Non-party campaigners: UK Parliamentary general elections

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What is notional spending?

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 in circumstances 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 to help you undertake regulated campaign activities, the value of what you use may count towards your spending limit and may be reportable in your spending return. Under the law, only transactions that meet certain criteria will be treated as notional spending.

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?

Items or services used by or on behalf of a non-party campaigner will be treated as notional spending if:

  • the property, services or facilities are provided free of charge or at a discount of more than 10% of the commercial rate for the use or benefit of the non-party campaigner, or in the case of the transfer of property it is transferred free of charge or a discount of more than 10% of market value1
  • the difference in value between the commercial rate and what is paid by the non-party campaigner is over £2002
  • they are made use of by or on behalf of the non-party campaigner and
  • if the expenses had been incurred by or on behalf of the non-party campaigner in respect of that use, they would have been controlled expenditure.3  

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

The non-party campaigner 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:

  • received at a discount of 10% or less or
  • 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.

Last updated: 19 December 2023