Case study 2: Immigration

A group that campaigns on immigration and xenophobia delivered a high profile poster campaign, followed by a digital campaign that went on for a number of months. The campaign aimed to show immigrants as real people. 

Although the campaign had been originally planned to go live the previous year, it was delayed for various practical reasons, and the poster campaign was launched in the period before the general election. The costs of the poster and digital campaign in the regulated period were above the registration thresholds in each part of the UK.

Public test:

The activity is aimed at the public since it uses billboards, websites and social media.

Purpose test:

Call to action to voters

There is no call to action of any kind, and in particular nothing related to voting behaviour.


The campaign is positive about immigrants. It suggests that we should be welcoming to immigrants as well as hinting at the view that immigrants are an economic and social good, and therefore the campaign can reasonably be regarded as in favour of immigration in general. It does not mention parties or candidates, or any particular policy.

Context and timing

The organisation has campaigned on the issue for some time. The campaign has been planned for a long time and was intended to be released much earlier, but now it is very close to the election. Immigration is a high profile issue in the election, and is associated in particular with UKIP. However UKIP usually focus explicitly on immigration from the EU, which the campaign does not. Neither of the two largest parties have a distinctive view on the issue, although the Conservative Party have a well-known target to reduce non-EU immigration to the ‘tens of thousands’. No particular policy is alluded to by the poster campaign. The broad issue of ‘immigration’ is not enough to link the campaign to UKIP or any other party or category of candidates. 

How a reasonable person would see the activity

A reasonable person would think that the intention of the activity was to change the general debate around immigrants, primarily in the media but also from politicians. Due to the proximity to the election and the subject matter, a reasonable person might consider the possibility that the posters were aimed at UKIP, and perhaps to a lesser degree the Conservative Party. However, given that the campaign has not been changed since it was originally designed to be launched in a period where there was no election, overall a reasonable person would not see the campaign as intended to influence voters.

This activity cannot reasonably be regarded as intended to influence voters to vote for a political party or category of candidates, so the purpose test is not met. The spending on the activity is not regulated, and the campaign group does not have to register. 

Last updated: 23 September 2019