Non-party campaigners: Senedd elections
Overheads, staff costs and VAT
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
Water, gas and council tax costs do not need to be reported, as they are not sufficiently closely connected to the regulated activity.
For example, during the regulated period a campaigner purchases additional computers, office equipment and phones to support their team with producing campaign material and canvassing. With these purchases, the campaigner’s electricity and internet bills increase beyond their normal spending.
As the spending on overheads has increased beyond the normal spending of the campaigner as a result of regulated campaign activities, these overheads costs will be regulated.
Staff costs
Staff costs that are directly attributable to regulated activity must be reported. Only staff costs that are incurred in connection with 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. For example, if you have a member of staff working on regulated campaign activity as well as on unregulated activities, you must only report the proportion of the staff costs which reflects the time they spent working on regulated campaign activities.
Where an apportionment of a staff member’s time is necessary, an aggregated figure for all staff time attributed to regulated activity will meet the reporting obligations.
You will need to account for all staff costs when recording the costs that are associated with a regulated activity. This includes:
- the staff member’s gross salary
- any additional allowances paid to them
- your national insurance and pension contributions as their employer
You do not need to include any staff member’s childcare costs as these are not closely connected to regulated campaign activities.
In your return, you are required to include invoices or receipts for any payments for regulated campaign activities over £200. As you will not have an invoice or receipt for directly employed staff, you should instead provide us with a breakdown of your staff costs for us to publish instead. For example, this may be broken down per activity, per anonymised staff member or per month. You should not submit any pay slips.
For example, a staff member is working on your organisation’s election campaign at the same time as your day-to-day business.
If your organisation already has an established way of apportioning these costs for other work, you may decide to calculate staff costs incurred in relation to regulated campaign activities in the same way.
In all cases, you should make an honest and reasonable assessment of the proportion of staff costs that can be fairly attributed to your regulated campaign spending.
To help you plan your spending, you and the staff member should agree a reasonable estimate of the time they are likely to spend on regulated campaign activities. You should ask the staff member to keep track of the time actually spent on regulated campaign activity and update you if they spend a significantly longer time than originally agreed. This should help you ensure that you do not breach the spending limit.
VAT
If you have paid VAT on an item, you must include this when reporting the costs of the item in your return. You must still include VAT even if it can be reclaimed as a business expense.
Invoices for payments made to companies based overseas may not always include VAT. If you have paid VAT, you should include this as part of the cost of the item when reporting, even if VAT is not included on the invoice.
For example, you pay for digital material to be published as adverts on a social media platform based overseas. You paid VAT on the adverts, but your invoice does not include VAT. You must still include the VAT you paid when reporting the costs of the adverts in your return.