Non-party campaigners: Senedd elections

A non-party campaigner decides to raise money on a crowdfunding website to spend on a campaign it will run before an upcoming Senedd election. The campaign is aimed at encouraging voters to support political parties and candidates that agree with the non-party campaigner’s position on a particular issue.

The non-party campaigner plans to spend the money it raises on regulated campaign activities. Based on previous campaigns it has run in the past, the organisation expects to spend over £10,000 in Wales during the regulated period and therefore registers with the Electoral Commission.

The election will take place on 7 May. For non-party campaigners, the regulated period begins on 7 January and ends on polling day. 

The non-party campaigner creates a crowdfunding page with a deadline of 24 March.

They choose a crowdfunding platform that collects enough information from donors to ensure they can complete their recording and reporting obligations, and allows donations to be returned if they are impermissible.

The non-party campaigner includes the following information on their crowdfunding page:

• what the money will be used for – “We are raising money to spend on [xxxxxx] for our upcoming campaign ahead of the Senedd election on 7 May”
• advice that permissibility checks will be undertaken for donations made over £500
• advice that if a donor cannot be verified, or is an impermissible source, their donation will be returned
• advice that details of donations may be reported to the Electoral Commission, and made publicly available
• a valid imprint

By the deadline, the campaigner has raised £24,750. The funds, minus the platform’s fees, are transferred to the non-party campaigner five working days later. The donations include:

• Donation A: £8,000 made on 2 February, donor name and home address received
• Donation B: £1,000 made on 12 April, donor name and home address received
• Donation C: private donation of £6,500 made on 14 April, donor name and email address received
• Several contributions between £500 and £7,500 made over the crowdfunding period
• Several contributions below £500 made over the crowdfunding period

The campaigner receives the funds on 31 March and downloads information on the donors from the crowdfunding platform. Their 30-day window for permissibility checks starts on 31 March, because this is the date of receipt.

Donation A is accepted after permissibility checks are carried out.

The campaigner carries out permissibility checks on Donation B and finds out that the donation was from an impermissible source. The candidate returns the donation to the donor through the crowdfunding platform.

The campaigner receives only the name and email address of the donor for Donation C. This information is not enough to check permissibility. The campaigner contacts the donor to request their home address, but doesn’t receive a response. The campaigner must reject the donation and return it to the donor.

When the non-party campaigner completes their spending and donations return, they record:

• Donation A, as it was above the £7,500 reporting threshold
• Donations B and C which were returned
• The total value of all other donations accepted between £500 and £7,500. These donations are checked for permissibility but only the total is reported in the return.

Contributions under £500 are not recorded or checked for permissibility.