Non-party campaigners: Senedd elections

Non-party campaigners may sometimes use property, services or facilities in their campaign that they did not have to spend money on, because the item or the services were provided as a benefit in kind, for free, or at a non-commercial discount.

This is known as ‘notional spending’.

You may incur notional spending where you use any items, goods or services given to you for free, or at a non-commercial discount of more than 10%. If any of these are used for regulated campaign activities, the value of what you use may count towards your spending limit and may be reportable in your spending return.

Notional spending is only applicable to non-commercial discounts which are special discounts given to the non-party campaigner. These are different to commercial discounts available to all customers, such as discounts for bulk orders or seasonal reductions. Items, goods and services purchased with commercial discounts will not be treated as notional spending.

What spending is treated as notional spending?

There are five tests that must all be met for an item (goods, a facility or a service) 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 rate and what is paid by the non-party campaigner is over £2002
4. it is made use of by or on behalf of the non-party campaigner
5. it would have been a regulated campaign activity if you had incurred the spending3

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 person.4

You 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:

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

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 laws on donations to non-party campaigners and may need to be reported to the Commission.

Notional spending with a value of more than £500 will also be a donation to the non-party campaigner. Please see How do you value a donation? for more information on non-monetary donations.

Seconded staff

If an employer seconds a member of staff to your campaign, you must record their gross salary and any additional allowances as notional spending.

You do not need to include the employer’s national insurance or pension contributions.5