Organic material – registered campaigners

If you are a non-party campaigner registered with the Electoral Commission, then as well as for paid adverts, you must also include an imprint on organic material – including anything you post on social media – if it is election material, referendum material or recall petition material.

Election material is very similar to material which meets the ‘purpose test’ for regulated non-party campaigner spending (see the Commission’s spending guidance for more information). If you have determined that your digital material meets the purpose test, then it will also need to carry an imprint.

The primary intention of your material may not be to influence voters. For example, you might publish material with one or more of the following intentions:

  • raising awareness of an issue
  • influencing political parties to adopt a policy in their manifestos
  • campaigning for or against government legislation
  • providing information to voters
  • encouraging people to register to vote
  • encouraging people to vote, but not for anyone in particular

Material that can reasonably be regarded as having one of these intentions will not be election material unless it can also reasonably be regarded as having the intention to influence voters to vote for or against certain parties, candidates or future candidates.

Even if your primary intention is something else, your material will still be election material if it can reasonably be regarded as intended to influence voters to vote for or against certain parties, candidates or future candidates.

For example, suppose your intention is to influence political parties to adopt a policy. If you go about this by publishing material promoting parties and candidates who have already adopted the policy, then this will be election material because the purpose of your material can reasonably be regarded as being to influence voters to support those parties and candidates.

An example campaign asset supporting a specific issue that reads 'Save Engleston Library. Grey Party is in favour'. An imprint in the bottom right hand corner reads 'Promoted by Campaigners Ltd, 98 High Street, Engleston, AB12 3CD'.
Election material which can reasonably be regarded as intended to promote a party on the basis of its support for an issue.

If issues-based material cannot reasonably be regarded as intended to influence voters to vote for certain parties, candidates or future candidates, then it is not election material.

An example campaign asset supporting a specific issue that reads 'Stop climate change'. An imprint in the bottom right hand corner reads 'Promoted by the Campaign Group, 62 High Street, Engleston, AB12 3CD'.
Campaign material which is not election material (but which carries an imprint as best practice).

More examples are included below.

Before any election is announced, an animal welfare organisation publishes a tweet-thread explaining what it regards as mistreatment of animals in captivity. As well as setting out problems, it argues that one of the causes is government policy and underfunding. It does not mention elections, candidates or political parties.

This is not election material and does not require an imprint. Although the material is critical of the government, it is not reasonably regarded as intended to influence voters in an election.

Two months before a UK Parliamentary general election, the animal welfare organisation, that is registered with the Electoral Commission, retweets, without commenting on it, a news article reporting that the party of government has announced they will legalise fox hunting if they are re-elected.

This is not election material. This is merely sharing information, and the organisation would be expected to share any news relevant to their work. No imprint is required.

Once all the main parties have launched their manifestos in advance of a UK Parliamentary general election, the registered non-party campaigner compares their manifesto pledges on fox hunting. They create a graphic comparing the parties’ positions on the issue, giving marks out of ten and saying which party has the best policies. They then publish the graphic on their own social media channels.

Because the campaigner has compared the parties and said which is better in this context, they have effectively promoted some over others. The graphic is therefore reasonably regarded as promoting those parties the campaigner considers to have better policies, so is election material. An imprint is required on the material.

During the referendum period for a PPERA referendum, a registered non-party campaigner publishes a blog post on their website setting out what they see as the consequences of each outcome for their service users.

This requires an imprint. For organic material which is published during the referendum period, it does not matter whether or not the material promotes an outcome in the referendum – it only needs to wholly or mainly relate to the referendum.

Organic material – unregistered campaigners

If you are a non-party campaigner who is not registered with the Electoral Commission, then you do not need to include an imprint on any organic digital material you publish on your own behalf. This is because an unregistered non-party campaigner is not a relevant entity.

Unregistered non-party campaigners who only publish material on their own behalf will only need to include an imprint on paid adverts.

Last updated: 2 November 2023