Party spending and pre-poll donations and loans: UK Parliamentary general election

Notional spending

Sometimes you might use something in your campaign that you did not have to spend money on, because it was provided to you as a benefit in kind, for free or at a non-commercial discount. 

For example, this could be because the supplier supports your campaign. 

Some examples of a benefit in kind could be:

  • space in a hall for an event
  • printing
  • providing volunteers with food and transport

When this happens, the full commercial value of what you used counts towards your spending limit and must be reported.1  

This is called ‘notional spending’. 

There are four tests that must all be met in order for an item (i.e., goods, a facility or a service) to count as notional spending:

  1. you receive the item free of charge or at a non-commercial discount of more than 10%
  2. the difference in value between the commercial rate and what you pay is over £200
  3. the item is made use of by or on behalf of the party
  4. it would have been campaign spending if you had incurred the spending (see What activities count as spending?)

The item must be transferred or provided to the party for it to count as notional spending. 

This means that any notional spending will also be a donation to the party if it is over £500, and must be reported separately. Please see our guidance for more information on donations to political parties.

If you receive items free of charge, then you must record the full market value of the item if it’s more than £200.

If you receive items at a non-commercial discount of more than 10% and the difference in value is more than £200, you must include the value of the discount as notional spending. The amount you actually pay must be included as normal party spending.

Commercial and non-commercial discounts

Notional spending is only applicable to non-commercial discounts which are special discounts given to you, specifically, by suppliers. This includes any special rate which is not available on the open market.

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. 

Made use of by or on behalf of the party

If you are provided with an item but you do not use it, it will still be a donation if it is over £500, but it will not be notional spending.2  

A person only makes use of something on behalf of a political party if that use has been directed, authorised or encouraged by the party, the responsible person, or one of their deputies.3

Valuing notional spending

If the supplier is a commercial provider, you should use the rates they charge other customers. If this information is not available, you should find out what similar providers charge for the same goods or services and use this as the commercial value. 

You should keep a record of how you reached your valuation and keep copies of any quotes you receive. 

The value you declare in your spending return should be an honest and reasonable assessment of the commercial value. 

Notional spending summary box 1

For example, you are provided office accommodation from which to run your campaign free of charge, which you use for four months of the regulated period. 

You would calculate and report the notional spending as set out below:

Commercial rate for monthly rent: £1,200

Commercial value of four month’s rent: £1,200 x 4 = £4,800

Notional spending to be reported: £4,800

Notional spending 2

Please see here for guidance on valuing a donation:

How do you work out the value of a donation? (Great Britain)

How do you work out the value of a donation? (Northern Ireland)

Seconded staff

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

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

Last updated: 9 November 2023