The Representation of the People Bill is a major step forward for our democracy. It will give more young people a say, modernise our outdated registration system and strengthen rules around campaign finance. These are reforms the Electoral Reform Society has campaigned for over many years – important changes that will help make our elections fairer and remove barriers to voters participating.
It is important that the ambitions of this bill are secured in practice by ensuring that votes at 16 and a modernised registration system are delivered in time for the next General Election; that changes to the voter ID scheme help those most impacted and ensure that no eligible voter is prevented from voting in future; that political finance measures are robust enough; and that our elections regulator is independent of government and equipped to enforce the rules.
Part 1 – Young Voters
Extending the franchise is an opportunity to nurture more active citizens for the future. By giving 16- and 17-year-olds a vote we can engage the next generation in politics and improve the future health of our democracy.
Research has shown that the younger people are engaged in voting, the more likely they are to carry on voting later in their lives and that enfranchised 16- and 17-year-olds also tend to turnout to vote in greater numbers than those voting for the first time aged 18 and over.[1] This is likely because younger voters are better supported through their first experience of voting whilst they are at home and in education.
There is also some evidence to suggest that inequalities in participation are reduced. In Scotland, newly enfranchised young people of all social groups were equally likely to be politically engaged.[2] In Wales, gender gaps in perceived political knowledge (seen in all other age groups) were not present amongst 16- and 17-year-olds.[3]
Votes at 16 has potential to improve democratic participation for the future.
To ensure votes at 16 realises these positive democratic impacts it is vital that younger people are supported through democratic education. Democratic education can provide younger voters with the confidence, efficacy and interest to get involved at the same time as gaining the right to vote increases young people’s desire to learn about political issues.
It is also vital that modernisations to voter registration are made to ensure that young people (who are the least likely to be registered) do not miss out, and that they are supported with early awareness and information campaigns. Lessons from the introduction of votes at 16 in Wales show the importance of early interventions on awareness, registration and mobilisation.[4]
Automatic voter registration, improved voter engagement and democratic education can help make votes at 16 a major moment of democratic change and renewal in the UK.
Enfranchising 16- and 17-year-olds would not drastically change the electoral landscape[5] (evidence from around the world shows that young people have diverse attitudes, do not vote as a uniform bloc and do not change the broader political landscape) but it would allow young people to have a voice in the decisions that are made for them every day at local, regional and national level.
For more information on Votes at 16: https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/briefing-on-votes-at-16-2026/
Part 2 – Registration of Voters
Comprehensive and accurate electoral registration is central to democratic participation. It is vital therefore that all possible steps should be taken to ensure everyone who is eligible to vote is registered. Registration without application, a more automatic form of registration, is a much-needed improvement to our outdated voter registration system.
The Electoral Commission’s most recent analysis of electoral registers estimated that between 7 and 8 million people are missing from the electoral rolls.[6] ERS constituency estimates based on these findings suggest that, in some places, as much as 20% of the total eligible population is likely to be missing from the register.[7] [For our interactive constituency map visit: https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/automatic-voter-registration-avr-briefing/]
Completeness has remained fairly static over time and the Electoral Commission has stated that, ‘there is little evidence to suggest that levels of accuracy and completeness are likely to significantly improve without major changes to the current electoral registration system.’[8]
81% of British people support automatically registering voters with 48% strongly supporting this change.[9]
Not only are millions missing from the electoral rolls but those missing are unequally distributed across society. Research suggests that the current system of registration is proving a barrier, particularly to young people and people in privately rented accommodation. In 2022, 65% of private renters were registered compared to 95% of owner occupiers and 88% of those with a mortgage; only 60% of 18- and 19-year-olds were registered compared to 96% of those aged 65 and over and only 16% of attainers (those aged 16 and 17 in England) were registered.[10]
Most countries use a form of automatic registration[11] and pilots of automatic registration in Wales have shown how much it can improve completeness of the registers (even when restricted to local data).[12] Changes to the annual canvass have already moved the UK’s system closer to automatic registration with EROs using data-matching as an integral part of the registration process and re-registering those who can be reliably matched.
Registration without application has great potential to improve voter registration and ensure that every eligible voter can participate. But it is essential that progress is made quickly to establish pilots and move to registration without application so that at the next General Election millions do not miss out.
For more information on modernising registration: https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/briefing-on-modernising-electoral-registration/
Part 3 – Conduct of Elections
s47 – Voter identification requirements
The introduction of photographic ID in the Elections Act 2022 has, to date, prevented over 42,000 people casting their vote. Despite little evidence to suggest voter ID was needed, the current scheme is highly restrictive with only a handful of IDs accepted (many of which need to be paid for). Expanding the types of IDs that will be accepted is a welcome move.
Out of all alleged cases of electoral fraud in the 2019 elections, only 33 related to personation fraud at the polling station[13] – this comprises 0.000057% of the over 58 million votes cast in all the elections that took place that year. Only one of those allegations resulted in a conviction, and one a caution.[14] Despite this, the voter ID scheme introduced in the Elections Act 2022 is highly restrictive (compared to other countries that do not have a national ID card) with only a limited number of photographic IDs deemed acceptable and no alternatives for voters who turn up without ID.
The Electoral Commission reported that in the 2024 General Election around 16,000 electors attempted, but were unable to vote due to the Voter ID requirement; this equates to 1 in every 1,200 voters.[15] Similarly, the May 2024 local and mayoral elections reported around 13,000 electors attempted to vote but were turned away because they lacked accepted ID and did not return; in the May 2023 local elections this figure was around 14,000.[16]
Across the first three sets of elections using Voter ID, at least 42,368 voters were denied their right to vote.*[17] [18]
In addition, many voters appear to have been put off by the new requirement. According to the Electoral Commission, when given a list of options, 10% of non-voters gave voter ID as the reason that they did not vote in the 2024 General Election, this figure was 4% when unprompted. Ipsos polling also found that 8% of people said that voter ID made them less likely to want to vote in the May 2023 local elections.[19]
Only 25,000 Voter Authority Certificates were used as ID in local elections in 2023, 22,749 at the local and mayoral elections in 2024 and 72,497 in 2024 General Election. This is far fewer than the number of registered voters who are estimated to need one (around 750,000).[20]
Increasing the range of acceptable identity documents, including non-photographic ID, would make the scheme more proportional. The Cabinet Office report ‘Securing the ballot’, which first suggested introducing ID, recommended that: ‘There is no need to be over elaborate; measures should enhance public confidence and be proportional.’[21] When voter ID was first introduced in Northern Ireland it was not solely photographic ID and elections took place for almost 20 years with this less stringent requirement.
Allowing IDs like bank cards and digital ID, which voters are likely to be carrying on them, will help voters who do not have access to the more restricted forms of ID and make it easier for all voters on the day.
Improvements to prevent any more eligible voters losing their right to vote are essential, but we will only know if these improvements are working if we have records of who is turned away at the polling station. It is critical that the impact of voter ID is monitored and reported to ensure that we have a full picture of how this policy is affecting voters and whether further changes, such as vouching or statutory declarations, are needed.
For more information on Voter ID: https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/briefing-on-voter-id-2026/
Part 4 – Campaigns and Political Donations
s58-s62 – Control of political donations
The role of money in politics is fundamental to the quality of our democracy. Today in our democracy, voters can readily see that those with deeper pockets have more of a say, and this corrodes public confidence. It is vital that we provide greater protection from foreign interference and corruption, and importantly, provide voters with more reason to feel confident that their voices matter.
S60 – donations by companies: The risk of shell companies being used to funnel foreign funds into UK politics was first identified as a risk prior to PPERA.[22] It is very welcome therefore that this bill seeks to address this vulnerability by requiring donor companies to demonstrate they have made sufficient funds in the UK and have a UK connection. However, a UK profit test (instead of revenue) would provide stronger protection in this regard.
s62 – Unincorporated Associations: Donations from Unincorporated Associations (UAs) present a well-documented gap in the UK’s political finance transparency requirements. A lack of transparency around the source of UAs’ political donations undermines efforts to have an open and transparent political finance regime and with few safeguards to prevent impermissible donations, UAs are a potential conduit for foreign funding entering UK politics. It is therefore welcome that this bill seeks to address these issues by introducing permissibility checks, increasing reporting requirements and lowering the contribution thresholds for triggering reporting, as well as extending the rules to candidate donations. However, at £11,180, the threshold for reporting is still high – especially if this same threshold applies to candidate donations.
Donations cap
Over time, both the total amount of donations and the number of very large donations (those over £1 million) from private sources have increased. The extent to which parties are reliant on a handful of very wealthy donors is recognised by the public and is a cause for concern. YouGov finds that 60% of people think that wealthy donors give money to gain influence compared to the 6% who this it is driven by support for the party. [23] Only 13% of people think that there should be no limits on how much people can give in political donations.[24]
In 2011 the Committee on Standards in Public Life produced a report addressing the problems of an increased reliance on significant donations. In their report the Committee said, ‘Over the last few decades all three main parties have instead become dependent on a small number of relatively large donations from individuals, trade unions (for the Labour Party) or other organisations. This dependency has inevitably created a risk that favours will be asked or given in return.’ The CSPL recommended a cap of £10,000 for donations from a single source in a year and for trade union donations to be treated as an aggregation of individual donations subject to opt-in rules.[25]
Since that report, the key problems identified have intensified. Our politics is too reliant on too few, and the sums involved are simply too large. Reducing the amount that single private sources can give to parties not only helps create a fair democratic contest but also protects parties and their representatives.
A donations cap would prevent a small number of wealthy donors dominating political finance, would reduce corruption risk, and is popular with the public.[26]
For more information on political finance: https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/briefing-on-political-finance/
s63-s64 – Information to be included with electronic material
The Electoral Reform Society has long advocated for the extension of the imprint regime to digital election material. Digital imprints, stating who has paid for and promoted content, are aimed at enhancing transparency about who is behind online campaign material. Voters should know who is trying to influence their vote so they are able to make an informed decision at the ballot box, and to hold those seeking to persuade them to account after the election.
Whilst an extension of the current regime is welcome, imprints alone do not provide voters with the full picture. An online ad repository or ‘library’ would assist with improving transparency around digital campaigning. This would allow both the public and regulators to view ads across all platforms and help to identify campaigns that are designed to mislead the audience about their source.
Part 5 – Enforcement and the Electoral Commission
s67 Abolition of maximum penalties in respect of offences triable summarily
An increase to the maximum fine that the Electoral Commission can impose is a welcome step. Currently limited to a maximum individual fine of £20,000, these fines can simply be seen as the ‘cost of doing business’. Multiple parliamentary committees, civil society organisations and campaigners have called for the Commission’s fines to be increased in recent years to provide an effective deterrent.[27] For comparison, the ICO is able to fine organisations up to four percent of global turnover, or £17 million.[28]
Electoral Commission independence
The 2022 Elections Act introduced a requirement for the Electoral Commission to ‘have regard to’ a strategy and policy statement set by ministers which reflects the government’s policy priorities and set out the ‘roles and responsibilities’ of the Commission in achieving those priorities. The Commission must now report annually against that statement to the Speaker’s Committee. A significant imposition on regulatory autonomy.
Electoral management body independence is set out under international law and in a range of international guidelines (such as the OSCE’s Office for Democratic Institutions and Human Rights guidance and the Council of Europe Venice Commission code of practice).
The change brought in under the 2022 Act was criticised by two different international electoral observer missions during the 2024 General Elections.[29] The Electoral Commission have themselves been highly critical of the change noting that allowing government to guide its work, ‘is inconsistent with the role that an independent electoral commission plays in a healthy democracy.’[30] In addition, there is nothing to prevent a government majority on the Speaker’s Committee through which the Electoral Commission is directly accountable to parliament.
The Strategy and Policy Statement and lack of safeguards create a very dangerous set of instruments that could seriously damage electoral integrity.
It is critical that the Electoral Commission’s independence is restored by removing the strategy and policy statement provisions in part 3 of the Elections Act 2022. It is also important to ensure that the Speaker’s Committee remains cross-party, and this could be strengthened by inviting ordinary ‘lay’ members of the public to join the committee (much like Parliament’s Standards Committee) and putting in place measures to prevent any party having a majority on the committee.
For more information on any of the issues in the briefing please contact [email protected]
[1] Huebner, C., and Eichhorn, J., ‘Evidence and Good Practice on Lowering the Voting Age to 16’. https://www.jrrt.org.uk/wp-content/uploads/2025/01/Votes-at-16-report-FINAL.pdf
[2] Huebner, C. & Eichhorn, J. (2022). The Tide Raising all Boats? Social Class Differences in Political Participation among Young People in Scotland. Scottish Affairs, 31(2), 165-189.
[3] Griffiths, J. D., Larner, J., Wyn Jones, R., & Poole, E. G., (2025) ‘A False Start: Votes-at-16 in Wales in the 2021 Senedd Cymru election’, Wales Governance Centre.
[4] Huebner, C., Smith, K. A., Mycock, A., Loughran, T., & Eichhorn, J. (2021). ‘Making Votes-at-16 Work in Wales. Lessons for the Future’ (pp. 1–34). Nottingham: Nottingham Trent University. https://www.ntu.ac.uk/media/documents/nce/Huebner-et-al_2021_Making-Votes-at-16-work-in-Wales.pdf
[5] ONS Research in 2017 showed there was around 1.5 million 16- and 17-year-olds in the UK (the current figure stands at 1.6 million). If enfranchised this group would make up around 3% of the voting age population. The small size of this cohort would have little impact on vote shares even if they achieved 100% turnout and all voted the same way. https://www.ons.gov.uk/peoplepopulationandcommunity/elections/electoralregistration/articles/whatimpactcouldloweringtheukvotingageto16haveontheshapeoftheelectorate/2017-07-14
[6] The Electoral Commission, “2023 report: Electoral registers in the UK”, 2023. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/accuracy-and-completeness-electoral-registers/2023-report-electoral-registers-uk
[7] (Cities of London and Westminster (20.3%), Leeds Central and Headingley (20.2%), Bristol Central (19.6%), Sheffield Central (19.5%)).[7] Estimates are based on ONS 2021 Census and Scottish Census 2022 population figures and Electoral Commission data on registration levels by housing tenure. https://electoral-reform.org.uk/latest-news-and-research/parliamentary-briefings/automatic-voter-registration-avr-briefing/
[8] Electoral Commission ‘2023 report: Electoral registers in the UK’, 2023
Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/2023-report-electoral-registers-uk
[9] https://yougov.co.uk/politics/articles/49960-what-electoral-reform-proposals-would-britons-support
[10] Electoral Commission, ‘Who is and isn’t registered to vote’, 2022. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/explore-data-who-and-isnt-registered-vote
[11] Toby. S. James and Paul Bernal (2020) Is it time for Automatic Voter Registration in the UK? Joseph Rowntree Reform Trust: York. https://www.jrrt.org.uk/wp-content/uploads/2020/04/Is_it_time_for_AVR_in_the_UK.pdf
[12] Electoral Commission, ‘Automatic registration pilots evaluation’, 2025. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-registration-research/automatic-registration-pilots-evaluation
[13] Uberoi and Johnstone, “Political disengagement in the UK: Who is disengaged?”, House of Commons Library, 2022. Available at: https://researchbriefings.files.parliament.uk/documents/CBP-7501/CBP-7501.pdf
[14] Electoral Commission, “2019 Electoral Fraud Data”, 2020. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/electoral-fraud-data/2019-electoral-fraud-data
[15] Electoral Commission, “Voter ID at the 2024 UK general election”, 2024. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-2024-uk-general-election
[16] Electoral Commission, “Voter ID at the May 2023 local elections in England: interim analysis”, 2023. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-may-2023-local-elections-england-interim-analysis
[17] Ibid.
* Those recorded as having been turned away and did not return at the 2023 local elections, 2024 local and mayoral elections and 2024 General Election combined. The 2024 General Election was the last election in which returning officers were legally required to collect these statistics.
[18] Electoral Commission, “Voter ID at the 2024 UK general election”, 2024. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/voter-id-2024-uk-general-election
[19] Ipsos UK, “Written evidence (VID0010) House of Lords Constitution Committee inquiry into voter ID”, 2023. Available at: https://committees.parliament.uk/writtenevidence/126939/pdf/
[20] The Electoral Commission, “Voter ID at the May 2023 local elections in England: interim analysis”, 2023. Available at: https://www.electoralcommission.org.uk/research-reports-and-data/our-reports-and-data-past-elections-and-referendums/report-may-2023-local-elections-england
[21] Cabinet Office, ‘Securing the Ballot: review into electoral fraud’, 2016. https://www.gov.uk/government/publications/securing-the-ballot-review-into-electoral-fraud
[22] Committee on Standards in Public Life, fifth report, ‘The Funding of Political Parties in the United Kingdom’, 1998. Available at: https://assets.publishing.service.gov.uk/media/5a7daa32e5274a5eaea6596a/5thInquiry_FullReport.pdf
[23] YouGov, 23 September 2024, 4046 GB adults: ‘Do you think that wealthy people make donations to individual politicians more because they support them and want them and their party to succeed, or more because they are trying to gain influence?’ https://yougov.co.uk/topics/politics/survey-results/daily/2024/09/23/a132c/1
[24] YouGov, biannual tracker at 29 December 2025, 1668 – 1804 GB Adults: ‘Should there be a limit of donations made to political parties by individuals?’
https://yougov.co.uk/topics/politics/trackers/should-there-be-a-limit-of-donations-made-to-political-parties-by-individuals
[25] Committee on Standards in Public Life, thirteenth report, ‘Political Party Finance: ending the big donor culture’, 2011. Available at: https://www.gov.uk/government/publications/political-party-finance-ending-the-big-donor-culture
[26] For example: Poll by Survation on behalf of 38degrees, cited in PoliticsHome, ‘Strong Support For Bringing In A Cap On Political Donations’, 23 Dec 2025. https://www.politicshome.com/news/article/strong-support-for-cap-on-political-party-donations-poll-shows; Electoral Reform Society, ‘Deal or No Deal’, https://www.electoral-reform.org.uk/wp-content/uploads/2017/06/Deal-or-no-deal-Party-Funding.pdf
[27] See, for example, Electoral Reform Society, ‘Reining in the Political ‘Wild West’: Campaign Rules for the 21st Century’, 2019. https://www.electoral-reform.org.uk/latest-news-and-research/publications/reining-in-the-political-wild-west-campaign-rules-for-the-21st-century/#sub-section-9
[28]See, for example, Electoral Reform Society, ‘Reining in the Political ‘Wild West’: Campaign Rules for the 21st Century’, 2019. https://www.electoral-reform.org.uk/latest-news-and-research/publications/reining-in-the-political-wild-west-campaign-rules-for-the-21st-century/#sub-section-9
[29] Commonwealth Parliamentary Association, ‘Final Report CPA BIMR Election Assessment Mission’ (pages 8/9) https://www.uk-cpa.org/media/gyskl0w3/final-report-cpa-bimr-election-assessment-mission-uk-general-election-2024.pdf
OSCE office for Democratic Institutions and Human Rights, ‘United Kingdom, General Election, 4 July 2024: Final Report’, 2025 (Page 10) https://www.osce.org/odihr/elections/uk/592972
[30] Electoral Commission, Letter from Commissioners: Strategy and Policy Statement measures in the Elections Bill, February 2022. Available at: https://www.electoralcommission.org.uk/news-and-views/key-correspondence/letter-commissioners-strategy-and-policy-statement-measures-elections-bill