Campaign Expenditure (Senedd Elections) Code of Practice 2025 for non-party campaigners

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

In electoral law, these individuals and organisations are defined as third parties. The Commission refers to them as non-party campaigners.

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

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

Who is covered by the law

The law on spending and donations apply to non-party campaigners who spend more than £700 on regulated campaign activity3 .

A non-party campaigner can only spend more than £700 on regulated campaign activity if they are listed in section 88(2) PPERA as eligible to give a notification to the Commission. It is an offence to spend more than £700 on regulated campaign activity if the non-party campaigner is not listed in s88(2) as eligible to give a notification to the Commission4 .

Eligible non-party campaigners intending to spend more than £10,000 on regulated campaign activity must submit a notification to the Commission following which they will appear on the register of notifications. It is an offence to spend more than £10,000 without submitting such notification5 . 

Registered non-party campaigners and the responsible person

Once a non-party campaigner appears on the register of notifications, following submission of a notification, the Commission will refer to them as a ‘registered non-party campaigner’.

Following its submission of a notification to the Commission, the registered non-party campaigner must appoint a ‘responsible person’. The responsible person is legally responsible for compliance with PPERA6 .

If an individual registers as a non-party campaigner, there is no need to appoint a responsible person as they are automatically the responsible person.

Non-party campaigning law only applies to regulated campaign activity. Not all non-party campaign activities are regulated.

Activities that may be regulated

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

• press conferences or other media events organised by the non-party campaigner
• transport in connection with publicising the campaign
• production or publication of campaign material which is made available to the public at large or any section of the public
• canvassing and market research seeking views or information from members of the public
  public rallies or other public events7

See section on ‘the public’ for the meaning of the public for the purpose of regulated 
campaign activities. 

Regulated Period

Spending by non-party campaigners is regulated in the period before an election to the Senedd. This is defined in PPERA as the ‘Welsh devolved regulated period’ and referred to in PPERA as the ‘relevant period’. In this Code it will be referred to as the ‘regulated period’.

The regulated period for non-party campaigners at a Senedd election is usually the four-month period up to and including the day of the poll8 .  Elections to the Senedd are held on the first Thursday in May in the fourth calendar year following that in which the previous Senedd election was held, in accordance with s3(1) Government of Wales Act 2006 ( the ‘2006 Act’)9   . The date of the poll can be brought forward or postponed up to one month under section 4 of the 2006 Act.

Where the date of the poll is brought forward no less than five months before the day on which the poll would have taken place under s3(1) of the 2006 Act or the date of the poll is postponed no less than four months before day on which the poll would have taken place under s3(1) the 2006  Act  the regulated period starts four months  before that new polling date and ending on that new date of the poll.

If the date of the poll is varied outside the above timeframes, the regulated period starts four months before the date on which the poll would have taken place under s3(1) 2006 Act and ending on that date.

Where an extraordinary general election to the Senedd10  is called, the regulated period starts with the date when the Presiding Officer proposes a date for the election and ends on the day of the poll11 .

The Commission produces updated guidance on specific elections (including regulated periods) on its website.

Combined Regulated Periods and targeted spending

The regulated period for an election other than to the Senedd may be relevant if it overlaps with the regulated period for a Senedd election. Where two or more regulated periods overlap, a combined regulated period applies to the relevant part of the UK.  The Electoral Commission produces updated guidance for non-party campaigners for specific elections, including combined regulated periods where relevant.

Targeted expenditure is not relevant for Senedd elections but could be relevant for combined regulated periods.12

Purpose test

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

• one or more political parties
• one or more of the party list candidates standing on a party list  
• political parties or candidates who support or do not support particular policies 
  or
• another particular category of candidates13

by influencing voters at an upcoming relevant election to vote in a particular way. See definition of ‘relevant elections’ above. 

Whether an activity can reasonably be regarded as intending to influence voters to vote in a particular way is commonly known as the ‘purpose test’.

The purpose test must be applied at the time, or in the event of a retrospective regulated period as if at the time, spending on the activity is incurred. If spending was incurred prior to the regulated period but the activity takes place during the regulated period, the purpose test must be applied at the time the activity takes place.

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

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

No single factor on its own will determine whether or not a particular campaign activity meets the purpose test. Rather all of the relevant factors taken together will determine whether a campaign activity meets the purpose test.

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

1. Call to action 

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

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

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

2. Tone

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

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

3. Context and timing

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

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

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

4. How a reasonable person would see the activity 

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

Multi-purpose campaigns

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

It is immaterial whether an activity can reasonably be regarded as intended to achieve another purpose or purposes if it can also be reasonably regarded as intending to influence voters to vote in a particular way14 .

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

Retrospective regulated period

Where a regulated period is applied retrospectively, any pre-announcement activity will only be regulated if, at the time it was carried out, it could reasonably be regarded as intending to influence voters to vote in a particular way at a relevant election15 . See definition of relevant election above.

If there are no upcoming relevant elections, an ongoing campaign on a particular issue is unlikely to be reasonably regarded as intending to influence voters to vote in a particular way. A campaign activity that is focused on an issue rather than on how a voter should vote, is unlikely to meet the purpose test if there are no upcoming relevant elections.

Campaign activity will only be regulated as a result of a retrospective regulated period in either of the following circumstances: 

• Campaign activity that meets the purpose test in any relevant election that is taking place at the time of the activity, even if it is not a Senedd election, will be regulated if a retrospective regulated period is applied. 
• An activity that is campaigning for the next election, regardless of what election that is, and meets the purpose test, will be regulated if a retrospective regulated period is applied.

See section on campaign activity before an election is announced.

Meaning of ‘the public’

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

• Canvassing and market research of the public 
• Public rallies and events 
• The production or publication of material

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

Canvassing and market research

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

Rallies and events

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

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

The production or publication of material

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

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

• Campaign material that is made available to the public or a section of the public

Campaign material that is made available for the public or a section of the public to hear or see will be public and will be regulated campaign activity if it also meets the purpose test and takes place during a regulated period. This applies regardless of the means by which the material is distributed, for example by print or digitally.

• Campaign material that is only made available to people who have chosen to receive the information

Campaign material that is only made available by the non-party campaigner to a closed group of members or people who have chosen to receive the information, will not be regulated.

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

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

Notification threshold

Non-party campaigners intending to spend more than £10,000 on regulated campaign activity in the regulated period before an election to the Senedd must submit a notification to the Commission16 . This is referred to in this Code as the ‘notification threshold’. In Commission guidance or correspondence with the Commission you may see this referred to as the ’registration threshold’.

Eligible non-party campaigners

Non-party campaigners are not permitted to spend more than £700 on regulated campaign activity unless they are eligible to give a notification the Commission by virtue of s.88(2) PPERA. Only individuals or organisations described in s.88(2) PPERA are eligible to submit a notification to the Commission17 . These are:

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

Organisations are prohibited from registering as both a non-party campaigner and a political party18

An eligible non-party campaigner may spend up to £10,000 across the UK without notifying the Commission19 .

Before spending more than £10,000 on regulated campaign activity, an eligible non-party campaigner must submit a notification to the Commission20 .

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

Reporting thresholds

Registered non-party campaigners who spend more than £10,000 on regulated campaign activity must record and report their spending and donations  to the Commission. This is known as a ‘reporting threshold’22 .

Maximum spending limit for registered non-party campaigners

There are spending limits that restrict the total amount a non-party campaigner can spend on regulated campaign activity during the regulated period. The spending limit for controlled expenditure which can be incurred by or on behalf of a registered non-party campaigner is £30,000 as set out in Paragraph 6 Schedule 10 PPERA. Combined regulated periods will have different spending limits23 . More information will be found in the Commission’s guidance.

Reporting requirements

All registered non-party campaigners must comply with the law on spending and accepting donations. Registered non-party campaigners must submit a spending return that details their spending on regulated campaign activity24  and any donations received for the purpose of meeting spending on regulated campaign activity . See the section on donations. The spending return must be submitted to the Commission within three months of the end of the relevant regulated period25 .

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

General guidance

Campaign activity before an election is announced

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

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

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

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

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

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

Apportionment of items for subsequent elections

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

Unused items

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

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

Items paid for prior to the commencement of the regulated period

Where spending was incurred prior to the start of a regulated period on items that are used during the regulated period, the spending on those items must be reported in the spending return26 .

Items provided free of charge or at a discount

Where any items are provided free of charge or at a discount, the appropriate amount must be reported in the spending return as notional spending and/or a donation. See definition of appropriate amount above.

Apportioning spending

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

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

VAT

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

Overheads

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

Where there is no increase in spending on overheads beyond the normal spending incurred by a campaigner, spending on overheads will not be regulated.

Where there is an increase in the cost of overheads incurred by a campaigner as a result of regulated campaign activity, that increase in spending must be reported.

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

Overheads can include items such as:

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

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

Staff costs

Staff costs that are directly attributable to regulated activity must be reported. Only staff costs that are incurred as a result of regulated campaign activity need to be reported. 
Where staff costs can only be partially attributed to regulated activity, the costs must be apportioned and only the portion attributed to regulated activity must be included in the spending return. 
Where an apportionment of a staff member’s time is necessary, an aggregated figure for all staff time attributed to regulated activity is sufficient to meet the reporting obligations. 
The childcare costs of staff members are not expenses that need to be reported as they are not sufficiently closely connected to the regulated activity27

Excluded items

Any spending on campaign activity that needs to be reported in the spending return of a candidate or in the spending return of a registered political party, must not be reported in the spending return of a non-party campaigner.

Schedule 8A

Schedule 8A PPERA lists the qualifying expenses that are regulated.

Expenses that fall within the regulatory regime

• the production or publication of material which is made available to the public at large or any section of the public (in whatever form and by whatever means)
• canvassing, or market research seeking views or information from, members of the public
• press conferences, or other media events, organised by or on behalf of the non-party campaigner
• transport (by any means) of persons to any place or places with a view to obtaining publicity
• expenses in respect of the transport of such persons include the costs of hiring a particular means of transport 
• public rallies or other public events, other than annual conferences of the non-party campaigner

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

Expenses that fall outside the regulatory regime

PPERA specifically excludes the following expenses from the reporting requirements:

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

Annex A sets out a non-exhaustive list of the kinds of expenses that do, or do not, fall within the meaning of qualifying expenses.

Discounts

Non-commercial discounts

Non-commercial discounts are special discounts given to the non-party campaigner. This includes any special rates which are not available on the open market.

When this happens, the full commercial value of the item or the services will count towards the spending limit and must be reported in the spending return.

Commercial discounts

Commercial discounts are those available to other similar customers, such as discounts for bulk orders or seasonal reductions. These are not treated as notional spending.

Notional spending

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

• the property, services or facilities are provided free of charge or at a discount of more than 10% of the commercial rate for the use or benefit of the non-party campaigner, or in the case of the transfer of property it is transferred free of charge or a discount of more than 10% of market value29
• the difference in value between what is provided and what is paid by the non-party campaigner is over £20030
• they are made use of by or on behalf of the non-party campaigner and
• if the expenses had been incurred by or on behalf of the non-party campaigner in respect of that use, they would have been controlled expenditure31 .

The items or services are only used on behalf of the non-party campaigner if that use is directed, authorised or encouraged by the non-party campaigner or the responsible person32 .

The value of the notional spending is the difference between the total value of what was transferred or provided and the amount that was paid, if anything. 

The non-party campaigner must record both:

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

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

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

Value of notional spending

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

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

• its market value (where it is transferred free of charge) or
• the value of the discount33 .

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

• the commercial rate (where is it provided free of charge) or 
• the difference in value between the commercial rate for an item or service and the price that was actually paid by the non-party campaigner34 .

Donations

The goods, services or facilities must be provided or transferred to the non-party campaigner to be treated as notional spending.

This means that any notional spending will also be a donation to the non-party campaigner.

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

Working with registered political parties

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

If the registered political party use the goods, services or facilities during their campaign, this must be treated as notional spending on behalf of the registered political party35  . This will also be treated as a donation by the non-party campaigner to the political party36 .

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

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

Working with other non-party campaigners

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

The law on joint campaigning apply to registered and un-registered non-party campaigners37

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

• they enter into a plan or other arrangement with one or more other non-party campaigners
• all non-party campaigners involved intend to incur controlled expenditure in pursuance of that plan or arrangement 
• one or more of the non-party campaigners involved actually incurs controlled expenditure in pursuance of the plan or arrangement and 
• that plan or arrangement can reasonably be regarded as intending to achieve a common purpose38 .

All of the spending on the joint campaign counts towards the spending limit of each of the non-party campaigners involved in the joint campaign.

What is joint campaigning

There must be more than one non-party campaigner

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

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

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

If there is no intention to incur expenditure there is no joint campaigning. For example, if it is agreed that all activity will be carried out by volunteers no spending will be incurred and there will be no joint campaigning.

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

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

There must be an agreed understanding between the non-party campaigners that each of them will incur controlled expenditure to achieve the common purpose

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

Joint campaigning is not simply

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

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

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

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

This paragraph includes:

Services, equipment, facilities or premises provided by others

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

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

that is used to:

• prepare, produce or publish material which is made available to the public at large or any section of the public

For example, the hire of a photographer and premises to produce images for use in advertising material. 

Specific costs in connection with producing or disseminating digital or electronic advertising material

This includes the cost of any software, of any kind, for use on any device to:

• design and produce advertising material in-house
• disseminate or facilitate dissemination of advertising material

whether that material is distributed digitally, electronically or via other means. 

For example, a licencing fee for a software application for use on a device.

It also includes any cost attributable to increasing the visibility of content by any means.

For example, the purchase of a more prominent position on a page within a search engine.

It includes the cost of preparing, producing or facilitating the production of advertising material for:

• download and use by others
• posting on and promoting material via any kind of social media channel or platform

For example, the costs of producing advertising material promoting the campaign that is posted to a page on a social media channel encouraging followers to share it.

It includes the cost of accessing, purchasing, developing and maintaining any digital or other network which:

• facilitates distribution or dissemination of material by any means
• promotes or increases the visibility of material by any means

For example, the purchase of digital identities to make material appear as if it has been seen and approved by a high number of users on a social media platform.

It includes the costs of:

• hosting, maintaining, designing or building a website or other electronic/digital material that promotes the outcome of the election
• any licensing or other rights fee for any image used in producing relevant material

Other costs

It includes the cost of purchase and use of any equipment used for: 

• the preparation, production or facilitating the production of the material 
• dissemination of the material by distribution or otherwise

It includes the cost of:

• paper or any other medium on which material is printed or displayed
• physically displaying material in any location, for example cable ties or glue for putting up posters

It includes the cost of printing material or the purchase, hire or use of:

• photocopying equipment
• printing equipment

It includes the cost of accessing, obtaining, purchasing, developing or maintaining:

• IT software or contact databases 
• any information, by whatever means, that is used to facilitate the sending of material to voters (for example, the purchase of email addresses)I

t includes the cost of accessing, obtaining, purchasing developing or maintaining data sets, including data analytics to target voters by whatever means, including the cost of agencies, organisations or others that identify groups of voters, by whatever means.

For example, the cost of any agency paid to analyse social media content to facilitate targeting of voters across electoral areas and the cost of modelling by any agency based on that analysis.

It includes any services to identify voters that are purchased, developed or provided before the regulated period, but are used to target voters during the regulated period. Where information or access to information is obtained from an external source, it includes the commercial cost of obtaining that information from the external source.

It includes delivering material by any means including electronic means, for example the purchase of a system for sending emails or a licensing fee for a software application for use on a device, as well as physical distribution, for example the cost of envelopes and stamps.

It includes oversight and maintenance of all social media, digital or other forms of distribution of material including the maintenance of all social media accounts whether or not maintained by another entity/individual.

This paragraph includes:

Services, premises, facilities, or equipment provided by others

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

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

used to:

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

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

Costs of obtaining or maintaining data 

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

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

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

Other costs

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

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

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

This paragraph includes:

Cost of press conferences or other dealings with the media

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

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

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

Other costs

It includes the costs of any rights or licensing fee for any image used in preparation, production, facilitating or conducting press conferences or other media events.

It includes the cost of purchase and use of any equipment in connection with preparation, production, facilitating or conducting press conferences or other media events.

This paragraph includes:

Transport of volunteers or campaigners

It includes the cost of transporting: 

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

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

• tickets for any transport, 
• hiring of any transport 
• fuel purchased or electric vehicle charging costs for any transport
• parking for any transport

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

Other costs

This includes the cost of use, or hire, of any vehicle or form of transport that displays material promoting the election result, including:

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

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

This paragraph includes:

Services, premises, facilities or equipment provided by others

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

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

used in

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

Other costs

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

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

It includes the purchase of any equipment in connection with:

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

Costs that are excluded

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