Parliamentary briefing: Representation of the People Bill (Part 3 – Conduct of elections: Voter ID, absent voting, and remaining conduct clauses) – Committee Stage

Overview

24 March 2026

This briefing has been prepared ahead of Committee Stage consideration of Part 3 of the Representation of the People Bill. If you have any questions about this briefing, or the Bill more generally, please contact [email protected].

Clause 47 – Voter ID requirements

This clause expands the list of ID accepted at polling stations in Great Britain to include bank cards as a non-photo form of ID. It also clarifies that digital versions of accepted photo ID can be accepted at polling stations if they can be verified visually.

  • The 2024 general election was the first at which voters were required to show photo ID when voting in polling stations, and most people were able to vote successfully. Our research found:
    • fewer than 0.1% of people in Great Britain who tried to vote at a polling station were unable to do so because they could not present an accepted form of ID
    • around 4% of people who did not vote said that the requirement to show ID was a factor
    • that the requirement to show voter ID affected some people more than others, particularly people from a disadvantaged background.
  • We recommended that the Government review the list of accepted IDs and the way the voter authority certificate (VAC) is issued including whether there could be a later deadline to apply for a digitally-issued VAC. We also recommended that options for voters without accepted ID – such as attestation or ‘vouching’ – be considered.
  • We will inform voters of any changes to accepted forms of ID, and continue to communicate when they need to show ID and how they can apply for a VAC as an 2 alternative. We will support electoral administrators and polling station staff in managing the voter ID verification process.

Bank cards as voter ID

  • The Bill expands the accepted ID list for UK parliamentary elections in Great Britain to include UK-issued bank cards. ‘Bank cards’ cover payment and cash withdrawal cards, including a credit, charge, debit or prepaid card

Key considerations

  • Allowing voters to show bank cards as a form of ID is less secure than the current requirements, where voters need to show photo ID at polling stations. Because bank cards do not include a photo and sometimes do not include a full name, it will be harder for polling station staff to verify a person’s identity when they use a bank card.
  • Bank cards also present practical challenges for polling station staff because they do not have a common format, design or validation feature, which is the case for other forms of ID.
  • It is not uncommon for people with the same surname and initial to live at the same address, which if using ID without a photo or full name will be hard for staff to verify. This not only causes difficulties for administrators, but may also cause voters to be needlessly turned away as staff cannot confidently verify their identity.
  • A similar issue may arise if bank cards are subject to different rules to other forms of ID. The government amendment requires bank cards to be in date, a rule which does not apply to any other form of voter ID.

Digital ID and voter authority certificates

  • Adding digital versions of ID as valid voter ID would give voters more flexibility and options for proving their identity. Issuing digital Voter Authority Certificates would also improve access for voters without other forms of ID. If local councils can issue digital certificates closer to polling day, the application deadline could also move closer to polling day.

Key consideration

  • We have previously recommended that the Government should consider introducing ‘vouching’ or attestation for voters who do not have or cannot access any form of accepted ID at polling stations. Canada uses ‘vouching’ at its federal elections. It allows registered voters with an accepted form of ID to vouch for someone who does not have accepted ID. As a result, provides a safeguard by requiring a formal link to a named voter who has had their own identity verified.
  • Given the Bill’s introduction of votes at 16, the list of accepted voter ID should be kept under review. It will be important to ensure it includes secure forms more likely to be held by younger voters to ensure elections are accessible for newly enfranchised young people.

Devolved considerations

  • The Welsh Government and Scottish Government have both taken the decision to not introduce voter ID for devolved elections for which they are responsible. They did not provide legislative consent to the Elections Act 2022 and have not introduced the requirement as part of their own electoral reform programmes. This means ID is not required at Scottish and Welsh Parliamentary elections or devolved local elections – although it is required for reserved elections and recall petitions in Scotland and Wales.
  • In Northern Ireland, photo ID has been a requirement for elections since 2003 and is well understood.

Clause 48, Schedule 3 – absent voting

Clause 48 and Schedule 3 make changes to the postal voting application deadline and rules around cancelling a postal vote

  • More than 1.3 million people applied to vote by post at the 2024 general election. While most postal votes were received on time, some postal voters did not receive their ballot packs in time to complete and return them before polling day.
  • The Commission recommended improvements to the postal voting system to improve the service for voters, including considering whether the deadlines allow sufficient time to process postal votes. The Bill makes several changes to the postal and proxy voting system, which are intended to improve flexibility and resilience.
  • These changes will work in conjunction with proposals to move the deadline for applying for a postal vote from 5pm, 11 working days before the poll to 5pm, 14 working days before, which will follow in secondary legislation. This change will increase the time between the application deadline and polling day, improving the likelihood of voters receiving and being able to return their ballot ahead of polling day, or having time to change their voting method.
  • The Bill will allow a postal voter in Great Britain to switch their voting method to vote in person or appoint an emergency proxy after the postal vote application deadline in circumstances where they may otherwise risk losing their vote (for example, if their postal ballot has not arrived on time).
  • The Bill also enables postal votes to be issued during the five-working-day registration objections period in situations where a postal vote and registration application are received at a similar time. There is also provision for the postal ballot to be subsequently cancelled should an objection be raised and the person is never registered.
  • A clear postal vote determination deadline will also be introduced, set at 5pm on the 6th working day before the poll.

Key considerations

  • Other forms of early or flexible voting could give voters further alternatives to postal or proxy voting. We have published feasibility studies showing how potential alternatives like advance voting or mobile voting in places like care homes could work for elections in the UK. 4
  • Three local authorities in England are piloting early voting hubs at May 2026 local elections, and one local authority is piloting a voting hub on polling day itself. We will evaluate and report on these.

Clauses 49 to 51 – Power to obtain election-related information

These clauses provide the Secretary of State with powers to make regulations requiring electoral administrators to provide information to the Secretary of State or Electoral Commission about reserved elections in Great Britain.

  • Currently, information about elections is published by local authorities and several other organisations.
  • This power would make it easier for voters to understand elections. It would require electoral administrators to provide information about: elections, referendums or recall petitions, including information about who can vote; when, where and how to vote; the candidates or referendum question; how the election will be run; and support for people with disabilities and the election results.
  • The Explanatory Notes to the Bill state that the Government envisions the information being published on an electronic platform which would provide a single source of election information for voters.
  • We support the Secretary of State being given this power. We have recommended that the clauses include a requirement for the Secretary of State to consult the Electoral Commission on the draft regulations to help identify, clarify and prioritise the data requirements. Regulations should ensure that data is provided in the correct format and in good time to provide the maximum benefit for voters ahead of elections.

Key considerations

  • This will require development work on administrators’ Electoral Management Software (EMS) to ensure that their systems have the required functionality to capture and provide the data needed in a consistent and usable format.
  • This may result in new burdens on funding to cover the additional costs. We recommend that the UK Government undertakes direct consultation with EMS suppliers on the updates to systems required so that any necessary enhancements can be identified and factored into the planned implementation of the provisions.
  • The new power only applies to reserved elections, excluding elections in Northern Ireland. The Electoral Management Board for Wales (EMB) has developed a Welsh Elections Information Platform, which will provide voters with information for the elections in May, and for future devolved polls. The Government should ensure its plans complement existing provisions in Wales and Scotland. Voters should have equality of information across all elections regardless of where they live. For this reason, the information sharing powers covered by these clauses should ideally be extended to all elections.
  • Section 49(4) provides that the manner and form in which information must be provided will be set out in secondary legislation. While we welcome this as being a more useful mechanism than primary legislation, we are concerned that requiring 5 any changes to be made via regulations would hamper our ability to make changes quickly, for example to reflect changing circumstances or developments in information technology. This could make it difficult to provide information to voters in the best and most up-to-date way, and hard for voters to get information about elections in the future.
  • A more flexible way forward would for the Commission to be given powers to issue directions, similar to those powers given to the Democracy & Boundary Commission Cymru to request information from Welsh Returning Officers. This would allow us the ability to make changes to how we inform voters about elections.

Clause 53, Schedule 5 – Form of documents for elections and referendums

This clause and schedule repeals existing legislation which contains forms relating to the administration of UK Parliamentary and Northern Ireland local elections, such as the writ, the notice of election, the nomination paper and the ballot paper.

  • The UK Government’s strategic review of elections concluded that electoral conduct forms should be simplified and transferred into dedicated secondary legislation that would be easier to amend. The changes contained in the Bill are the necessary first step in this work.
  • The Electoral Commission will be consulted on the regulations made under these changes.
  • The changes will allow voter facing forms, such as poll cards and ballot papers, to be updated more easily, ensuring that voters have and understand the information they need to vote effectively. Simplified and fewer forms will also assist electoral administrators to perform their duties efficiently, and candidates and their agents to complete nomination forms quickly.

Key considerations

  • The Government should make sure any legislation, including secondary legislation is made clear for voters, administrators and campaigners at least six months before they are due to be implemented or complied with.

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