Non-party campaigners: UK Parliamentary general elections

A political party may publicly adopt policies that you are already actively campaigning for or against.

If your campaign did not meet the purpose test before the party changed its position, your planned campaign remains unlikely to meet the test.

However, as a result of the party changing their position, you might enhance or increase your spending on the issue over what you originally planned.

In this case where you alter your approach, the further campaign spending will be regulated if it can reasonably be regarded as intended to promote or criticise the party.

As usual you should assess your campaign using the factors we have set out.

For example, if you welcome a political party’s commitment to a policy that you have campaigned on, and it is clear that you would welcome a commitment from any political party, this will typically not meet the purpose test.

Example A

An organisation runs a campaign calling for the government and political parties to commit to freezing rent to help renters during the cost of living crisis. The campaign has been running for a number of years.

Once a UK Parliamentary general election is announced, the organisation increases its spending as planned to widen the reach of its campaign. The scope of the campaign does not change during the regulated period.

During the regulated period, several parties identify the increased costs of renting as an issue for the public. Two parties include a pledge to freeze rent costs for certain renters in their manifestos, while a few others propose general policies around increasing support for renters if they are elected.

The organisation puts out a statement welcoming each party’s policy announcement and encourages other parties to follow their example.

While the campaign is positive about parties that support freezing rent by praising them for adopting policies, the purpose test is not met. The timing of the campaign and call to action aimed at political parties to change their policies, rather than targeting voters suggests the activity cannot reasonably be regarded as intended to influence voters. Spending on the activity is not regulated.

Example B

A campaigner has been campaigning on a policy area for some years. They run a digital advertising campaign on the issue, which runs during the regulated period for a UKPGE. The campaign does not mention parties or candidates and does not meet the purpose test.

During the course of the campaign, the governing party commits to abolishing a key spending commitment in that policy area. The three largest opposition parties all reaffirm their commitment to the spending, and the issue becomes a prominent one in the election. This creates a new political context.

The digital advertising campaign continues throughout. Since the campaign has not changed since it was launched before the parties adopted the issue, the purpose test does not need to be applied in the new political context. The campaign still does not meet the test.

Responding to the increased interest in their issue, the campaigner increases their media appearances and social media activity. In these they focus on the advantages of the policy and urge all parties to reaffirm their commitment. 

Because this is new activity, the purpose test needs to be applied in the new political context. However, as the campaign continues to be generic, without a specific call to action by voters, even in the new context it cannot be reasonably regarded as intended to influence voters, and the purpose test is not met.

Nearer the election, the campaigner runs a new advertising campaign with the slogan ‘Vote to save the commitment’. In the new political context, the slogan has a clear link to the election and a call to action to voters with ‘Vote’. Because the issue is prominent, a reasonable person would think that the campaigner intends to influence voters to vote against the governing party and for any of the three opposition parties who have made the commitment. Spending on the new campaign is regulated.