Guidance for Candidates and Agents at Senedd elections

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Examples of notional spending

There are five tests that must all be met for an item to count as notional spending:

  1. it is transferred to you or provided for your use or benefit
  2. it is transferred or provided for free or at a non-commercial discount of more than 10%1
  3. the difference in value between the commercial value of what is provided and what you pay is over £502
  4. you make use of it in your campaign (or someone does on your behalf)3
  5. it would have been election spending if you had incurred the spending.4 See What activities count as candidate spending? for information about the categories of candidate spending

Example A

A campaign group sends a candidate leaflets with a value of £600 to use in the candidate’s campaign. The candidate accepts the leaflets and arranges for them to be delivered to voters.

The first and second tests have been met as the leaflets have been provided for the candidate’s use for free.

The third test has also been met as the difference in value between the commercial value of the leaflets (£600) and what the candidate pays (£0) is over £50.

The fourth test is met as the candidate has arranged for the leaflets to be used on their behalf by arranging the delivery.

The fifth test is met as unsolicited material addressed to voters counts as  candidate spending.

As all the tests have been met, this is an example of notional spending. The full value of the leaflets provided to the candidate must be reported as notional spending.

A donation has also been made to the candidate as the value of the notional spending is over £500.

Example B

A printer provides a candidate with a quote of £200 to print leaflets to promote the candidate’s campaign. The printer also offers the candidate a 50% non-commercial discount on the order. The candidate pays for the leaflets, accepts the discount, and arranges for the leaflets to be delivered to voters.

The first and second tests have been met as the leaflets have been provided for the candidate’s use at a non-commercial discount of more than 10%.

The third test has also been met as the difference in value between the commercial value of the leaflets (£200) and what the candidate pays (£100) is over £50.

The fourth test is met as the candidate has arranged for the leaflets to be used on their behalf by arranging the delivery.

The fifth test is met as unsolicited material addressed to voters count as an election expense.

As all the tests have been met, this is an example of notional spending. The candidate must report the £100 they paid for the leaflets as a usual payment paid by the agent. The remaining £100 of the value provided as a discount must be reported as notional spending.

The value of the notional spending is not over £500 so this only needs to be reported as notional spending on the candidate’s return as a donation has not been made.

Last updated: 14 October 2025