspondence)10
• a statement that the applicant is a British citizen11
• a statement that the applicant is not resident in the UK on the date of the declaration12
• a statement as to whether the applicant is seeking to be registered based on the previous registration condition or the previous residence condition13
• a statement that the applicant believes the matters stated in the declaration to be true14
• if they have a British passport which describes their national status as a British citizen, the number, date and place of issue of that passport – even if that passport has expired15
• if they do not have such a passport but were born in the UK before 1 January 1983, a statement of that fact16
• if they do not have such a passport and were not born in the UK before 1 January 1983, a statement of when and how they acquired British citizenship, together with the date, place and country of their birth17
• the date of the declaration18

If an applicant's has a correspondence address that is different from their present address they may provide both addresses in their declaration. You may maintain a record of both the present and correspondence address but only the present address is published on the list of overseas electors.  For more information, see our guidance on How should overseas electors be listed in the register?

A declaration received later than three months after it is dated must be rejected.19 The applicant should be informed and invited to submit a fresh declaration.

Depending on the qualifying condition the applicant is applying under, the application must contain additional information stating whether the declarant is seeking to be registered based on the previous registration condition or the previous residence condition as appropriate.

Applicants using the previously registered qualifying condition

If the applicant is using the previously registered qualifying condition, the application must also include the following:

• the last UK address at which they were registered20
• when they were last included on a register there21
• a statement that the applicant’s entry in that register ceased to have effect and that they have not been included in any electoral register since (whether in respect of that or any other address)22
• if they have changed their name since they were last registered, their previous name and the reason for the change of name23
• an indication if the applicant was previously registered via:24
  • an overseas elector’s declaration
  • a service declaration
  • a declaration of local connection

If an applicant states on their declaration that they were simultaneously registered in respect of two addresses before they left the UK, you should advise the applicant to nominate one of these as part of their application to register.

Applicants using previously resident qualifying condition

If the applicant is using the previously resident qualifying condition, the application must also include the following:

• the last UK address at which they were resident25
• when they were last resident there26
• a statement that since being resident at that address, the applicant has not been resident at any other address in the UK27
• if they have changed their name since they were last resident, their previous name and the reason for the change of name28   
• if they were younger than 18 when they left the UK29 (the applicant may provide documentary evidence or information as evidence as part of their declaration)29

If the applicant is using the previously resident qualifying condition, on the basis that they could have made a declaration of local connection in respect of an address30 the following information must be included in the declaration:

• the address in respect of which the applicant could have made a declaration of local connection on the last day on which the applicant was resident32
• a statement as to which category of declaration of local connection applied33 and, if the category of declaration of local connection was as a mental health patient, the name and address of the hospital34
• if they have changed their name since they were last resident at the address at which they could have made a declaration of local connection, their previous name and the reason for the change of name.35
   

For an applicant to qualify to register under this condition they must have been previously registered to vote in the UK and are required to provide the address in respect of which they were last registered. This is in addition to the need to verify the applicant’s identity.

You must be satisfied that the applicant was previously registered at the address they have provided.1 In most instances, this will involve checking previous registers where these are held, either digitally or in hard copy. Retaining historical registers for as long as is practicable will assist you with undertaking such checks of applicants’ previous registration.

Checking electoral registers

The applicant will have provided a date that they were last registered as part of their declaration.

If an applicant has recently moved overseas the current register can be checked to find their registration entry. However if an applicant left the UK some time ago, and you hold historical registers in an easily accessible format or location, you should check whether the applicant was on the relevant register. 

An applicant’s declaration may contain other information that can assist you to locate their previous registration. For example, if the applicant was last registered as an overseas elector, service voter or via a declaration of local connection, they may be listed in a distinct part of the register.

A person may qualify under the previous registration condition even if they were only registered for local elections or as an attainer, so you should ensure that you check all the registers you hold, not just the parliamentary register. 

Information that an applicant has changed their name since they were last registered may also assist you in identifying the previous registration of the applicant more easily.

You should check registers either side of the date the applicant claims that they were last registered, to cover the possibility that the applicant may have supplied the wrong date.

If you cannot find the applicant’s entry, you cannot confirm that they were previously registered. You should consider this as evidence that the person is not eligible to register under the previously registered condition as they have applied in respect of an address which they were not registered at, and reject the application on that basis.

If the applicant has ever been previously registered at any other address (or addresses) in the UK, you should advise the applicant to make another application using their next most recent address. If their next application is rejected on the basis that they were not on the register, they can continue to make applications at the next most recent address(es) where they may have been registered, working backwards chronologically. If the applicant has no more addresses at which they were previously registered, they may then apply to register on using the previously resident criteria. 

You should consider how accessible older copies of the register are, especially those that are from before the 15-year period relevant to the previous overseas elector registration rules.

When is it not feasible to use electoral registers to check an applicant’s qualification to register under the previously registered condition?

It may not always be feasible to check electoral registers, for example:

• the applicant left the UK a long time ago and you are unable to access the relevant register or you no longer hold it because it is stored offsite and/or archived or it is held outside the EMS in an inaccessible format 
• if the time and/or cost of doing so would significantly affect the ERO’s ability to complete other duties which may adversely impact other applicants and electors

Next steps if you are unable to use electoral registers to check an applicant’s qualification under the previously registered condition

You should not take a decision to reject an application based solely on a register check not being feasible.

If you are unable to check electoral registers, you can choose to use other information available to you to assist you in being satisfied that the applicant meets the previously registered condition.

These include:

• using the result of the automated match against DWP records
• checking other locally-held records
• using any documentary evidence provided by the applicant at the time of application, or requesting evidence where it hasn’t already been provided 

If after you have carried out the checks of other information available, you remain unable to be satisfied that the applicant meets the previously registered condition, you can choose to either:

• review your decision relating to the feasibility of checking electoral registers 
• reject the application
• consider any exceptional circumstances

There may be exceptional circumstances where an applicant is unable to provide you with documentary evidence to support their application and is also unable to provide an attestation. 

In these circumstances, you should ask the applicant for an explanation as to the specific reasons why they are unable to provide you with the evidence or attestation. If you are satisfied with the explanation given, you may consider the information included in an applicant’s declaration is sufficient evidence that they meet the previously registered condition, given that you have attempted, but been unable to, obtain either documentary evidence or an attestation from the applicant.

You should be sure you have taken all the steps available to you before taking a decision to reject an application. 
 

This section applies where an applicant was either:

• previously registered via a declaration of local connection1
• on the last day on which the person was resident in the UK, they were not resident at an address but could have made a declaration of local connection in respect of such an address2

If after requiring the applicant to provide documentary evidence, you remain unsatisfied that an applicant was or could have been previously entered in an electoral register via a declaration of local connection in respect of the relevant address, because either:

• the applicant has been unable to provide a document from the list of acceptable evidence3  that must be accepted
• you have received alternative documents that meet the evidential requirement but you remain unsatisfied

you can require the applicant provides either:

• additional documentary evidence
• an attestation of local connection made by a qualifying attestor

Additional documentary evidence

This evidence must be either a copy (or original) of any documents which:

• show the full name of the applicant4
• confirms that the applicant met the local connection requirement5   

Attestation of local connection

Alternatively, the applicant may supply an attestation of local connection from a qualifying attestor which must:6

• confirm the basis on which the applicant met the local connection requirement7
• give an indication of the dates between which, to the best of the qualifying attestor’s knowledge, the applicant met the requirement8  

The local connection requirement is that the applicant was registered via a declaration of local connection because they were:

• a person of no fixed abode
• a patient in a mental health hospital whose stay at the hospital was sufficient for them to be regarded as resident there
• a remand prisoner whose stay at a penal institution was sufficient for them to be regarded as resident there

Attestation of relevant address connection

If you remain unsatisfied after requesting additional evidence or attestation of local connection from a qualifying attestor, you may require the applicant to make an attestation of relevant address connection.9

The attestation of relevant address connection must include:

• confirmation that the applicant met the relevant address connection requirement
• an indication of the dates between which, to the best of the qualifying attestor’s knowledge, the applicant met the requirement

The attestation of relevant address connection requirement is:10

• that the applicant would have been residing at the relevant address if the applicant had not been a patient or detained
• that the relevant address was, or was nearest to, a place in the UK where the applicant commonly spent a substantial part of their time (whether during the day or at night)

Our guidance on Address attestations has more information on the requirements of an attestation.

HM forces service voters

A member of HM forces and their spouse or civil partner may register as a service voter, although they may choose in certain circumstances to make a registration application as an ordinary elector instead.1

A member of HM forces is a person serving on full pay the naval, military or air forces of the Crown raised in the UK.

A person who is under 18 years old and living with a parent or guardian who is a service voter is also eligible to register as a service voter at local government and Scottish Parliamentary elections.2 They must be living in Scotland or would be living in Scotland if their parent or guardian were not based overseas.

The following do not qualify as an HM forces service voter:3

• persons serving only as a member of a reserve or auxiliary force (except those serving during a period of emergency)
• members of the regular army required, by the terms of their service, to serve in Northern Ireland only

When a person is not qualified to be a service voter for one of the reasons listed above, and is away from a UK address at which they have been residing, they can still be deemed to be resident there. They may therefore be registered as an ordinary elector if outside the UK on duty.4

Service Unit Registration Officers

Each unit has designated one member of staff to be a Unit Registration Officer (URO) and each base commander has been asked to give assistance to the URO and other personnel in their unit to promote participation in the electoral process. A Unit could be a base, ship, depot, barracks etc.

The responsibilities of the URO include providing information to service personnel and their families and acting as a liaison between the unit and local EROs.

Where you have any military establishments in your area you should make contact with the UROs. If any problems occur with the registration of service personnel you should raise these issues with the URO of the unit in the first instance. It should now be possible for you to contact a URO in any location, including overseas. To ascertain who the URO is for any particular unit, the Ministry of Defence recommends contacting the unit directly, initially through directory enquiries, and then asking for information about the URO from:

• Royal Navy – First Lieutenant’s office
• Army – Adjutant’s office
• RAF – OC PSF (Officer Commanding Personnel Services Flight)

Registration of HM forces service voters who are qualifying Commonwealth citizens

A service declaration must state the address where the applicant is living in the UK or, if they are living abroad because of their service, where they would have been living in the UK but for their service abroad. If they cannot give such an address, they must give an address at which they have lived in the UK.5

Qualifying foreign nationals who have been recruited to the services in their country of origin or outside the UK without previously being resident in the UK, but who receive their training in the UK and are then immediately posted overseas may register at:

• the address of the barracks where they were enlisted and/or did their training
• a barracks where they were or would be resident if they were not posted abroad
• their regimental headquarters where they may have been resident
• an address in the UK where they would be resident were they no longer in the forces or not required to be resident in barracks, such as a relative’s address
   

What must be included in an application from a member of HM forces?

An application to register as an HM forces service voter must contain all of the following:1

• the applicant’s full name
• their correspondence address or British Forces Post Office (BFPO) number
• any address where the applicant has ceased to reside in the 12 months prior to the date of the application and, where that address is not in the UK, an indication of whether registered as an overseas elector during this period
• an indication of whether the applicant is resident at any other address, including any address where the applicant is currently registered and claims to be entitled to remain registered
• the applicant’s date of birth or, if unable to provide this information, the reason why they are unable to do so and a statement as to whether as to whether the applicant is aged 16 or 17 or aged 18 or older2
• the applicant’s National Insurance number or, if they are not able to provide this, the reason they are not able to do so. This does not apply where the applicant is under 16 years old
• the applicant’s nationality or nationalities or, if they are not able to provide this information, the reason they are not able to do so
• an indication of whether their name should be omitted from the edited register. The details of any person under 16 years old must not be included in any version of the published register, including the edited register
• a declaration that the contents of the application are true
• the date of the application
• the appropriate declaration  

The application form must also provide space for their most recent previous name3 (if they have one) and an explanation that providing this information is not mandatory but may help in verifying their identity and that if it is not provided, additional personal information may be required.

An HM forces service declaration must state:4  

• the date of declaration 
• the applicant’s full name and address
• that on that date the applicant is, or but for the circumstances entitling that person to make the declaration would have been, residing in the UK. In relation to an application from a person under 18 years old who is living with a parent or guardian who is a member of HM forces, the address the person is, or would have been residing in, or at which they have resided, must be an address in Scotland
• the address where the applicant is, or would have been residing in the UK, or if they cannot give any such address, an address at which they have resided in the UK. In relation to an application from a person under 18 years old who is living with a parent or guardian who is a member of HM forces, the address the person is, or would have been residing in, must be an address in Scotland
• that on the date of the declaration the applicant is a qualifying foreign national or, a citizen of the Republic of Ireland
• whether the applicant had on the date of the declaration attained the age of 18 years and, if they had not, their date of birth
• the grounds on which a service qualification is claimed
• information relating to the service in which they or the person entitling them to make the application serve (whether naval, military or air forces), their rank and service number  

How should an application from a member of HM forces be processed?

Acknowledging applications

There is no legal requirement for an application to be acknowledged although you do have discretion to send an acknowledgement if you wish. In all cases, you are required to send a confirmation if the application is successful, as set out below.

Verifying applications

All applications and declarations should be processed and the applicant’s identity verified as soon as possible after receipt.

If you receive an application where the qualifying address falls outside your area you should forward it to the relevant ERO without delay.

Members of the armed forces whose personal identifiers fail the DWP match must provide an attestation as to their identity

You must write to the applicant informing them that it has not been possible to verify their identity and ask them to supply an attestation.
 
You may wish to create a form which contains the necessary legal statements and requirements for the attestation. Alternatively, you may wish to set this detail out in the letter to the applicant. In all cases, you must communicate the legislative requirements for an attestation.1
 
The attestation must:

• be in writing
• confirm that the applicant is the person stated in the service voter’s application
• be signed by an officer of the armed forces who is not the spouse, parent, grandparent, brother, sister, child or grandchild of the applicant
• state the full name, address and rank of the person signing the attestation and the service (whether naval, military or air forces) in which the attestor serves
• state the date on which it is made

Persons attesting armed forces applications do not have to be registered to vote and may attest an unlimited number of applications.

You may wish to set a deadline date for the applicant to respond; this will be helpful when deciding to reject an application because no response has been received. The time given to applicants to respond is at the discretion of the ERO; however, it should allow the applicant reasonable time to source and return their attestation, bearing in mind that armed forces electors may be deployed to overseas locations.

Spouses or civil partners of members of the armed forces whose personal identifiers fail the DWP match must provide documentary evidence in support of their application

You must write to the applicant informing them that it has not been possible to verify their identity and asking them to supply documentary evidence. This must be a copy of the information / photograph page of their passport or both sides of their EEA identity card, certified by an officer of the armed forces who is not the applicant’s spouse or civil partner.
 
You may wish to set a deadline date for the applicant to respond; this will be helpful when deciding to reject an application because no response has been received. The time given to applicants to respond is at the discretion of the ERO; however, it should allow the applicant reasonable time to source and return their attestation, bearing in mind that armed forces electors may be deployed to overseas locations.  

Children of members of the armed forces whose personal identifiers fail the DWP match must provide documentary evidence in support of their application

Where an application as a service voter is made by a person under 18 years old for the purpose of registering in the local government register, and that person's identify cannot be verified by education records or other local data, you should ask them to supply a copy of the information / photograph page of their passport or both sides of their EEA identity card, certified by an officer of HM Forces who is not the applicant's parent, guardian, spouse or civil partner.

Confirming applications and declarations

If you have determined an applicant is entitled to be registered, you must confirm to them in writing that their registration application has been successful.2 2
 
You should also include alongside the confirmation letter, information on any absent voting arrangements that are in place. If no arrangements are in place you should make clear what the absent voting options are. 

If you have rejected a registration application, you must notify the applicant and inform them of the reasons why.3  

Where an existing HM forces elector has successfully renewed their declaration, there is no requirement to send them a confirmation notice. You may, however, still decide to confirm their renewal has been successful, which you could do by e-mail. This communication could also include information on when their declaration will expire, how and when they will next be reminded to renew it, what absent voting arrangements they have in place and, if they have none, information on absent voting options.

You should make the elector aware of the general timings for dispatching postal votes ahead of an election and could advise the elector to appoint a proxy as an alternative if it is not realistic for their postal ballot pack to be dispatched, completed and returned before the close of poll. It is, of course, the elector’s choice as to which method of voting they prefer, but it is important that they can make an informed decision. Further information can be found in our guidance on absent voting. 
 

How should HM forces service voters be listed in the register?

Service voters either living at their qualifying address, or who would be living there were it not for the fact that they were stationed elsewhere because of their employment in the services, must be shown in the main body of the register, in the same way as ordinary electors.
 
HM forces service voters should only be listed as other electors when they no longer have a connection to their qualifying address other than the fact that they once lived there.1  

Their names are to be listed in alphabetical order at the end of the relevant polling district beneath the ‘other electors’ heading. The entry will show their name and elector number but not their address.2  

As set out in eligibility to register, the parliamentary and local government registers are combined. The combined register will need to make clear the date on which those included on it that are under 18 years of age will become 18 years old in order to clearly show their eligibility to vote in different elections.

No information on those aged under 16 must be included on any version of the register published or otherwise made available, except in very limited circumstances. For further information, see our guidance on access and supply.

The entry in the combined registers of any person who is registered only as a local government elector by virtue of being a qualified foreign national must give an indication of that fact.
 

How long are service declarations valid for?

A service declaration for members of HM forces or their spouse or civil partner is valid for five years.1 Registrations can be removed earlier in the following circumstances:2  

• cancellation by the elector 
• you determine the person is not entitled to be registered
• you determine the person was registered, or their entry was altered, as a result of an application made by another person (i.e. not the individual whose details are provided on the application and who has declared that the information provided is true)
• if another entry is made in respect of the elector in any register of electors 

For guidance on removing an elector from the register, see our guidance on deletions.
 
A service declaration received later than three months after it is dated must be rejected.3 The applicant should be informed and invited to submit a fresh declaration.

A service voter may cancel their declaration at any time.4 The cancellation of a service declaration will cancel any absent voting arrangement made in connection with that declaration even if the elector registers as an ordinary elector at the same qualifying address.

Service voters aged under 18
 

A person who is under 18 years old who is registered as a service voter because they live with a parent for guardian who is a member of HM forces must renew their registration every year.5

They will cease to be registered as a service voter when they are 18 years old. Our guidance on renewal of service declarations cover renewal process for those aged under 18.

Renewal of service declarations

A person registered as an HM forces service voter is entitled to remain registered, provided the elector continues to satisfy the other conditions for registration, until the end of the five year period beginning with the date when the entry first takes effect. You should make contact with the HM forces service voter during this five year period to ensure that their registration and voting arrangements remain current.

You will need to maintain a record showing when reminders are due to be sent. 

You must remind every service voter of the need to make a fresh declaration if they wish to remain registered.1 The reminder must be sent between 57 and 58 months after the date when the service entry first takes effect2 and should include a new declaration for the service voter to complete. If you do not receive a fresh declaration, you are required to send a second reminder not less than 21 days and not more than 28 days after sending the first reminder.3  

Reminders must not be sent where you have received information that the person is no longer entitled to make the relevant declaration or no longer wishes to be registered as a service voter.4
 
Where a declaration is not renewed within the five year period and the person is removed from the register, they will also lose any absent voting arrangement they had in place.  

Further information about notifying electors of loss of entitlement to absent voting arrangements can be found in our guidance on absent voting.

Service voters aged under 18

A person who is under 18 years old who is registered as a service voter because they live with a parent or guardian who is a member of HM forces must renew their registration every year5 .

You should send a reminder of the need to make a fresh declaration if they wish to remain registered as a service voter, and include a declaration for them to complete. The reminder should be sent between 9 and 10 months after the date when the entry first takes effect. You should send a second reminder to let them know that their declaration is about to expire if they have not responded to the first reminder. This second reminder should be sent not less than 21 days and not more than 28 days after sending the first reminder. You will need to maintain a record showing when reminders are due to be sent.

Furthermore, they will cease to be registered as a service voter when they are 18 years old. You must issue a reminder to the elector stating that their registration will cease when they are 18 years old, and this reminder must be issued within the period of three months ending when the person attains the age of 18. They will need to make a new application to register reflecting their circumstances at that time.

Crown servants and British Council employee service voters

Crown servants and British Council employees abroad and their spouse or civil partner accompanying them can be registered at any time as service voters1 – although they may choose in certain circumstances to make a registration application as an ordinary elector instead. 

A Crown Servant is a person employed in the service of the Crown in a post outside the UK. They are required to devote the whole of their working time to the duties of that post, and their remuneration is paid wholly out of money provided by Parliament.2

However, spouses and civil partners who are themselves in the UK do not qualify for this type of registration.3  

A person who is under 18 years old and living with a parent or guardian who is a Crown servant or British Council employee serving abroad is also eligible to register as service voter provided they would be living in Scotland if their parent or guardian were not based overseas4 .
 

What must be included in an application from a Crown servant or British Council employee?

An application to register as a service voter must contain all of the following:1  

• the applicant’s full name
• their correspondence address
• any address where the applicant has ceased to reside in the 12 months prior to the date of the application and, where that is not in the UK, an indication of whether that person was registered as an overseas elector during this period
• an indication of whether the applicant is resident at any other address, including any address where the applicant is currently registered and claims to be entitled to remain registered
• the applicant’s date of birth or, if unable to provide this information, the reason why they are unable to do so and a statement as to whether the applicant is under the age of 16, aged 16 or 17 or aged 18 or older2
• the applicant’s National Insurance number or, if they are not able to provide this, the reason they are not able to do so. This does not apply where the applicant is under 16 years old
• the applicant’s nationality or nationalities or, if they are not able to provide this information, the reason they are not able to do so 
• an indication of whether their name should be omitted from the edited register. A person under 16 years old is automatically opted out of the edited register. The details of any person under 16 years old must not be included in any version of the published register, including the edited register
• a declaration that the contents of the application are true
• the date of the application
• the appropriate declaration

The application form must also provide space for their most recent previous name3 (if they have one) and an explanation that providing this information is not mandatory but may help in verifying their identity and that if it is not provided, additional personal information may be required.

Their service declaration must state:4  

• the date of declaration 
• the applicant’s full name and address
• that on that date the applicant is, or but for the circumstances entitling that person to make the declaration would have been, residing in the UK. In relation to an applicant for a person under 18 years old who is living with a parent or guardian who is a Crown servant for British Council employee serving abroad, the address the person would have been residing in, must be an address in Scotland
• the address where the applicant is, or, would have been residing in the UK, or if they cannot give such an address, an address at which they have resided in the UK. In relation to an applicant for a person under 18 years old who is living with a parent or guardian who is a Crown servant for British Council employee serving abroad, the address the person would have been residing in, must be an address in Scotland
• that on the date of the declaration the applicant is a qualifying foreign national or , a citizen of the Republic of Ireland
• whether the applicant had on the date of the declaration attained the age of 18 years and, if they had not, their date of birth
• the grounds on which a service qualification is claimed
• information relating to their job (or the person’s job who entitles them to make the application) must be declared as shown in the table below:

The declaration made by Crown servants and British Council employees does not need to be sent via their employer, which means that Crown servant and British Council employees can complete the registration process online.5

How should an application and declaration from a Crown servant or British Council employee be processed?

Acknowledging applications

There is no legal requirement for an application to be acknowledged although you do have discretion to send an acknowledgement. In all cases, you are required to send a confirmation if the application is successful, as set out below.

Verifying applications

All applications and declarations should be processed and the applicant’s identity verified as soon as possible after receipt. 

If you receive an application where the qualifying address falls outside your area it should be forwarded to the relevant ERO without delay.

Potential Crown servants, British Council employees or their spouses or civil partners who fail the DWP match must provide documentary evidence in support of their application.  

You must write to the applicant informing them that it has not been possible to verify their identity and asking them to supply documentary evidence. This must be a copy of the information / photograph page of their passport or both sides of their EEA identity card, certified by a Crown servant or British Council employee who is not the applicant’s spouse or civil partner. 

Where an application as a service voter is made by a person under 18 years old for the purpose of registering in the local government register, and that person's identity cannot be verified by education records or other local data, you should ask them to supply a copy of the information / photograph page of their passport or both sides of their EEA identity card, certified by a Crown Servant or British Council employee who is not the applicant's parent, guardian, spouse or civil partner.

You may wish to set a deadline date for the applicant to respond; this will be helpful when deciding to reject an application because no response has been received. The time given to applicants to respond is at the discretion of the ERO; however, it should allow the applicant reasonable time to source and return their attestation, bearing in mind that some electors may be deployed to overseas locations.

Declaration requirements

The declaration must contain all the required information for it to be considered duly made.1

If the declaration does not meet with the requirement, you shall return the declaration to the applicant and explain what information is missing.2

Confirming applications and declarations

If you have determined that an applicant is entitled to be registered, you must confirm to them in writing that their registration application has been successful.3   

You should also include, alongside the confirmation letter, information on any absent voting arrangements that are in place. If no arrangements are in place you should make clear what the options are. 

If you have rejected a registration application, you must notify the applicant and inform them of the reasons why.

Where an existing service voter has successfully renewed their declaration, there is no requirement to send a confirmation notice. You may, however, still decide to send them further information confirming that their renewal has been successful, which you could do by e-mail. This communication could also include information on when their declaration will expire, how and when they will next be reminded to renew it, what absent voting arrangements they have in place and, if they have none, information on absent voting options.

You should also make the elector aware of the general timings for dispatching postal votes ahead of an election and could advise the elector to appoint a proxy as an alternative if it is not realistic for their postal ballot pack to be dispatched, completed and returned before the close of poll. It is, of course, the elector’s choice as to which method of voting they prefer, but it is important that electors can make an informed decision. Further information can be found in our guidance on absent voting.
 

How should Crown servants and British Council employee service voters be listed in the register?

Service voters either living at their qualifying address, or who would be living there were it not for the fact that they were stationed elsewhere because of their employment, must be shown in the main body of the register, in the same way as ordinary electors. 

Crown servant and British Council employee service voters should only be listed as other electors when they no longer have a connection to their qualifying address other than the fact that they once lived there.1   

If this is the case then their names are to be listed in alphabetical order at the end of the relevant polling district of the register beneath the ‘other electors’ heading. The entry will show their name and elector number but not their address.2  

As set out in eligibility to register, the parliamentary and local government registers are combined. The combined register will need to make clear the date on which those included on it that are under 18 years of age will become 18 years old in order to clearly show their eligibility to vote in different elections.

No information on those aged under 16 must be included on any version of the register published or otherwise made available, except in very limited circumstances. For further information, see our guidance on access and supply.

The entry in the combined registers of any person who is registered only as a local government elector by virtue of being a qualifying foreign national must give an indication of that fact.
 

How long are service declarations for Crown servants and British Council employees valid for?

A service declaration for Crown servants, British Council employees, or their spouse or civil partner is valid for 12 months.1 Registrations can be removed earlier in the following circumstances:2  

• cancellation by the elector 
• you determine the person is not entitled to be registered
• you determine the person was registered, or that their entry was altered, as a result of an application made by another person (i.e. not the individual whose details are provided on the application and who has declared that the information provided is true)
• if another entry is made in respect of the elector in any register of electors 

For guidance on removing an elector from the register, see our guidance on deletions.

A declaration received later than three months after it is dated must be rejected.3 The applicant should be informed and invited to submit a fresh declaration.

A service voter may cancel their declaration at any time.4 The cancellation of a service declaration will cancel any absent voting arrangement made in connection with that declaration even if the elector registers as an ordinary elector at the same qualifying address. 
 

Service voters aged under 18

A person who is under 18 years old who is registered as a service voter because they live with a parent or guardian who is a Crown servant or British Council employee serving abroad must renew their registration every year.5

They cease to be registered as a service voter when they are 18 years old. Our guidance on renewal of service declarations cover the renewal process for those aged under 18.

Renewal of Crown servant and British Council employee service declarations

A Crown servant or British Council employee is entitled to remain registered provided the elector continues to satisfy the other conditions for registration during this period until the end of the 12 month period beginning with the date when their entry first takes effect. 

You will need to maintain a record showing when reminders are due to be sent.
 
You must remind every service voter of the need to make a fresh declaration to remain registered as a service voter.1 The reminder must be sent between 9 and 10 months after the date when the service entry first takes effect2 and should include a declaration for the service voter to complete.

If you do not receive a fresh declaration, you are required to send a second reminder not less than 21 days and not more than 28 days after sending the first reminder.3  

Reminders must not be sent where you have received information that the person is no longer entitled to make the relevant declaration or no longer wishes to be registered as a service voter.4
 
Where a declaration is not renewed within the 12 month period and the person is removed from the register, they will also lose any voting arrangement they had in place.

Further information about notifying electors of loss of entitlement to absent voting arrangements can be found in our guidance on absent voting.
 

Service voters aged under 18

A person who is under 18 years old who is registered as a service voter because they live with a parent or guardian who is a Crown servant or British Council employee serving abroad, must renew their registration every year.5

You should send a reminder of the need to make a fresh application if they wish to remain registered as a service voter, an include a declaration for them to complete. The reminder should be sent between 9 and 10 months after the date when the entry first takes effect. You should send a second reminder to let them know that their declaration is about to expire if they have not responded to the first reminder. This second reminder should be sent not less than 21 days and not more than 28 days after sending the first reminder. You will need to maintain a record showing when reminders are due to be sent.

Furthermore, they will cease to be registered as a service voter when they are 18 years old. You must issue a reminder to the elector stating that their registration will cease when they are 18 years old, and this reminder must be issued within the period of three months ending when the person attains the age of 18. They will need to make a new application to register reflecting their circumstances at that time.

Declarations of local connection

A person who does not have a fixed or permanent address may register at the place where they spend most of their time, or to which they have a local connection,1 by making a declaration of local connection.

Our guidance on eligibility to register sets out in detail who can make a declaration of local connection.
 

There is an additional ground to make a declaration of local connection for those under 16 years old if they are, or have been, looked after children or are currently being kept in secure accommodation.2 Local authorities in Scotland have a duty to promote awareness of how to register as local government electors for children that are "looked after" and to provide assistance to help such young people to register. For further information about this duty, see can someone register without a fixed address?

What must be included in an application made by a declaration of local connection? 

An application to register by making a declaration of local connection must include all of the following:1  

• the applicant’s full name
• the address in respect of which the applicant applies to be registered
• any address where the applicant has ceased to reside in the 12 months prior to the date of the application and, where that address is not in the UK, an indication of whether that person was registered as an overseas elector during this period.
• an indication of whether the applicant is resident at any other address, including any address where the applicant is currently registered and claims to be entitled to remain registered
• the applicant’s date of birth or, if unable to provide this information, the reason why they are not able to do so and a statement as to whether the applicant is under the age of 16, aged 16 or 17 or aged 18 or older2  
• the applicant’s National Insurance number or, if they are they are not able to provide this, the reason they are not able to do so. This does not apply where the applicant is under 16 years old
• the applicant’s nationality or nationalities or, if they are not able to provide this information, the reason they are not able to do so
• an indication of whether the applicant requests their name to be omitted from the edited register. A person under 16 years old is automatically opted out of the edited register. The details of any person under 16 years old must not be included in any version of the published register, including the edited register
• a declaration that the contents of the application are true
• the date of the application
• the appropriate declaration

The application form must also provide space for their most recent previous name3 (if they have one) and an explanation that providing this information is not mandatory but may help in verifying their identity and that if it is not provided, additional personal information may be required.

A declaration of local connection must be signed and dated by the applicant and state:4  

• the applicant’s full name
• the address to which correspondence can be delivered or a statement confirming that they are willing to collect correspondence from the ERO
• the category in which their declaration falls, e.g. mental health patient, remand prisoner or person of no fixed address
• in the case of a person of no fixed address, the address of, or near, a place where they commonly spend a substantial part of their time
• in the case of a prisoner on remand, the name and address of the place where they are detained, as well as the address at which they would be residing if they were not detained. If they are unable to give such an address, an address at which they have previously resided
• in the case of a mental health patient, the name and address of the mental health hospital, as well as the address at which they would be residing if they were not a patient. If they are unable to give such an address, an address at which they have previously resided
• in the case of a prisoner convicted to a term of 12 months or less; who does not have uninterrupted residence and cannot remain registered as a local government elector, the address at which they would be residing if they were not convicted, or another previous address. If they are unable to give such an address, the address of the penal institution where they are detained.5 See can prisoners register to vote for further details on the provisions for Scottish prisoners
• in the case of a person under 16 years old who is or has been a child looked after by a local authority or is being kept in a secure accommodation, an address in Scotland at which they have previously resided6
• that they have attained 18 years of age or, if not, their date of birth.
• that they are a qualifying foreign national or a citizen of the Republic of Ireland

Where a declaration of connection is made by a person under 18 years old for the purposes of registering in the local government register, the address given where they would be living if were not for their current situation, or where they have lived in the past or spend a substantial amount of time, must be an address in Scotland7

At a by-election to the UK Parliament any declaration of local connection made by a homeless person received during the period from the date of the vacancy to the close of nominations must include a statement that the applicant has spent a substantial part of time during the past three months at or near to the address at which they claim to be entitled to be registered.8  

If a person makes a declaration of local connection stating more than one address, or makes more than one declaration on the same date and stating different addresses, the declaration or declarations will be void.9  
 

How should applications made by a declaration of local connection be processed?

Acknowledging applications

There is no legal requirement for an application to be acknowledged although you do have discretion to send an acknowledgement. In all cases, you are required to send a confirmation if the application is successful, as set out below.

Verifying applications

All applications and declarations should be processed and the applicant’s identity verified as soon as possible after receipt.
 
If you receive an application where the qualifying address falls outside your area it should be forwarded to the relevant ERO without delay.

Any applicant who fails the DWP match must provide documentary evidence, or if they cannot provide documentary evidence, an attestation in the same way as people applying to register as an ordinary elector. See our guidance on verification, exceptions and attestations.

All correspondence between you and applicants may be sent electronically. In addition, it is permissible for applicants to provide attestations or documentary evidence by electronic means such as a fax or scanned image.

Where an application through a declaration of local connection is made by a person under 18 years old for the purpose of registering in the local government register, and that person's identity can't be verified by education records or other local data, you should ask them to provide documentary evidence, or if they cannot do so an attestation in the same way as people applying to register as an ordinary elector.

Confirming applications and declarations 

If you have determined that an applicant is entitled to be registered, you must confirm to them in writing that their registration application has been successful.1
 
You should also include, alongside the confirmation letter, information on any absent voting arrangements that are in place. If no arrangements are in place you should make clear what the absent voting options are. 

Convicted prisoners registered as local government electors may only vote by post or proxy,2  so you should make clear what their absent voting options are.

If you have rejected a registration application, you must notify the applicant and inform them of the reasons why.

Where a person who is registered through a declaration of local connection has successfully renewed their declaration, there is no requirement to send them a confirmation notice. You may, however, still decide to send them further information confirming that their renewal has been successful, which you could do by e-mail. This communication could also include information on when their declaration will expire, how and when they will next be reminded to renew it, what absent voting arrangements they have in place and, if they have none, information on absent voting options.
 

How should electors registered by making a declaration of local connection be listed in the register?

All persons registered through a declaration of local connection must be included at the end of each relevant part of the register under the heading ‘other electors’ without an address. Their names are to be included in alphabetical order, grouped together with any service voters and overseas electors, but before any anonymously registered electors.1  

As set out in our guidance on eligibility to register, the parliamentary and local government registers are combined. The combined register will need to make clear the date on which those included on it that are under 18 years of age will become 18 years old in order to clearly show their eligibility to vote in different elections.

No information on those aged under 16 must be included on any version of the register published or otherwise made available, except in very limited circumstances. For further information see our guidance on access and supply.

The entry in the combined registers of any person who is registered only as a local government elector by virtue of being a qualifying foreign national must give an indication of that fact.

How long are declarations of local connection valid for?

A declaration of local connection is valid for 12 months from the date when the entry on the register first takes effect.1 Registrations can be removed earlier in the following circumstances:2  

• cancellation by the elector 
• you determine the person is not entitled to be registered
• you determine the person was registered, or that their entry was altered, as a result of an application made by another person (i.e. not the individual whose details are provided on the application and who has declared that the information provided is true)
• if another entry is made in respect of the elector in any register of electors 
• in the case of prisoners registered as local government electors through a declaration of local connection, although their declaration is valid for 12 months, their restricted franchise only applies for the duration of their detention. However, they must make a new application in order to be added to the register of UK Parliamentary electors, and you should invite them to do so upon their release

For guidance on removing an elector from the register, see our guidance on deletions.

A declaration received later than three months after it is dated must be rejected.3 The applicant should be informed and invited to submit a fresh declaration.

Renewal of declarations of local connection

A person registered through a declaration of local connection is entitled to remain registered until the end of the 12 month period beginning with the date when the entry first takes effect, provided the other conditions for registration remain satisfied.

You will need to maintain a record showing when reminders are due to be sent. You must remind the elector of the need to make a fresh declaration if they wish to remain registered.1 The reminder must be sent between 9 and 10 months after the date when the entry first takes effect2 and should include a declaration for the elector to complete. If you do not receive a fresh declaration, you are required to send a second reminder not less than 21 days and not more than 28 days after sending the first reminder.3  

Reminders must not be sent where you have received information that the person is no longer entitled to make the relevant declaration.4  In the case of a prisoner registered as a local government elector, there is no need to send reminders to renew their declaration.
 
Where a declaration is not renewed within the 12 month period and the person is removed from the register, they will also lose any absent voting arrangement they had in place.

Further information about notifying electors of loss of entitlement to absent voting arrangements can be found in our guidance on absent voting.

You should consider the most appropriate method of obtaining a renewal from those who have registered through a declaration of local connection. It may be appropriate, in addition to simply sending a renewal notice by post, to make a personal visit to ensure the reminder and declaration reaches the elector.
 

Prisoners and detained mental health patients

Some remand prisoners or detained mental health patients may remain registered as ordinary electors if their absence from their home address is limited.

Longer term remand prisoners or mental health patients may register through a declaration of local connection, at an address where they would be living, if it were not for their circumstances, or where they used to live before becoming a remand prisoner or mental health patient.1
 
Some remand prisoners or mental health patients will qualify to register at a place of custody or hospital address, if their length of stay is sufficient.2

Prisoners convicted for a sentence of 12 months or less may remain registered as ordinary electors on the local government register if they are deemed to have uninterrupted residence.3

Otherwise, they may register as local government electors through a declaration of local connection, at an address where they would be living, if it were not for their circumstances, or where they used to live before their detention, or at the penal institution.4

Our guidance on eligibility to register sets out the options that prisoners and patients in mental health hospitals have for registering.
 

Who may apply and how should applications be processed?

Prisoners on remand and patients in mental health hospitals who are registered at their place of custody or hospital must supply the same information as for an ordinary application.1  

Convicted prisoners convicted for a term of 12 months or less who are registering as local government electors at an address where they resided previously and to which they intend and are permitted to return, or a deemed to have continued residence there, are ordinary electors, not special category electors, and must supply the same information as for an ordinary application.2

Acknowledging applications

There is no legal requirement for an application to be acknowledged although you do have discretion to send an acknowledgement. In all cases, you are required to send a confirmation if the application is successful, as set out below.

Verifying applications

All applications and declarations should be processed and the applicant’s identity verified as soon as possible after receipt. 

If you receive an application where the qualifying address falls outside your area it should be forwarded to the relevant ERO without delay.

Any applicant who fails the DWP match must provide documentary evidence, or if they cannot provide documentary evidence, an attestation in the same way as people applying to register as an ordinary elector.

Confirming applications and declarations 

If you have determined that an applicant is entitled to be registered, you must confirm to them in writing that their registration application has been successful.3  

You should also include, alongside the confirmation letter, information on any absent voting arrangements that are in place. If no arrangements are in place you should make clear what the absent voting options are. 

If you have rejected a registration application, you must notify the applicant and inform them of the reasons why.
 

Anonymous registration

Anonymous registration is available to electors whose safety would be at risk if their name or address were listed on the electoral register. Other persons in the same household also qualify to register as anonymous electors and may also apply for anonymous registration if they wish.1

You should consider which establishments or properties, such as refuges, should receive anonymous registration forms and additional information as part of your duty to maintain the register. Registration application forms could be sent with a note explaining what anonymous registration is and how people can apply.

In partnership with Women’s Aid we have produced a guide to anonymous registration for professionals working with survivors of domestic violence.

The guide, which may also be useful to you and your staff, explains what anonymous registration is and that an applicant’s name and address details will be kept securely and will not be searchable on the electoral register. The guide also outlines how to apply for anonymous registration.

There may be circumstances where a returned canvass communication may include a note from a potential elector with a reason that may satisfy the requirements for anonymous registration. An anonymous registration application should then be sent and the person told that others in the household may also be entitled to register anonymously.

Combining anonymous registration with other special category elector entitlement

Anonymous registration does not affect any other special category elector entitlement and can be combined. For example, a person may be an anonymous elector with a local connection or an anonymous service voter, or an anonymous overseas voter if they meet the qualification for both registrations.

What must be included in an application for anonymous registration?

Applicants for anonymous registration must include the following as part of their application for registration:1  

• the applicant’s full name
• the address where the applicant is resident on the date of the application and in respect of which they are applying to be registered 
• where an anonymous application is made by a person under 18 years old for the purposes of registering in the local government register, the address given where the applicant is resident on the date of the application and in respect of which they are applying to be registered, must be an address in Scotland
• any address where the applicant has ceased to reside in the 12 months prior to the date of the application and, where that address is not in the UK, an indication of whether that person was registered as an overseas elector during this period
• an indication of whether the applicant is resident at any other address, including any address where the applicant is currently registered and claims to be entitled to remain registered
• the applicant’s date of birth or, if unable to provide this information, the reason why they are unable to do so and a statement as to whether the applicant is under the age of 16, aged 16 or 17 or aged18 or older2
• the applicant’s National Insurance number or, if they are not able to provide this , the reason they are not able to do so. This does not apply where the applicant is under 16 years old
• the applicant’s nationality or nationalities or, if they are not able to provide this information, the reason they are not able to do so
• a declaration that the contents of the application are true
• the date of the application
• the fact that the application is accompanied by an application for anonymous registration

An application for anonymous registration must be in writing. It must be signed and dated by the applicant and must contain:3  

• the applicant’s full name and address
• the reason for their application
• evidence to support their application (a court document or an attestation as described below)
• if the applicant is someone who lives in the same household as someone whose safety would be at risk, evidence that the applicant lives in the same household as that person. Evidence could be a utility bill, bank statement, photocard driving licence, etc.
• if the applicant is someone who lives in the same household as someone whose safety would be at risk, evidence that that person’s safety would be at risk
• a declaration that: 
  • the evidence to support their application is genuine so far as the applicant is aware
  • if it is someone who lives in the same household, the person to whom the evidence relates lives in the same household and that, as far as they are aware, the evidence is genuine   
  • the other information given is true 

The application form must also provide space for their most recent previous name (if they have one)4 and an explanation that providing this information is not mandatory but may help in verifying their identity and that if it is not provided, additional personal information may be required.

Applicants must be able to satisfy you that their safety or that of any other person in the same household would be at risk if their details were made public.5 Documentary evidence or an attestation must be provided in support of the application.6  

You should not involve yourself in the personal circumstances of applicants and your decisions should only rely on the accompanying documents. You should be satisfied that documents provided in support of an application are genuine.

Anonymously registered electors are entitled to submit a correspondence address which must be used for future registration correspondence if given.7  
 

What documents or attestations must be included with an application for anonymous registration?

The application must be accompanied by either a court order or an attestation.1

Any court order or injunction must be for the protection or the benefit of the applicant or another person of the same household.2 The order must be in force on the day of the application,3 but need not be for the whole 12 month period of registration. An order ceasing to be in force during the 12 month period of registration does not reduce or otherwise affect the length of registration. A copy of any relevant court document is acceptable.4

The eligible court documents are:5

No documents other than these can be used as eligible court documents in support of an application for anonymous registration.

If an attestation is used it must certify that if the name or address were on the register the applicant’s or another member of the same household’s ‘safety would be at risk’.6 Attestations must be in writing and must be signed and dated by a qualifying officer. The period of the attestation begins on the date stated and lasts for a period of between one and five years. The actual length must be stated within the attestation.7

The anonymous registration application form approved by the Lord President of the Council and made available by the Electoral Commission contains a template attestation that applicants may use.

The qualifying officers who may attest are:8

• a police officer of or above the rank of inspector of any police force in the UK 
• the Director General of the Security Service or the National Crime Agency
• a director of adult social services or children’s services in England or a director of social services in Wales
• any chief social work officer in Scotland
• a chief social work officer in Scotland may authorise any person to attest an anonymous registration application for a person aged under 16. The written authorisation from the chief social work officer must accompany the attestation9
• any director of social services of a Health and Social Services Board or executive director of social work of a Health and Social Services Trust in Northern Ireland
• any medical practitioner who is registered with the General Medical Council
• any nurse or midwife who is registered with the Nursing and Midwifery Council
• any person who manages a refuge. A ‘refuge’ means accommodation together with a planned programme of therapeutic and practical support for victims of, or those at risk of, domestic abuse or violence10  

No person other than those listed may attest an application for anonymous registration. It is not possible for a qualifying officer to delegate their power to attest an application to a different person.

The attestation can come from one of the qualifying officers from a different area from which the elector now lives and is registering. This may often be the case where the applicant has moved to a new area to set up home away from the cause of the risk to their safety. For example, an attestation from one English local authority director of children’s services is valid in every local authority area in Great Britain.

You should consider contacting any qualifying officers to alert them to their powers under the anonymous registration process. They may wish to be aware of their attestation powers and any guidance that their representative groups have given on dealing with requests for attestation. In particular, you should proactively contact any refuges, GP surgeries and other medical establishments in your registration area who may not be aware that the types of court order and the attestation requirements have been expanded. For example, you could contact social services, Women’s Aid, or other organisations who work with survivors of domestic abuse, and – explaining what are you doing – ask for details of refuges in your registration area.

In partnership with Women’s Aid we have produced a guide to anonymous registration for professionals working with survivors of domestic violence.

The guide explains what anonymous registration is and that an applicant’s name and address details will be kept securely and will not be searchable on the electoral register. The guide also outlines how to apply for anonymous registration and how refuge managers may provide an attestation if they wish to do so.

If you consider it necessary, you are able to undertake online checks of certain categories of attestor:

• The General Medical Council maintains a list of registered medical practitioners available on their website: www.gmc-uk.org
• The Nursing & Midwifery Council maintains a list of registered nurses and midwives on their website: www.nmc.org.uk

If you have concerns about an application for anonymous registration, it should be treated like any other application for registration. As set out in identifying suspicious registration applications, your local police single point of contact (SPOC) will help you ensure that any possible instances of registration fraud are quickly identified and dealt with. If you have reason to believe that an attestation provided as part of an application for anonymous registration is not genuine, you should contact your SPOC as soon as possible.

How should an application for anonymous registration be processed?

Acknowledging applications

There is no legal requirement for an application to be acknowledged although you do have discretion to send an acknowledgement if you wish. In all cases, you are required to send a confirmation if the application is successful, as set out below.

Verifying applications

Applications should be processed and the applicant’s identity verified as soon as possible after receipt. 

If you receive an application where the qualifying address falls outside your area it should be forwarded to the relevant ERO without delay.

Any applicant who fails the DWP match must provide documentary evidence, or if they cannot provide documentary evidence, an attestation in the same way as people applying to register as an ordinary elector.  See our guidance on verification, exceptions and attestations.

All correspondence between you and applicants may be sent electronically. In addition, it is permissible for applicants to provide attestations or documentary evidence by electronic means such as a fax or scanned image.

Where an application to register anonymously is made by a person under 18 years old for the purpose of registering in the local government register, and that person's identity cannot be verified by education records or other local data, you should ask them to provide documentary evidence, or if they cannot do so, an attestation, in the same way as people applying to register as an ordinary elector.

Anonymous registration application details such as name and address are not added to the lists of applications. Anonymous applications are not available for public inspection at any time.1
 
This means that these applications do not have the same type of public scrutiny as other electoral registration applications. You should therefore be particularly proactive in being satisfied that all the requirements for registration are met.

When an anonymous application is received, all previous ‘ordinary’ applications either awaiting determination or determined but not added to the register for that individual are suspended until the anonymous application is determined. If the anonymous application is rejected, then all pending applications for registration must be disregarded. If the anonymous registration application is rejected, they cannot be added as an ordinary elector.

Confirming applications and declarations

If you determine that an applicant is entitled to be registered anonymously, you must issue a certificate of anonymous registration.2  You must also send them a notice by post, as soon as is reasonably practicable, to inform them that they must have an Anonymous Elector's Document if they want to vote in person at UK parliamentary elections, or sign a signing sheet in person at a recall petition.3  You should also consider confirming any absent voting arrangements that are in place, or if no arrangements are in place you should make clear what their absent voting options are. If a person already has an entry on the register and an anonymous application is accepted, the ordinary register entry must be removed and the anonymous registration added. However, the existing entry must not be removed until the anonymous application is accepted. 

If you have rejected an application, you should notify the applicant and inform them of the reasons why.

The details of a person who has made an application to register anonymously must not be added to the register if the anonymous part of the application fails.4 However, you should encourage them to submit an ordinary registration application and invite them to register. If they do not submit an application in response to an invitation, you may require them to submit an application to register, but you should consider the individual’s particular circumstances before issuing a ‘requirement to register’ notice.

Where a requirement to register is issued to a person under 16 years old, it must not include reference to the civil penalty as a civil penalty cannot be imposed on a person under 16 years old.

How should anonymous electors be listed in the register?

Persons registered anonymously must be included at the end of each relevant part of the register under the heading ‘other electors’ without a name or address. The entry for each anonymously registered elector must consist of their elector number and the letter ‘N’.1
 
Anonymous entries must not be included in the edited register and all anonymous electors are automatically opted out.2  

You must keep a separate list – the record of anonymous entries. This will contain the elector number, full name, qualifying address, correspondence address (if any) and the date that the registration first took effect. If the person has a postal vote, the delivery address must also be kept on the record.3 You should ensure that the list is kept secure and prevent any unauthorised access.

Only the following persons and organisations are entitled to have access to the record of anonymous entries:4

• Returning Officers and referendum Counting Officers
• the security services, including Government Communications Headquarters (GCHQ)
• the police, including the National Crime Agency (at the request of a senior officer, this means an officer a rank senior to that of superintendent, or, in the case of the National Crime Agency, the Director General of that Agency)

When a person is entered in the record, you will need to issue a signed ‘certificate of anonymous registration’. This must state the local authority area, the elector’s name, qualifying address, electoral number and the date on which the registration took effect. It must also state that the registration will end no later than 12 months from that date if a fresh application for anonymous registration is not made.5  

We have produced a template certificate of anonymous registration which you may wish to use.

Absent voting lists 

The absent voting lists for anonymous electors and their proxies, must contain only the elector’s electoral number and the period for which the absent vote is in effect, but not any name or address.6 At an election, the copy of the absent voting lists to enable postal vote issuing and marking the return of postal votes contains only the electoral number.7 The address to which the ballot pack will be sent must not be on that list and all correspondence must be sent in an unidentifiable envelope.8  
 

The content of the ITR is prescribed.1  

Whenever you issue an ITR you must include a paper application form with it.

You must use the application form approved by the Minister for the The Department for Levelling Up, Housing and Communities and made available to you by the Commission and must, if practicable, pre-print on the application form the full name and address of the individual being invited.2

This does not apply if you give the ITR by electronic means.3 In that case the prescribed email ITR includes a link to www.gov.uk/register-to-vote.

The ITR and application form that you must use are available on our website. The prescribed form includes a data protection statement and the prescribed description of the electoral and open registers.  The data protection statement also includes wording covering what happens to data relating to 14 and 15 year olds.

The prescribed email invitation is included in the letters folder, also available on our website. You should always ensure that you are using the latest versions.

Our forms and letters guidance sets out how the application form and letter must be used.  

The forms and letters guidance is available on our website.

If you have given a third invitation and no application to register has been made, you are required by law to make at least one visit to the address for the purpose of encouraging an application to be made.1

You can choose to make a visit at any time in the process, for example, at the same time as delivering any of the invitations. You may, therefore, have met this requirement before the end of the ITR chasing cycle. You must, however, have made a visit specifically for the purpose of encouraging an individual to make an application to register. In our view, this means a visit where you have attempted to make contact personally with the individual you are inviting. 

What constitutes a personal visit?  

A visit made only for the purpose of leaving an ITR and application form at the address with no attempt made to contact the individual being invited would not, in our view, satisfy the requirement. 

The requirement would be fulfilled if the individual making the visit speaks to the individual being invited and encourages them to make an application. 

As with all stages of this process, you should ensure that you keep records for the purpose of having a clear audit trail of the steps that you have taken as part of the ITR process. This will help to ensure that, if you consider requiring an individual to make an application, you are able to establish that the prerequisites for making such a requirement have been met. 

You should, in any case, consider making a further visit if this is likely to result in an application being made.

If no application is made in response to the third invitation and you have made at least one visit to the address, you can move to the next stage of requiring the individual to make an application to register by giving them notice in writing of the requirement.2  

A personal visit to a 14 or 15 year olds who have not responded to an ITR is not required at any time during the year.

If you do not make a visit to the household, you should consider what other mechanism you can use to encourage a response from those in this age group. For example, you could contact under 16s by email if you hold their email address.

Also, as part of any canvass follow-up activity, there may be an opportunity to remind any adults living at an address that 14 and 15 year olds are entitled to register and to ask them to encourage any 14/15 year olds at the address to apply to register online.

You should also work with partners that specifically work or have influence with young people and reflect this in your plans. We provide specific guidance on engaging with young people and attainers in our example tactics sheet for reaching target audiences below.

If you have given a third ITR and, after a reasonable period of time, you have not received a response and you have made a personal visit at least once to encourage an application, you may require an individual to submit an application to register by a specified date. This must be done on a written notice.1 1  

A personal visit is not required before a requirement to register can be issued to an individual aged under 16 years old.2

Before you can require an individual to make an application for registration you must establish that the individual:

• has received at least one ITR3 - ideally, you should obtain confirmation from the named person, such as written confirmation of receipt or a written statement from a canvasser that they have given an invitation to the individual in person. Confirmation by email or telephone would also be acceptable and, if the telephone call is not recorded, you should make a written note of the conversation
• has received a personal visit to encourage an application4 – an individual must already have received a personal visit as part of the ITR follow-up process
• has been informed of how to make an application for registration5 - your ITR will already have informed the individual how they can make an application to register
• has been informed that you may impose a civil penalty if you require them to make an application and they fail to do so6 – your ITR will already have included an explanation of the circumstances where a civil penalty may be imposed, and the amount 
• is resident at the address at which the ITRs were given7 - you should consider if there are any local records you can check or other action that you can take to confirm that the person is resident 

A civil penalty for failing to respond to a requirement to register cannot be imposed on any individual under 16 years old8 , and the ITR makes clear that the civil penalty does not apply to such individual.

Your record-keeping and processes for issuing ITRs and carrying out personal visits should be designed to ensure that you can be satisfied that all of those requirements have been established.

You may impose a civil penalty on individuals who were issued a requirement to register but who failed to make an application to register by the date you stated in the requirement to register notice.1  

You should have a process in place for issuing civil penalties. This should include how you will:

• make the arrangements for collecting any money 
• account for any money collected
• ensure any that any money collected is returned to the The Department for Levelling Up, Housing and Communities to be paid into the Consolidated Fund

You may want to seek advice on carrying out the civil penalty process and collecting penalties from other departments within the council who have experience of undertaking similar processes, including the council’s legal department.

If you decide to impose a civil penalty on an individual, you must give a civil penalty notice informing them that a penalty has been imposed and specifying the reasons for it.2  

A civil penalty for failing to respond to a requirement to register cannot be imposed on any individual under 16 years old, and the ITR makes clear that the civil penalty does not apply to such individual.3

Where no review has been requested or no appeal has been made to the First-tier Tribunal, payment must be made within 28 calendar days of the date of the civil penalty notice.1

Where the individual has requested a review or made an appeal to the First-tier Tribunal, the civil penalty must also be paid within 28 calendar days, but the 28-day period ceases to run while the review or appeal is being considered and re-starts if the review or appeal is unsuccessful.2

When calculating the 28-day period, the day on which any review or appeal is requested is excluded and the day on which the review or appeal concludes is included.

You should liaise with your council’s legal department regarding the process for any debt recovery should an individual fail to pay the penalty within the required timeframe. Where a payment is overdue, interest is accrued at a daily rate equivalent to 8% per year.3  

In cases where an individual refuses to pay, an application can be made to the sheriff in , for recovering the debt and any accrued interest.4  

Individuals are able to apply to register to vote in a number of ways1 : 

• online via the central government website - www.gov.uk/register-to-vote
• by providing the necessary information in writing (e.g. on a paper form)
• by telephone to your staff (if you offer the service)
• in person at your office (if you offer the service)

You are obliged to send an invitation to register (ITR) to potential electors within 28 days of becoming aware of them. However if you have an email address for a potential elector you could, in the first instance, use it to encourage them to submit an online application or issue an ITR by electronic means.

The register to vote website will not allow a person to submit an application to register to vote online unless they provide all the information necessary or have given a reason as to why this cannot be provided. You may, however, receive applications on paper which do not contain all the information required for processing. In such cases, you will be able to obtain the missing information through various channels, irrespective of how the original application was made.

While there is a specific process to follow where someone cannot provide their date of birth, National Insurance number or nationality, you can collect missing information by telephone, in person or via email. For example, it may not be clear from a paper application whether a missing National Insurance number was an oversight by the potential elector or was not included because they cannot provide it. Where you have the telephone number or email address for that elector, you can obtain the missing information through those channels.

There is no requirement for an applicant who is under the age of 16 to provide their National Insurance number or a reason why they are not able to do so.2

Promotion of the application channels available

You should make sure that your potential electors know how to apply to register. You should ensure that you: 

• provide a link to the online registration form on any relevant pages of your website (and the council’s, if that is separate) 
• provide a link to online registration wherever electoral registration may be relevant including, for example, on any online system for setting up new council tax accounts and on the websites of partner organisations 
• set out the alternative registration channels for those who cannot, or do not wish to, apply online
• liaise with local parties and candidates to share information on how to register online or obtain registration forms
• liaise with other local partners you work with to promote registration in any materials they may distribute to or use to communicate with residents
• provide a clear link to the online application form at the end of any process you provide for responding to canvass communications

You should make clear the various application channels so that electors can make a choice that best meets their needs and preferences. Promoting the different ways of registering should make the application process as accessible as possible.

What can a person do to assist another person to register to vote?

We have produced a factsheet for care homes that you can adapt to reflect your particular circumstances. The factsheet is based on our assisted applications guidance which details what one person can do to support another to register.

Information supplied as part of an application for a Voter Authority Certificate or Anonymous Elector's Document

You cannot use any information supplied as part of an application for a Voter Authority Certificate or Anonymous Elector's Document, such as a National Insurance number, for any other purpose than the processing of that application.3 This means that you cannot use the information provided as part of an application for a Voter Authority Certificate or Anonymous Elector's Document to complete a registration application for the same elector if they are not registered to vote. The registration process is prescribed and requires the elector to provide a declaration that the information on the application is true.4

Information included on a Voter Authority Certificate or Anonymous Elector's Document also cannot be used to complete registration applications where the registration application is incomplete or the information supplied with the registration application has not matched with DWP records. Further information on potential data sources that can be used for local data matching can be found in our guidance.

We would advise, however, that where you have received an application for a Voter Authority Certificate or Anonymous Elector's Document from an elector who is not already on the electoral register, that you may use this information to invite them to register. More information on the potential sources of data to register electors can be found in our guidance.

The online registration form is hosted on the central government website www.gov.uk/register-to-vote, you should provide a link to this from your website and include it in all of your communications and public awareness activity.

If you have an email address for an individual you could use it to encourage them to submit an online application. You can also issue an invitation to register by electronic means, including by email.

Information from applications to register that are completed online will be sent to your EMS system automatically from the IER Digital Service.

Online registration provides a range of opportunities to integrate registering into other services the council provides and to deliver electoral registration more efficiently.

Promoting online or other channels may make it simpler and potentially cheaper for you to process applications. There are many benefits for individuals in completing an application online including:

• improved accessibility for individuals with particular communication needs  who may be able to complete the application more easily online, for example those with visual impairments who use electronic screen readers 
• providing assurance that the application they have made is complete as the online system will not allow any incomplete applications to be submitted, for example  any applications with obvious inadvertent errors, such as their date of birth being missed or given in the wrong format
• providing assurance that the application is received the moment it is submitted, which is particularly beneficial close to a registration deadline ahead of an election

There are also benefits for you including:

• reduced need for manual data input
• fewer errors due to the validation of information entered on the online form
• no need to decipher handwriting
• applications will be complete when received, reducing the need to follow-up any missing information
• verification will be undertaken immediately rather than once you enter the data into your EMS system
• not having to receive, open, scan and store a paper form

14 and 15 year olds can apply to register through the register to vote website (excluding those applying as special category electors) but these applications will not be sent for verification against DWP records. Instead, their application details will be sent to you to verify by checking against education records or other local data. For further information see verifying the identity of applicants.

Your own website and social media accounts are also key tools for communicating messages about registration and encouraging applications. You should regularly review and update any general advice or information contained on your website relating to electoral registration so that people have accurate and up-to-date information about how to register.
 

There is no requirement for an application to register that is made in writing (on paper) to be made on a particular form. The application must, however, contain all the information required for a valid application. Forms can be sent to you by post, delivered by hand or sent electronically, such as by fax or as a scanned copy sent by e-mail.

Where you are making non pre-populated forms available you may supply them in hard copy or electronically, so that they can be printed out, completed, and sent to you.

The paper application form that you must include alongside an invitation to register must be the form1 as approved by the Minister for the The Department for Levelling Up, Housing and Communities and made available by the Commission2  

The form includes space for you to add your contact details, local authority information, unique reference, security code and a barcode.

If you receive a written application that is not on an application form you should check that it contains all the required information. If incomplete, you should follow the process outlined in our guidance on incomplete applications.

Where you receive a written application that is not made on the approved form and which does not include the explanation of the full and open registers using the prescribed short form of words, you should write to the applicant to provide them with the prescribed short form of words. You should set out their existing open register preference including an explanation of how they can change their preference if they wish to do so.

Where you receive a written application from a person under 16 years old that is not made on the approved form you do not need to provide them with the prescribed short form of words. This is because a person under 16 years old is automatically opted out of the edited register.

Legislation enables applications by phone and in person. For the benefit and convenience of electors, you should offer these services wherever possible. This will also help you meet your duties under the Equalities Act, as people who may have difficulties completing the paper or online form will have the opportunity to apply without the need to provide the information in writing.

If you are unable to provide telephone and/or in-person registration for all, you may allow these at your discretion in certain circumstances, and you should do so to assist applicants with disabilities in order to meet equalities obligations.

If you decide to allow telephone applications, you may use a central contact centre. This gives staff the opportunity to promote registration to residents who are contacting the authority for another purpose and take an application to register by phone. This could help to maximise the accuracy and completeness of the register and avoid you having to formally invite them to register.

Because of the requirement for an application to be made in writing, where a person applies by telephone or in-person, you must transfer the information into an application in writing. In practice this can be achieved by inputting the information into a paper application form or the register to vote website. 

If you decide to accept applications by telephone and/or in-person it is important that you keep accurate records of the applications or information provided. Before collecting the information required for the application, you should inform the applicant:

• that the information they provide will be processed in accordance with data protection legislation (reflecting the wording used in the prescribed voter registration form)  
• what information will appear on the register
• that it is an offence to knowingly provide false information, and that the maximum penalty is up to six months in prison and/or a fine not exceeding £5,000

Before asking whether the applicant wishes their name and address to be included in the open register you must provide the applicant with an explanation of what the open register is, using the prescribed short form of words.

For applicants that are 14 or 15 years old, you do not need to provide an explanation of the open register as the details of such individuals must not be included in any version of the published register, including the edited register.

When taking information on the applicant’s nationality, you should consider highlighting to the applicant that checks may be carried out in relation to their immigration status against Home Office records. 

Further guidance on this process and contact details are available by contacting the Home Office: [email protected].

You will be asked to complete a template which will be provided – please complete and return the section below the heading ‘Subject 1’ to the same email address. The Home Office have requested one template per subject per email, and that ‘ER’ be added to the subject header for each email to ensure that it goes into the correct folder for a response. The Home Office will respond within five working days unless a file is required, in which case it will respond within ten working days. The fact that you may request checks of a person’s immigration status against Government records is included on the registration application form approved by the Minister and made available to you by the Commission.

You may ask for an e-mail address and telephone numbers to use for future contact, as well as an indication of whether the applicant wishes to be able to vote by post or by proxy. However, you must make it clear that the applicant is not required to provide this information. 

Under data protection legislation, an elector can object to the processing of their email or telephone contact details. To demonstrate that you are processing personal data lawfully and transparently you should maintain records to detail any request made under the right to object to processing. Your EMS provider may have the facility to record consent against elector records. 

Our data protection guidance for EROs and ROs provides further information on lawful processing and the rights of the data subject.

You should review all of your existing email templates and ensure that where you communicate by email, you include an unsubscribe option. The email ITR that you must use has been updated to include an unsubscribe option.

Applicants must make a declaration of truth.1 Once you have taken the required information you should read it back to the applicant, giving them an opportunity to review the information provided and satisfy themselves that it is true and accurate. 

If an applicant does not have all of the information to hand they can call back at a later time. When you collect the missing information, you should go through the same process of giving the elector general information about how their data will be used and alert them to the offence of making a false statement. A declaration of truth must also be made to cover the missing information and you should give the applicant an opportunity to review the information supplied and correct any errors.
 

One of the criteria regarding an individual’s eligibility to register is that any statutory requirements in relation to the application are met.

An ordinary application for registration (excluding special category electors) must contain the following information:1

• the applicant’s full name
• the address where the applicant is resident on the date of the application and in respect of which they are applying to be registered
• any address where the applicant has ceased to reside in the 12 months prior to the date of the application and, where that address is not in the UK, an indication of whether that person was registered as an overseas elector during this period
• an indication of whether the applicant is resident at any other address, including any address where the applicant is currently registered and claims to be entitled to remain registered
• the applicant’s date of birth or, if unable to provide it, the reason why they are not able to do so and a statement as to whether aged under the age of 16, 16 or 17 or aged 18 or older2
• the applicant’s National Insurance number or, if they are not able to provide it, the reason they are not able to do so - where an applicant is under 16 years of age there is not a requirement to provide their National Insurance number3
• the applicant’s nationality or nationalities or, if they are not able to provide this, the reason why they are not able to do so
• an indication of whether the applicant requests their name to be omitted from the edited register - a person under 16 years old is automatically opted out of the edited register and must not be included in any version of the published register, including the edited register4
• a declaration that the contents of the application are true (in practice, on paper, this involves a signature or at least a mark on the form that shows that they have made the declaration)
• the date of the application

If any of the above is not provided, the application is incomplete and cannot be processed. You should follow up on the missing information with the applicant.

The application form must provide space for the applicant to provide their most recent previous name (if they have one)5 and an explanation that providing this information is not mandatory but may help in verifying their identity and if not provided, additional personal information may be required.

The register to vote website allows anyone over 14 to submit an application (excluding those applying as special category electors), however applications from 14 and 15 year olds will not be sent for verification against DWP records. Instead, their application details will be sent to the ERO to verify by checking against education records or other local data.

You may also receive a paper form from those not old enough to be an attainer.

If you receive such an application, you should contact the applicant and explain that you cannot process their application at this time, but that you will keep their details on file and invite them to register once they become eligible. Keep a record of their name, address, any other contact information, and the date on which they would become eligible for registration based on their age and put in place a mechanism to alert you to send an invitation to register at the appropriate time.

If any required part of the application is missing or incomplete, it will not constitute a complete application, and you will need to contact the applicant and request the information that is missing.

You can also require additional evidence where you consider it necessary to verify identify, or to determine an applicant’s entitlement to register.

In some cases, an applicant may not be able to give you their date of birth, National Insurance number or nationality. If they are unable to provide this information they must, as part of the application, provide a statement of the reasons why.1 Where an applicant is under 16 years of age there is no requirement to provide their National Insurance number.2

Where no statement is included, you cannot assume that the person cannot provide this missing information and should contact the applicant and ask them to supply it. 

The application will be on hold until the required information has been returned. The missing information does not need to be provided in writing – it can be provided over the phone, via e-mail or in person. You must, however, keep a written record of the missing information that has been provided, and ensure that is transferred to the written application. 

If unable to state their nationality, you can require the applicant to provide evidence about their nationality and immigration status in order to determine whether they are a qualifying Commonwealth citizen or a qualifying foreign national. This includes, if applicable, the applicant’s biometric immigration document issued in the UK. The fact that you may require additional evidence of an applicant’s nationality, and may request checks of a person’s immigration status against Government records is included on the registration application form. 

Where the required information has not been provided but the statements of reasons are completed (and their identity could not be verified using local data matching) you can use the exceptions process to verify the applicant’s identity.

You should keep a record of any incomplete applications or applications where you have requested further information, so that you can follow up with the applicant if they do not respond to your initial request for information. You should give the applicant a date to respond by with the information requested. 

Where you do not receive a response within a reasonable time (the 28-day maximum, but potentially earlier if there is an election), and you consider that the person is resident and may be eligible to register, you must give them a new invitation to register. 3
 

You are required to maintain three separate lists for:1

• applications received 
• any objections made prior to the person being added to the register
• any objections made after the person has been added to the register

As soon as any application or objection is received, the appropriate details must be recorded as follows: 

• details of the application (the name and nationality of the applicant, and the address given as their qualifying address) must be entered in the list of applications2  
• details of the objection (the name and qualifying address of the objector, plus details of the application (as above) or register entry) must be entered in the relevant list of objections3  
• where an objection is received before a person has been entered on the register, the particulars of the objection must be entered in the list of applications4  

Applications made by a person under 16 years of age must not be entered in the list of applications available for public inspection5 .

Applications to register anonymously are not subject to objections and are therefore not included on any of these lists. 

The lists of applications and objections are open for inspection until determined, i.e. until you have made the final decision as to whether an entry or alteration to the register is required.6 These lists are usually produced by software packages or, alternatively, they could be handwritten or typed manually.
 

You are uniquely placed to identify incidents and patterns of activity that might indicate electoral fraud in your local area. Applications for registration do not have to be taken at face value – you have the option of taking any application to a hearing. You can also require additional evidence where necessary to verify identity, or to determine an applicant’s entitlement to register.

Although there are no definitive signs of possible electoral registration fraud, and each specific case will be different, you should ensure that you have mechanisms in place to monitor indicators of possible fraud. These indicators and any trigger points for further action will need to be informed by: 

• the context of your local area 
• whether they are consistent or inconsistent with any other data available to you 
• the specific circumstances surrounding an application or applications

The following could, depending on the context, be indicators of possible fraud:

• any number of registration application forms completed in the same hand
• large numbers of registration applications submitted in respect of a single property, particularly where the number of forms does not reflect the type or size of the property (e.g. 10 applications for a small flat)
• applications which do not appear to match the usual pattern of previous or existing registrations at a particular property
• unusual number of applications failing verification, for example, if all applications from a property or neighbouring properties fail verification
• large numbers of attestations in any particular area
• information from the IER Digital Service on: 
  • whether the National Insurance number supplied with an application has been given in any other applications in the previous 12 months and in which local authority areas
  • the originating IP address for each online application

You should put in place mechanisms that will help you to identify suspicious registration applications including:

• training for canvassers and office staff on what to look out for
• review returns data regularly to identify patterns
• consider how best to share data about patterns of registration applications with local political parties and elected representatives, to improve transparency and confidence, and so that they can help identify any specific register entries which might be suspicious

Working with your local police Single Point of Contact (SPOC) 

Your local police SPOC is a key partner in ensuring that possible instances of registration fraud are quickly identified and dealt with.

Prompt action to address possible electoral registration fraud could help avoid costly police investigations or legal challenges to the results of elections. 

Make sure you know who your SPOC is and how to contact them. If you have any problems establishing contact with your SPOC, please contact your local Commission team.

You should have an agreement in place with your SPOC outlining the division of responsibilities, so that there is clarity about each other’s roles.

Your early discussions should cover:

• processes for identifying possible fraud and what actions should be taken where any suspicions arise
• an agreed approach for referring allegations of fraud for further investigation where appropriate
• establishing a process for handling evidence, so that the police can carry out any forensic analysis

Documentation that you would need to provide to the police for their investigation is likely to include:

• all papers received (including envelopes), sealed in a packet or envelope
• copies of the internal documents used to conduct internal checks (e.g. council tax records)

You should also agree a mechanism for handling evidence, following advice from your SPOC, so that the police can carry out any forensic analysis, where necessary.

The police will investigate any allegations of fraudulent electoral registration until, following consultation with the Procurator Fiscal Service (COPFS), either they are satisfied that no further action is necessary or appropriate, or they forward the case file to the COPFS for prosecution. The police should keep you, and where appropriate the RO, informed of the progress of the case.

Verification of an applicant’s identity

One of the aspects of entitlement to register is that the application is made by someone who appears to be the person named on the application.1
 
Any person making a new application for registration must provide personal identifiers which are used to verify the applicant’s identity against DWP records. 

If the applicant’s identity cannot be verified using DWP records, their identifiers may also be matched against local data sources. The results of these checks must be taken into account in determining the application.2
 
Regardless of when an application for registration is received, you must send the relevant information for verification matching against DWP data and take the results into account when deciding whether to allow the application. 

Applications from 14 or 15 year olds will not be sent for verification against DWP records.3 Instead, you will need to verify the applicant's identity using education records or other local data that meets the required standards.

If you are still unable to verify the applicant’s identity using local data sources, you should follow the exceptions process. 
 

National Insurance numbers 

National insurance numbers (NINo) should appear in the following combination of letters and numbers - two letters, six numbers, one letter. For example: QQ 123456 C. 

The table below gives some other examples of things that may be submitted in place of the usual NINo with some guidance on sending these applications for verification. 
 

You are not required to filter applications with temporary NINos manually, if an application is sent for verification as normal, it will fail, and you will proceed to the exceptions process.
 
When completing a paper form, some electors may mistakenly provide numbers other than their NINo. The most common are likely to be:

• NHS Number - these are 10 digits long, feature numbers only, and are normally laid out in a 3 – 3 – 4 format; and
• passport number - these are in varying formats, but not the same as either the NHS number or the NINo

In cases where the applicant has clearly provided the wrong number you should contact the applicant by any means of communication including email and telephone if you have the contact details, and ask them to provide the correct number. 

An application which does not contain a correct NINo, is missing the applicant’s NINo, or does not give a reason why a NINo cannot be provided is not a complete application and you cannot determine it for purposes of being included on the electoral register until a NINo or a statement as to why a NINo cannot be provided has been given. 

Who should have a National Insurance number?

Most eligible electors will have a NINo.
 
NINos are ordinarily, but not always, issued to:

• those who legally work in the UK
• those who claim benefits in the UK (including those who have had a Student Loan)
• those who are present in the UK just before their sixteenth birthday and whose parents are claiming child benefit for them

Who might not have a National Insurance number?

A small number of people may not have a NINo.

A number of applicants are Individuals who are eligible to vote in the UK but will not be in possession of a NINo might include (this list is not exhaustive):

• a qualifying foreign national who is studying in the UK and who is financially self-sufficient
• a qualifying foreign national who has been posted to work in the UK but who continues to pay tax in their home country 
• a British young person who was not issued a NINo by HMRC’s automatic issuing process
• a Commonwealth citizen who lives in the UK and who is financially self-sufficient 
• a qualifying foreign national who has never worked or claimed benefits in the UK 
• a British citizen who has never worked

What if an applicant does not have a National Insurance number or cannot submit one? 

DWP are not allowed to issue NINos for the purposes of registering to vote, and you must not ask applicants who do not have a NINo to apply for one.

Applicants who do not submit a NINo are asked to explain why they are not providing it and you should be satisfied with the reason given for non-provision of a NINo.

The exception to this is applicants who are under the age of 161 who do not need to provide NINo or an explanation as to why they are not providing it.

There is no definitive list of those individuals who should hold NINos. It is therefore not possible to give a definitive list of satisfactory reasons why a NINo cannot be provided.

Some reasons you may be provided with are: 

• the applicant was never issued one
• the applicant refuses to give it 
• the applicant cannot find their NINo

If the applicant makes a statement on their application form that they have never been issued a NINo, and you have no evidence to contradict the claim, you should direct the applicant to the exceptions process.
 
If an applicant makes a statement on the application form that they refuse to provide their NINo, you have the discretion to determine whether to reject the application or to direct the applicant to the exceptions process. The applicant is required2 to provide their NINo, and can be reminded of this fact.

If the applicant makes a statement on the application form that they have lost or forgotten their NINo, you should either ask the applicant to locate their NINo or direct the applicant to the exceptions process.

Although most paper communications from HMRC and DWP will feature an applicant’s NINo, there is no definitive list of places where an applicant can find it. 

Below is a list of places the NINo is most likely to be found, depending on the circumstances of the applicant:

For people over 16 but not yet working

• A registration letter from HMRC telling them what their NINo is (their parents may have this)

For employed people

• Pay slips from their employer
• P60 (end of year statement of pay and tax from their employer)
• P2 (notice of tax coding from HMRC)
• P45 (from their employer when they left a job)
• P11D (from their employer if they get any benefits in kind)
• P800 (from HMRC if they have over or underpaid tax at the end of the year)
• Notice to file a Tax Return (SA316) or Tax Return (if they are in Self-Assessment)

Self-employed people

• Notice to file a Tax Return (SA316) or Tax Return
• Statement of Account

Retired people

• the letter issued each year by DWP in February or March telling you how much your pension will be

Other

• A plastic NINo card (these stopped being issued in 2011)

You may be provided with other reasons as to why a NINo cannot be provided. You should assess the validity of the reason given on a case by case basis, bearing in mind this guidance.

What if an applicant does not have a date of birth or cannot submit one? 

On both the digital and paper application forms, applicants who do not or cannot submit a DoB are asked to explain why they are not providing it. You should be satisfied with the reason given for non-provision of a DoB.

Applications without a DoB must also be accompanied by a statement that the applicant is:1

• under the age of 16
• aged 16 or 17
• aged 18 or over

How to interpret DWP match results

Where a person aged 14 or 15 years old makes a registration application, it will not be sent for verification against DWP records and so you will not receive verification results. Instead, you will need to verify the application using education records or other local data that meets the standards. if you are unable to verify the identity of a 14 or 15 year old applicant you should write to the elector to inform them that it has not been possible to verify their identity and request they supply documentary proof of their identity. This is known as the exceptions process.

Applications to register are matched against the Department of Work and Pensions (DWP) Customer Information System (CIS) database. CIS is an amalgamated data source, containing data received from internal DWP systems, as well as other government sources, such as Her Majesty’s Revenue and Customs (HMRC). DWP use the CIS as the main source of customer information.

In order to perform the data match, DWP have developed an algorithm which matches an applicant’s personal identifiers sent to them via the IER Digital Service against the CIS database.

The DWP matching algorithm works like a filter. The stages are broadly summarised below: 

• The personal identifiers are standardised by DWP to make them more consistent with the DWP dataset (e.g. removal of spaces and hyphens from NINos)
• The personal record is then compared to the records in the DWP dataset in the following matching sequence
   
  1. Is there a record in the DWP dataset with a NINo that matches the NINo provided by the applicant? If not, the personal record is flagged as No Match and no further matches are attempted.
  2. Does the DWP record identified at step 1 have a DOB that matches the DOB provided? If not, the personal record is flagged as No Match.
  3. Do the names on the DWP record identified at step 1 match the names provided? A series of name matches are carried out until the best match is obtained. These are described in Table 1.
  4. At the end of the matching process, the match level is sent back to the IER Digital Service. The IER Digital Service assigns a score to the results, showing either a successful match or failed match.
  5. The match results plus the score assigned to them are sent back to your EMS where they are displayed to you. 

At the end you will have a set of match statements in your EMS that describe the levels at which an applicant’s record has passed or failed against a number of matching criteria. You will need to assess whether the applicant’s identity has been established according to the rating supplied.

Where a NINO matches against a DOB at any other levels set out in the table below, a positive match will be assigned to that record.

 
You are not limited to using the match rating to decide whether the identity of the applicant has been established. For example, you may have local data which is different to the DWP match. However, where you make an assessment which does not accord with the match rating (for example local data which contradicts the DWP match) you should record the reasons why you have reached your assessment and the evidence used.
 

Using local data matching for verification purposes

Local data matching can provide you with further information which you can use to make a determination as to whether to allow a new application. 

You must disclose the details of an application to the IER Digital Service upon receipt,1 and you should not carry out any local data matching for the purposes of verifying an applicant’s identity until you have received and considered DWP match results. 

You can use local data matching to verify applicants whose personal identifiers fail to be matched against DWP records.

You can also use local data to verify an applicant's identity where an applicant has been unable to provide a National Insurance number, provided that the reason given for not providing a National Insurance number is valid. 

Matching against local data allows you to use data sources available to you2 to verify that the person making the application is the person they claim to be. If you do not normally carry out local data-matching for verification purposes, this option should only be used if you are satisfied that the data sources available to you can satisfy the requirements of the task.

Where an applicant is under 16 years old, the requirement to provide their National Insurance number or, if they do not provide this information, the reason they are not able to do so, does not apply.

Applications from 14 or 15 year olds will not be sent for verification against DWP records. If you are able to verify an applicant's identity by using any educational records you are not required to carry out further verification checks.3

Alternatively, you can use other local data that meets the standards set out in evaluating local data sources for verification purposes to verify the identity of 14 and 15 year old applicants.

If you are unable to verify the identity via education records or via other local data, you should follow the exceptions process. Guidance on the exceptions process can be found here.

Potential data sources for local data matching

You can require any person to supply you with information required for the purpose of your duties in maintaining the register of electors.1 You are therefore entitled to request data sets from organisations where you deem it necessary for the purpose of verifying the identity of an applicant.
 
There are a wide variety of data sources that may be available including, but not limited to: 

• council tax data
• adult social care data 
• local authority billing and payments data 
• parking permits data
• school admission data
• blue badge data 
• customer service records 
• payroll data 
• registrar data on births, deaths and marriages

Each data source must be assessed against the criteria found in our guidance on evaluating local data sources before being used for local data matching.
 
Where a data set has limited coverage you may wish to consider using that data set alongside another to provide greater coverage across your registration area. Data sets with limited coverage may have additional value where they match with groups identified by you as part of your engagement strategy. 

As ERO, you are legally entitled to access local data sets and to inspect and make copies of records kept in whatever form by:2  

• any registrars of births, deaths and marriages, including any superintendent
• any person, including a company or organisation, providing services to, or authorised to exercise any function of the council; this includes those providing outsourced services under any finance agreement. For example, a private contractor appointed to collect council tax on behalf of the local authority

Legislation gives express permission for local authorities which have not directly appointed an ERO, to provide data to this ERO, but requires a written agreement between the ERO and the authority to be in place before any transfer of data occurs.3 The written agreement should regulate the processing of information including its transfer, storage, destruction, and security. 

While you have a legal entitlement to your local authority’s data, you should conduct any data matching activities in accordance with current data protection legislation, relevant guidance and good practice available on the Information Commissioner’s Office website.

Information supplied as part of an application for a Voter Authority Certificate or Anonymous Elector's Document

You may not use any information supplied as part of an application for a Voter Authority Certificate or Anonymous Elector's Document, such as a National Insurance number, for any other purpose than the processing of that application.4 This means that you may not use the information provided with an application for a Voter Authority Certificate or Anonymous Elector's Document to complete a registration application for the same elector where the registration application is incomplete or the information supplied with the registration application has not matched with DWP records.

The registration process is prescribed and requires the elector to provide a declaration that the information on the application is true.5

Managing the verification of applications received close to an election registration deadline

A complete registration application (i.e. an application containing all the information required for an application) must be made by midnight, 12 working days before the poll1 to be valid for an election. 

Even when an application for registration is received near to the application deadline for inclusion on the register for an election, you must still send the relevant information for verification matching against DWP records and take account of the result when determining the application.
 
You can expect to receive the results of the verification matching from the IER Digital Service within 24 hours. However, if an applicant cannot be verified, you will have limited time to undertake the additional steps required to get them verified before the determination deadline.
 
These steps include carrying out local data matching and advising the applicant to provide documentary evidence under the exceptions process if necessary. 

In the run up to an election, you may choose to take steps to minimise length of time required before being able to determine an application. 

For example, you could choose to proceed with local data matching before the results of the DWP match have been returned. If the identity of the applicant can be verified using local data, and then a negative match result is then returned by the IER Digital Service, you can use the local data match in order to determine the application without any further input from the elector.

If local data matching does not verify the applicant’s identity and you have still not received the results of verification from the IER Digital Service, you could advise the applicant that it might be beneficial to their application for them to voluntarily supply the necessary evidence for the documentary exceptions process at that stage, in advance of the verification result being received.

If the applicant does voluntarily choose to provide the evidence at this point, in the event that the IER Digital Service returns a negative match result, you can use the documentary evidence to determine the application. 

You must have processes in place to securely record and store any documentary evidence that you receive. You are only permitted to continue to hold the documentary evidence that has been provided in these circumstances if it is used to determine an application in the event of a negative match result,2 if the IER Digital Service returns a positive match, the documentary evidence is unnecessary and must be destroyed. You will therefore also need to have processes in place to securely destroy documents where necessary.  

If the results of the applicant’s identity verification are not returned by the IER Digital Service by midnight on the day before the election determination deadline (by midnight, seven working days before the poll), then you should refer to the contingency guidance.
 
You will need to consider the benefits and risks of requesting evidence in these circumstances. You will need to take into account the potential for voter confusion balanced against doing what you can to ensure that everyone who has applied by the registration deadline can be registered in time to be able to vote in the election. In no circumstances should you ask for documentary evidence to be submitted with a registration application - this may discourage applications from being made, and could cause confusion about the registration process.

If you receive an application from a 15 year old who will turn 16 before the date of the election close to the registration deadline, you are reminded that their details are not sent for verification against DWP records and so you will not receive a verification result with the application. Instead, you will need to verify the applicant's identity using education records or other local data that meets the required standards.

Is the attestation valid?

When a complete attestation is received, you must assess whether the attestation is valid.

To do this, you should ask the following questions.

• Is the attestor a ‘person of good standing in the community?
• Is the attestor registered to vote in a local authority area in Scotland?
• Has the attestor signed fewer than two attestations since, whichever is the most recent, either the last publication of the annual register, or the attestor was first added to the register?

Good standing

There is no precise definition of good standing; however, for purposes of an attestation, you should consider it to mean someone who has credentials that can be checked and would suffer professional or reputational damage if they were to provide a false attestation. The list in the table below is not definitive but is intended to illustrate which professions could be described as of good standing:

It is important to note that an unemployed/retired person who is of good standing in the community is not precluded from attesting an application.

You must judge each attestation on its individual merits rather than apply a blanket policy.

You must assess whether the attestation satisfies the relevant requirements, by answering two further questions:

Is the attestor registered to vote in a local authority area in Scotland?

If the applicant’s address is situated in a local authority in Scotland, the attestor must be registered to vote in a local authority area in Scotland.1

If the attestor’s address is in the same local authority area as the applicant, you should check your electoral register and your electoral management software to check that the attestor satisfies this condition.

If the attestor’s address is not in the same local authority area as the applicant, you should contact the attestor’s ERO to check if the attestor fulfils these conditions.

Has the attestor signed fewer than two attestations since either the last publication of the register or since the attestor was added to it, whichever is the most recent?

Attestors are limited to signing no more than two attestations in any one electoral year (normally from 1 December to 30 November), or since their entry was added to the register in that local authority area, whichever is the shortest period.

This allows the attestor’s ERO to confidently supply the required information without being required to account for attestations made whilst the attestor was registered elsewhere.

Election management software should record each time an elector has signed an attestation. Where the limit has been reached, you should reject the attestation for this reason. This does not prevent the applicant from seeking another attestation from a different elector. You should process attestations in the order they are received.

This means that if the attestor fulfils all the conditions, the attestation will be accepted, and so the attestor’s ERO will be able to record this against the elector’s record. This will then count towards this elector’s total allowable attestations, in case they sign another attestation in the future.

When can entitlement to be registered be determined?

You should determine entitlement as soon as is practicable. If possible, you should make your decision by the relevant deadline for the next register update. This will either be a notice of alteration or the publication of the revised register.

Making a decision quickly will ensure that your register is kept as up-to-date as possible.  

If you decide that a person is entitled to be registered, the application must be listed and made available for objections for five working days. Further information can be found in our guidance on the objections process.

You must not list any applications accompanied by an application for anonymous registration. This is because an anonymous registration application cannot be objected to.1 You can therefore allow an anonymous registration application as soon as you have made a decision that the application meets all of the requirements for registration.

Although a registration application from a person under 16 years old is included in the list of applications for registration, it must not be entered in the list of applications available for public inspection.2 You can determine the application on the sixth working day after the application has been entered in the list of applications.

What happens after the five day objection period?

After five clear working days have passed from the day the application was listed, and if no objections have been received, you can determine/allow the application without a hearing. 

If an objection has been made you must consider it before determining/allowing the application. 

If you decide an objection to be without merit you can determine/allow the application.3  

If you decide that the objector is not entitled to object, you can disallow the objection. You must inform the objector that you have not allowed their objection.4 If not, the determination of the application will be made alongside the determination of the objection.

Further information on the process can be found in our guidance on objections.

Do applications to register to vote have to be acknowledged? 

There is no legal requirement for an application to be acknowledged. However, you do have discretion to send an acknowledgement. In all cases, you are required to send a confirmation if the application is successful.