Representation of the People Bill — Impact Assessments: Impact assessment from the Ministry of Housing, Communities & Local Government

1 OFFICIAL OFFICIAL Update Title: Representation of the People Bill Impact Assessment IA No: Lead department or agency: Ministry of Housing, Communities & Local Government Other departments or agencies: N/A Impact Assessment (IA) Date: February 2026 Stage: Bill Source of intervention: Domestic Type of measure: Primary Legislation Contact for enquiries: electionsresearchanalysismailbox@commu nities.gov.uk Summary: Intervention and Options RPC Opinion: N/A Cost of Preferred (or more likely) Option (in 2025 prices) Total Net Present Social Value Business Net Present Value Net cost to business per year Business Impact Target Status £0 -£107.2m £0 £0 What is the problem under consideration? Why is government action or intervention necessary? Democratic engagement is waning. Millions of eligible electors are either incorrectly registered or not registered at all. Increased security threats, cases of harassment and intimidation, and concerns around foreign interference, have undermined trust in politics and contributed to reduced confidence in our political system. Without reform, there is a risk that trust in the democratic process worsens, undermining participation and representation, and that our electoral system remains susceptible to evolving risks. To safeguard our democracy and ensure community empowerment, the electoral system must be strengthened. Government intervention is necessary to build this resilience and reduce risks of delivery failure, as it holds the legislative power to improve electoral administration and campaign regulation, thereby restoring public confidence, enhancing democratic engagement, and ensuring votes genuinely reflect individuals’ voices and perspectives. What are the policy objectives of the action or intervention and the intended effects? The interventions aim to strengthen democracy and reinforce the resilience of our electoral system through: • Broadening democratic engagement • Reducing the major risks in election delivery, electoral registration, electoral campaigning and political finance • Removing barriers to participation in democracy Intended outcomes include improving accuracy and completeness of electoral registers, expanding participation among young voters by lowering the voting age to 16, reducing barriers to voting, protecting the UK’s democracy from foreign interference, closing loopholes in political finance, reducing harassment in politics, ensure fairness and enhancing the resilience in our electoral system. Ultimately, these interventions seek to underpin public trust in our democracy. What policy options have been considered, including any alternatives to regulation? Please justify preferred option (further details in Evidence Base) A range of options have been considered to strengthen democratic participation and safeguard electoral integrity: • Do nothing: This option risks weakening trust in the democratic process and reductions to participation and representation, and leaves the electoral system exposed to evolving risks. • Non-legislative approach: For example, this could include a democratic engagement programme, increased communications or provision of guidance. However, these interventions alone would not be sufficient to tackle underlying issues facing the electoral system. As this option does not meet strategic objectives, it was rejected. • Legislative approach (preferred): This option augments non-legislative interventions with legislative changes including lowering the voting age, transforming registration practices and allowing the use of bank cards as a form of ID for voting. Unlike the other options, this option will deliver the policy objectives by tackling the systemic issues facing the electoral system, and is necessary to ensure the government delivers on its manifesto commitments. Will the policy be reviewed? Yes, see section L. Is this measure likely to impact on international trade and investment? No Are any of these organisations in scope? Micro No Small No Medium No Large No What is the CO2 equivalent change in greenhouse gas emissions? (Million tonnes CO2 equivalent) Traded: N/A Non-traded: N/A I have read the Impact Assessment and I am satisfied that, given the available evidence, it represents a reasonable view of the likely costs, benefits and impact of the leading options. Signed by the responsible SELECT SIGNATORY: Date: 2 OFFICIAL OFFICIAL Summary: Analysis & Evidence Option: Do nothing Description: FULL ECONOMIC ASSESSMENT Price Base Year 2025 PV Base Year 2025 Time Period Years 10 Net Benefit (Present Value (PV)) (£m) Low: 0 High: 0 Best Estimate: 0 COSTS (£m) Total Transition (Constant Price) Years Average Annual (excl. Transition) (Constant Price) Total Cost (Present Value) Low 0 0 0 High 0 0 0 Best Estimate 0 0 0 Description and scale of key monetised costs by ‘main affected groups’ There are no monetised costs resulting from this option. Other key non-monetised costs by ‘main affected groups’ 1. Failure to meet the Government’s objective to strengthen democracy and reinforce the resilience of our electoral system and deliver manifesto commitments. BENEFITS (£m) Total Transition (Constant Price) Years Average Annual (excl. Transition) (Constant Price) Total Benefit (Present Value) Low 0 0 0 High 0 0 0 Best Estimate 0 0 0 Description and scale of key monetised benefits by ‘main affected groups’ There are no monetised benefits resulting from this option. Other key non-monetised benefits by ‘main affected groups’ There are no non-monetised benefits resulting from this option. Key assumptions/sensitivities/risks Discount rate (%) N/A Not applicable. BUSINESS ASSESSMENT (Option: Legislative Approach) Direct impact on business (Equivalent Annual) £m: Score for Business Impact Target (qualifying provisions only) £m: Costs: 0 Benefits: 0 Net: 0 0 3 OFFICIAL OFFICIAL Summary: Analysis & Evidence Option: Legislative Approach Description: FULL ECONOMIC ASSESSMENT Price Base Year 2025 PV Base Year 2025 Time Period Years 10 Net Benefit (Present Value (PV)) (£m) Low: -53.6 High: -160.8 Best Estimate: -107.2 BUSINESS ASSESSMENT (Option: Legislative Approach) Direct impact on business (Equivalent Annual) £m: Score for Business Impact Target (qualifying provisions only) £m: Costs: 0 Benefits: 0 Net: 0 0 COSTS (£m) Total Transition (Constant Price) Years Average Annual (excl. Transition) (Constant Price) Total Cost (Present Value) Low 0 7.4 53.6 High 0 22.2 160.8 Best Estimate 0 14.8 107.2 Description and scale of key monetised costs by ‘main affected groups’ 1. Votes at 16 - this policy is estimated to cost £88.0m. 2. The Electoral Commission and Enforcement - this policy is estimated to cost £13.3m. 3. Improving Registration - this policy is estimated to cost £5.2m. Other key non-monetised costs by ‘main affected groups’ 1. Practical challenges of implementing new registration systems – including resource investment to develop and maintain infrastructure and train staff. 2. Added complexity of voter ID checks – Allowing bank cards to be used as identification in polling stations could introduce complexity where cards lack identifying features. Electoral administrators will be trained to recognise such cards and apply clear guidance on verification standards. 3. Concerns of personation – Allowing bank cards to be used as voter ID may raise public concerns about the risk of personation, but if there is, any actual incidence is expected to be very low. This is considered a proportionate risk in order to ensure that no legitimate elector is prevented or discouraged from voting due to ID requirements. 4. Potentially diminished value of open register – Should a large proportion of electors choose not to opt-in, the dataset may be too limited to retain its current utility, which may diminish its value for businesses. However, completeness of the open register has already been in decline over recent years. BENEFITS (£m) Total Transition (Constant Price) Years Average Annual (excl. Transition) (Constant Price) Total Benefit (Present Value) Low 0 0 0 High 0 0 0 Best Estimate 0 0 0 Description and scale of key monetised benefits by ‘main affected groups’ There are no monetised benefits resulting from these policies Other key non-monetised benefits by ‘main affected groups’ 1. Building a long lasting engagement with our democracy. Engaging voters early will build the foundations for their participation in democracy. There is evidence this could close the participation gap for younger voters and build lifelong voting habits, if introduced alongside the right conditions. 2. Improving the completeness and accuracy of the electoral registers. This could result in more people being correctly registered at their current address and a higher percentage of eligible people being registered overall, ensuring a greater proportion of the population has the opportunity to exercise their democratic right to vote. 3. Minimising the possibility that legitimate electors are prevented or discouraged from voting by ID requirements. Amending the list of accepted documents, should address concerns that current voter ID requirements may pose a barrier for some electors and make it easier for eligible voters to meet the requirements when voting in polling stations. 4. Minimising the possibility that any individual is discouraged from participating in democracy due to harassment or intimidation. This will contribute to candidates, candidates, campaigners and elected officeholders feeling safer and being able to more effectively participate in elections and political debate without fear of intimidation. 5. Reducing the risk of foreign interference in our democratic processes by making it harder for malign actors to subvert the rules around donations to political parties. This will help to safeguard the integrity of elections by enhancing transparency and accountability around donation and in turn restore public trust in political financing. Key assumptions/sensitivities/risks Discount rate (%) 3.5 Elector behaviour is difficult to predict and there is a lack of evidence as to how electors’ behaviour will be impacted by the implementation of the policy changes. The costs and outcomes of the votes at 16 and improving registration policies will be impacted by the completeness of the electoral register for 16- and 17-year-olds and for the general population respectively. As these assumptions are uncertain, sensitivity analysis has been conducted to demonstrate the impact on outputs. The headline EANDCB does not include the diminished value of open register as this is classified as a second order effect. 4 OFFICIAL OFFICIAL Contents A. Problem under consideration and rationale for intervention ................................... 6 A.1 Votes at 16 ....................................................................................................... 6 A.2 Improving Registration ..................................................................................... 7 A.3 Voter ID ............................................................................................................ 9 A.4 Candidate ID and Nomination Changes ......................................................... 10 A.5 Outcomes of the Elections Review ................................................................ 11 A.6 Harassment and Intimidation .......................................................................... 12 A.7 Political Finance ............................................................................................. 13 A.8 The Electoral Commission and Enforcement ................................................. 14 A.9 Imprints .......................................................................................................... 15 A.10 Northern Ireland Measures ........................................................................... 16 B. Policy objective .................................................................................................... 17 B.1 Votes at 16 ..................................................................................................... 18 B.2 Improving Registration ................................................................................... 18 B.3 Voter ID .......................................................................................................... 19 B.4 Candidate ID and Nominations Changes ....................................................... 19 B.5 Outcomes of the Elections Review ................................................................. 20 B.6 Harassment and Intimidation .......................................................................... 21 B.7 Political Finance ............................................................................................. 21 B.8 The Electoral Commission and Enforcement ................................................. 22 B.9 Imprints .......................................................................................................... 22 B.10 Northern Ireland Measures ........................................................................... 22 C. Rationale and evidence to justify the level of analysis used in the IA .................. 23 D. Description of options considered ........................................................................ 23 E. Summary and preferred option with description of implementation plan .............. 33 F. Appraisal .............................................................................................................. 45 F.1 Votes at 16 ..................................................................................................... 46 F.2 Improving registration ..................................................................................... 63 F.3 Voter ID .......................................................................................................... 73 F.4 Candidate ID and Nomination Changes ......................................................... 78 F.5 Outcomes of the Elections Review ................................................................. 80 F.6 Harassment and Intimidation .......................................................................... 83 F.7 Political Finance ............................................................................................. 85 F.8 The Electoral Commission and Enforcement.................................................. 89 F.9 Imprints ........................................................................................................... 92 5 OFFICIAL OFFICIAL F.10 Northern Ireland Measures ........................................................................... 94 F.11 Summary of Option ....................................................................................... 96 G. Direct costs and benefits to business calculations............................................... 97 H. Risks and assumptions ........................................................................................ 98 H.1 Risks .............................................................................................................. 98 H.2 Sensitivity analysis ...................................................................................... 100 I. Impact on small and micro businesses ................................................................ 103 J. Wider impacts ..................................................................................................... 103 K. A summary of the potential trade implications of measure ................................. 111 L. Monitoring and evaluation .................................................................................. 111 6 OFFICIAL OFFICIAL A. Problem under consideration and rationale for intervention 1. Elections are the cornerstone of a healthy democracy, providing citizens with a direct means to steer the future of the country. With over 48 million registered voters in the UK 1, even small changes to electoral policy can have significant aggregate impacts. However, the effects on individual voters are often more nuanced, reflecting variations in personal circumstances and how different groups interact with the electoral system. For this reason, throughout this Impact Assessment (IA), we have sought to present the effects of proposed changes at both the aggregate and individual level. 2. Undermining of public trust in politics has led to reduced confidence in our political system. While the UK’s strong democratic systems and institutions are rightly regarded worldwide as a model of democracy and the right to participate in democracy is a defining aspect of our national identity, evolving security risks, ever- increasing levels of intimidation and harassment, and concerns around foreign interference all contribute to this undermining of trust. 3. The Government has a clear aim to strengthen democracy and reinforce the resilience of the UK’s electoral system. Strengthening and upholding the integrity of our elections is vital to ensure the needs of all people are fairly represented and considered. Broadening and deepening engagement in the democratic process is necessary to ensure a wide range of voices are properly heard and considered. 4. Government is the only entity that has the power to change administrative arrangements (via legislation) for running electoral events and the regulatory framework which governs campaigning. Implementation is mostly dependent on local authorities (LAs), statutorily independent Electoral Registration Officers (EROs) and Returning Officers (ROs), voters, political campaigners and the Electoral Commission (EC). A.1 Votes at 16 5. Our democracy must reflect modern society and empower young people . Young people are the future of our society, and are engaged and focused on the key issues affecting our country both domestically and internationally. Lowering the voting age will give young people a chance to have their say on issues that affect them on a local and a national level , empowering them to play an active role in shaping their future. 1 Electoral statistics, UK - Office for National Statistics, 2021 7 OFFICIAL OFFICIAL 6. There is a participation gap in our democratic processes , with levels of completeness for voter registration increasing with age. According to data from 2022, compared to other age groups, completeness of electoral registers is lowest for current attainers aged 16-172. According to a report by IPSOS3, a broadly similar pattern appeared in the 2024 United Kingdom Parliamentary General Election (UKPGE) as compared to previous elections, of lower turnout among younger people. While turnout estimates are uncertain and based off surveys rather than actual turnout data, they indicate that the estimated turnout for those aged 18– 24 (37%) was almost half that of those aged 65 and over (73%). This proposed franchise change could create a more engaged electorate and could even lead to an increase in turnout over time4. Thus, by supporting younger voters to participate in elections early, we expect to build the foundations for their lifelong participation in our electoral processes and reduce the voter registration gap. 7. Reducing the voting age for all elections will bring consistency in voting age across the UK. Scotland and Wales have already enfranchised 16 - and 17-year- olds in devolved elections. This change to the franchise will improve consistency across the UK. Scotland permanently lowered the voting age to 16 for devolved elections in 2015, having first lowered the voting age for the Independence Referendum in 20145 . Wales lowered the voting age in 2020, with the first Senedd election for that franchise occurring in 2021 6. A range of further jurisdictions have successfully lowered the voting age to 16 , including the Isle of Man, Jersey and Guernsey, and Austria. A.2 Improving Registration 8. An estimated 7-8 million eligible electors are either incorrectly registered or not registered to vote. While the current registration system works well, achieving around 86% completeness and 88% accuracy across Great Britain (GB) (83% and 86% respectively in Northern Ireland)2, there are clear opportunities to improve this and close the gap. There is evidence that some citizens find certain aspects of the system confusing, and some even assume that they are on the electoral register because they have used other government services and their information will have been passed on7. 9. There is currently insufficient join up of government services or data sharing, and no real consideration of the Government’s blueprint for a modern digital government, to enable better use of data and services. Eligible citizens are unable 2 Electoral registers in the UK - Electoral Commission, 2023 3 How Britain voted in the 2024 election – Ipsos, 2024 4 See section F.1.3.3 for discussion of the evidence around turnout. 5 Votes at 16 in Scotland - Eichhorn and Hübner, 2022 6 A False Start - Griffiths, Larner, Jones and Poole, 2025 7 Is it time for Automatic Voter Registration in the UK? - Joseph Rowntree Reform Trust, 2020 8 OFFICIAL OFFICIAL to be invited or reminded to apply to register or update their details when they interact with other services run by government. Current legislation also hinders the ability of EROs to identify people who are incorrectly registered or not registered at all, as it can be misinterpreted and does not allow for proactive sharing of relevant data by departments and public bodies. 10. Steps need to be taken to identify and support the registration of groups who are less likely to be registered accurately . A recent report by the EC 8 identified that these groups include young people, people living in rented accommodation and those who have recently moved. Moreover, length of residence at an address and age are the variables most associated with differences in completeness in GB and Northern Ireland. These factors are related, as young people are also more likely to be frequent movers (and therefore likely to live at an address for less than one year). There are also barriers for EROs in the voter registration system that increase ERO’s workload or don’t facilitate successful or accurate registrations. This includes managing duplicate applications and high volumes of applications in the run up to an election. 11. Current registration processes are hindered by outdated requirements that mandate a written application (digital or otherwise), preventing the adoption of more automated and efficient systems. Changes are necessary to enable the exploration and testing of more automated registration systems - including a process whereby individuals are registered without needing to apply , or give consent for data which they have already provided to be used as part of their application to register to vote . Countries like Canada and Australia have successfully implemented similar systems, demonstrating the potential benefits of this approach. 12. The current opt-out system of the open register is unfit for purpose . While access to the full electoral register is strictly controlled, the edited or ‘open’ register is available for sale to anyone and the data in it may be used for any legitimate purpose9. The EC has previously stated that the current ‘opt-out’ system should be replaced with one that allows electors to ‘opt-in’10. The AEA have also stated how the sale of the open register appears incompatible from a citizen’s perspective and could deter potential electors from registering by the prospect of having their details sold on11. Shifting from an opt-out to an opt-in model will also support the phased introduction of direct registration, an automated process that enables eligible individuals to be added to the electoral register without needing to actively apply. 8 Electoral registers in the UK - Electoral Commission, 2023 9 Electoral registers and access to them. July, 2025. 10 Transcript of oral evidence - Political and Constitutional Reform Committee, 2014 11 Response to the UK Parliament Committee Inquiry on Electoral Registration call for evidence - The Association of Electoral Administrators, 2023 9 OFFICIAL OFFICIAL The shift also will provide additional safeguards against anyone’s details appearing in publicly-available sources without their consent. 13. Electoral registration provisions for anonymous electors (AEs) are outdated and need updating . As it stands, upon successful application, AE status only remains valid for one year, so AEs are required to re-register annually. This places a disproportionate burden on AEs compared to non -AEs. While this policy may have been appropriate in 2006, when electoral registers were recreated annually based on the annual canvass, it is less appropriate today following the introduction of individual electoral registration and year-round online registration. A.3 Voter ID 14. Voters in the UK are required to show photographic documents as a means of identification at polling stations. This requirement was introduced through the Elections Act 2022 and first implemented at the May 2023 local elections. Voters can use a number of different forms of IDs and if they do not have one of these, they can apply for a Voter Authority Certificate (VAC), available free of charge from their LA, or may choose to vote by post or proxy. 15. Despite data collected following the implementation of the policy showing that the majority (84%) of electors are aware of the requirements, 0.25% of people who tried to vote at a polling station at the 2024 UKPGE were initially turned away due to lack of accepted ID 12. Around two-thirds of those people returned later in the day with an accepted form of ID and were able to vote. However, these statistics only record electors who were turned away at the polling station desk – they do not include electors who turned away at an earlier point in time or were dissuaded from voting. Research from public opinion surveys conducted after the UKPGE found that 3-4% of non -voters cited the voter ID policy as a factor in why they did not vote, suggesting a higher number of electors have been impacted.13 16. The provision of the VAC ensures all electors have an option to meet the ID requirements, free of charge , but uptake and awareness remain low. Awareness of the VAC among the overall population and among those who said they did not already have photo ID is reported as 58% and 57% respectively. The overall number of VACs applied for is low (210,000) compared with the estimated number of eligible, registered voters who might need it and not have any other accepted ID (around 750,000)12. Therefore, there remains a small proportion of the electorate that does not hold an accepted form of ID. For those electors the requirements are therefore creating a barrier which could lead to some electors being unable to vote or be dissuaded from doing so. 12 Voter ID at the 2024 UK general election - Electoral Commission, 2024 13 Voter ID at the 2024 UK general election - Electoral Commission, 2024; Evaluation of Electoral Integrity Programme: public opinion research wave 3 – MHCLG, 2025 10 OFFICIAL OFFICIAL 17. The enfranchisement of 16- and 17-year-olds will also need to be considered in the context of the Voter ID policy. Initial evidence published by the Department for Education (DfE) on public school pupils and college learners in England shows that this group has lower rates of ownership of passports and driving licences, two of the main items used by 18+ voters 14. Given 16- and 17-year-olds are ineligible for some of the accepted documents and may have less need to prove their identity in general, it is likely they will have a lower incidence of holding documents that could be used as ID overall and so may similarly face this barrier to voting. A.4 Candidate ID and Nomination Changes 18. The current nominations process does not require candidates to provide proof of identity, nor does it include a clear statutory declaration that all information provided is truthful. While it is a criminal offence to knowingly make a false statement on nomination papers, the existing forms do not make this sufficiently clear to candidates. This has raised concerns about the integrity of the nominations process and the potential for fr audulent or misleading nominations, particularly in light of recent cases where candidates have used tactics such as name changes to test the system and interfere with our democratic processes. 19. The Speaker’s Conference and some stakeholders have highlighted the need for stronger behavioural signals and clearer accountability mechanisms within the nominations process . Government intervention is necessary to strengthen the legal and procedural framework around candidate nominations, ensuring candidates are fully aware of the consequences of providing false information and enabling proportionate safeguards against imper sonation or deception. Withdrawal of Political Party Support for Nominations 20. Under current electoral law, once a candidate is validly nominated with a party description and emblem, that nomination is fixed unless the candidate themselves withdraws before the statutory deadline. There is no mechanism for a political party to formally withdraw its support or amend the nomination after submission, even if serious concerns about the candidate arise during the nomination period. 21. This legal position creates reputational risks for political parties and risks misleading voters who may unknowingly vote for candidates no longer supported by the party . It also limits parties’ ability to uphold standards and respond to emerging issues during the nomination period. By introducing a statutory mechanism allowing political parties to revoke their nomination of a 14 Parent, pupil and learner voice: March 2025 - DfE, 2025 11 OFFICIAL OFFICIAL candidate up to a defined point before the close of nominations, this intervention is expected to provide greater transparency, protect party reputations, and uphold public confidence in the democratic process. A.5 Outcomes of the Elections Review 22. The Review of Electoral Conduct and Registration 15 was commissioned in October 2024 in response to growing pressures on the electoral system. These pressures include the increasing complexity of electoral law, rising demand for postal voting16, and the operational challenges posed by unscheduled elections. Together, these factors have placed significant strain on ROs, EROs, and the wider electoral infrastructure. Without intervention, there is a risk that pressures could increase the likelihood of administrative errors, undermine the timely and effective delivery of elections and reduce voter confidence. 23. The Review identified several specific issues requiring attention including inefficiencies in the postal vote process, burdensome registration procedures and challenges with high levels of registration and absent vote application activity in the lead up to polls . It also highlighted challenges in securing polling venues, recruiting polling station staff, and ensuring that ROs have access to the resources they need. These issues affect LAs, electoral suppliers, and electors and if left unaddressed, they could lead to delays, increased costs, and reduced participation. The key recommendations that require primary legislation and are therefore in scope of this Impact Assessment are as follows: i. Electoral timetable ii. Absent voting iii. Electoral resourcing iv. Elector information power v. Election Forms Consolidation Measures 24. The Review’s recommendations are based on extensive engagement with key stakeholders who provided practical insights into the day -to-day challenges of running elections, helping to shape realistic and deliverable proposals. The Government is best placed to act on these findings, using its legislative and convening powers to implement reforms that will strengthen the system and support those responsible for delivering elections. Sector experts consulted include the EC, the Association of Electoral Administrators (AEA), Society of Local Authority Chief Executives (SOLACE), and electoral administrators across the UK , including the Electoral Management Boards in Scotland and Wales and the Electoral Office for Northern Ireland. 15 Letter from Minister Norris to the electoral sector - MHCLG, 2024 16 General Election 2005 - Mellows-Facer, 2006, Results and turnout at the 2015 UK general election - Electoral Commission, 2019, 2024 UK Parliamentary general election and the May 2024 elections - Electoral Commission, 2024 12 OFFICIAL OFFICIAL 25. Coordinated Government intervention is necessary to address these challenges and to ensure consistency, fairness, and resilience across the electoral system. While some LAs have introduced their own mitigations, such as register checkers or email communications, these efforts are inconsistent and cannot resolve systemic issues - such as the legal constraints around postal vote reissue. Many of the solutions require legislative change, national coordination, or access to central data systems. 26. Many electors struggle to access clear, consistent, and relevant information about elections , with 30% of voters reporting seeing misleading or inaccurate information about electoral processes at the recent UKPGE17. Electors often rely on multiple, inconsistent sources such as social media, or word of mouth which leads to confusion, reduced confidence, and in some cases, disengagement from voting. To address this, the Government plans to legislate for a duty on ROs and EROs to provide standardised election data to the EC or the Government. This will support the provision of timely, accessible, and impartial information to electors, and reduce the burden on local administrators. 27. The rules for different types of polls are set out in various separate and or interconnected pieces of legislation each with its own set of forms (poll cards, ballot papers, nomination papers etc) . A minor amendment results in duplication across legislation which is inefficient and time consuming. These measures would allow all prescribed forms to be amended via a single statutory instrument. A.6 Harassment and Intimidation 28. Harassment and intimidation in public life has been a long -standing issue. The last UKPGE campaign saw unacceptable harassment and intimidation towards candidates, campaigners and electoral staff. The EC’s post-poll report1717 following the UKPGE found that over half of candidates who responded to their survey (55%) felt that they had experienced some kind of problem with harassment, intimidation or abuse. Moreover, a third of respondents were intimidated or intentionally made to feel unsafe at least once during the campaign. 29. There is a lack of a deterrent towards those who may seek to intimidate electoral officials. A 2017 report 18 by the Committee on Standards in Public Life (CSPL) led to the introduction of the disqualification order, and refined the undue influence offence. Whilst the disqualification order is a crucial part of tackling intimidation and harassment, as a lone deterrent it does nothing to prevent those who have no interest in standing as a candidate from intimidating or harassing candidates, campaigners or electoral staff. 17 2024 UK Parliamentary general election and the May 2024 elections - Electoral Commission, 2024 18 Intimidation in Public Life - Committee on Standards in Public Life, 2017 13 OFFICIAL OFFICIAL 30. The publishing of candidate and member home addresses poses a security risk. This can affect whether people choose to stand for election when they intend to act as their own election agent. The ability for candidates acting as their own election agent to provide a correspondence address instead of their home address will provide further protection for candidates and will also help to ensure that no one is discouraged from participating in our democracy. A.7 Political Finance 31. Whilst there is no indication that UK politics is awash with illegitimate money, there is compelling evidence of the foreign interference threat to UK democratic processes. Evidence includes: • Intelligence and Security Committee’s (ISC’s) Russia Report19 identified several Putin-linked members of the Russian elite donating to UK political parties. The Government previously assessed that it was “almost certain that Russian actors sought to interfere in the 2019 UKPGE”. • The ISC’s China Report20 also warned of China’s intent to interfere with the UK Government and influence political thinking and decision -making, with individuals receiving “funds from overseas sources for onward donation to political parties, prospective Parliamentary candidates”. This evidence highlights how UK elections almost certainly represent attractive targets for malicious actors. 32. This evidence makes the case for addressing the vulnerabilities in the system by making specific enhancements to the existing controls on donors and recipients of donations to narrow the opportunity for subverting existing rules . This has been recommended by stakeholders including the EC, who have emphasised the need to strengthen the controls around donations and powers of regulators to improve the resilience against foreign influence. 33. Key electoral stakeholders including t he EC, CSPL, and campaign organisations, such as Spotlight on Corruption (SPoC) argue that the current permissibility test of a company “carrying on business” in the UK exposes political parties and other recipients to the risk of accepting foreign money and proceeds of crime. To remedy this, CSPL and other stakeholders have recommended requiring companies who wish to donate to link their profits to the UK. 34. The permissibility checks which recipients are required to carry out on donors are lagging behind the more stringent anti -money laundering and know - 19 Russia - Intelligence and Security Committee of Parliament, 2020 20 China - Intelligence and Security Committee of Parliament, 2023 14 OFFICIAL OFFICIAL your-customer obligations in corporate and charity sectors. The EC, CSPL, National Crime Agency (NCA) and SPoC have all called for introducing know -your-donor requirements to ensure that parties are attuned to the risk of foreign interference and know where their donations are coming from. 35. The EC and the CSPL have identified unincorporated associations (UAs) as potential vehicles for foreign or otherwise illegitimate money to enter electoral campaigns and therefore as a point of vulnerability in the political finance framework. Recommendations have been made to introduce tighter rules on UAs to address these risks. A.8 The Electoral Commission and Enforcement 36. The EC is the independent statutory body responsible for overseeing elections and regulating political finance, and therefore responsible for enforcing certain breaches of the political finance framework relating primarily to offences committed by political parties, third party campaigners and permitted participants in referendums . The enforcement regime is currently uneven, fragmented and lacks a proportionate and effective deterrent for offences . This undermines effective regulation, and it is potentially damaging to public confidence for offences to be seen to either go unpunished or for proportionate action not to be taken. Additional reforms to the role and powers of the EC are needed to strengthen enforcement of the framework and maximise the impact of the reforms to the political finance framework outlined above. 37. There is an ‘enforcement gap’ in the political finance framework, resulting in certain breaches of the rules often being left unaddressed and unsanctioned. The EC has been able to impose civil sanctions since 2010 for breaches committed by parties, third -party campaigners, and permitted participants in referendums. However, breaches by candidates, local third -party campaigners, and accredited campaigners at recall petitions can only be investigated by the police and referred for criminal prosecution. As cri minal prosecution is often considered disproportionate or not in the public interest, these breaches frequently go unpunished. 38. The fining powers of the EC are deemed insufficient to be an effective deterrent. The maximum fine that the EC can apply to punish breaches of the Political Parties, Elections and Referendums Act (PPERA) is £20,000 per offence (up to £10,000 for certain offences committed in Scotland and £5 ,000 in Northern Ireland). Numerous key stakeholders have described the current maximum fine as an inadequate deterrent that is seen by some campaigners as a “cost of doing business”. 15 OFFICIAL OFFICIAL 39. The EC lacks an explicit statutory gateway to share information with other regulators and law enforcement which makes information sharing burdensome and impedes cross-regulatory cooperation. 40. The EC has advised that the need for campaigners to seek leave from courts to pay late invoices adds unnecessary complexity and bureaucracy , thereby impeding administrative efficiency and effectiveness, noting that most late claims are for simple administrative reasons. 41. The criminalisation of administrative breaches can deter volunteers from participating in election campaigns. Some administrative requirements, such as failing to submit statutory expenditure reports on time, carry the possibility of criminal prosecution. While prosecution is unlikely in practice, the EC and the CSPL have expressed concerns that criminalising thes e minor breaches may have a ‘chilling effect’ on participation by deterring volunteers from participating in election campaigns. A.9 Imprints 42. Imprint rules play an important role in upholding trust in our democratic process by ensuring electors can see clearly who is behind political campaigning material. While these rules have improved the transparency of campaigning material, there remain transparency gaps and the split of enforcement responsibilities between the police and the EC is unnecessarily complicated. 43. A loophole in the current rules allows third -party campaigners who are not recognised to disseminate potentially influential digital content without disclosing its origin . This is because t hese organisations, who do not field candidates and spend below the £10,000 notification threshold , are not registered with the EC and therefore not subject to the same transparency requirements. This is particularly concerning when such material is designed to be shared virally, especially if it is misleading, controversial, or intended to manipulate public opinion without accountability. 44. The EC is unable to make minor corrections to its digital imprint guidance quickly. This is due to restrictive legal requirements, including the need for Secretary of State approval and a 40-day parliamentary procedure for any revisions to guidance. 45. The current division of responsibility for enforcing imprint rules, split between the police and the EC depending on the purpose of the material, creates confusion for both campaigners and enforcement bodies. This fragmented approach can lead to uncertainty and inconsistency in enforcement. Moreover, the possibility of criminal investigation and prosecution may be 16 OFFICIAL OFFICIAL disproportionate, particularly for volunteers and first -time candidates, and can discourage participation. Streamlining enforcement so that the EC takes primary responsibility for all imprint offences would bring greater clarity, consistency, and proportionality to the regime. A.10 Northern Ireland Measures The Northern Ireland canvass 46. The existing canvass regime in Northern Ireland is unfit for purpose. The current system requires that the register be recreated from scratch every 10 years and specifies that electors must re-register as part of the canvass to remain on the register, in spite of there being evidence to show that they remain eligible. This creates the risk that a significant number of electors will be lost from the register, impacting its integrity. 47. Government intervention is necessary to address these challenges and to reform and modernise the Northern Ireland canvass so that it is aligned more closely with the lighter -touch process in GB . Moving to a rolling system of registration will allow for the use of the data available to the Chief Electoral Officer (CEO) to avoid the arbitrary removal of voters that the Electoral Office for Northern Ireland (EONI) is confident are still eligible to be on the register. This is supported by the CEO for Northern Ireland and the EC. Adding National Insurance numbers to elector records 48. As the law stands, the CEO does not have powers to add a National Insurance number (NINo) to an elector’s record where they have not already included it on their registration form. In Northern Ireland, a NINo is required to be held on an elector’s record, along with date of birth, so that it can be used as a security check when an elector applies for an absent vote, electoral ID card or requests any information about their registration status. 49. Enabling the CEO to add NINos to an elector’s record where it is already known will improve registration by helping ensure electoral records are complete without seeking new or additional information from an applicant. This will support the implementation of Votes at 16 for 14 and 15 year old attainers, i.e. those registering in advance of their 16th birthday, who will be unlikely to meet the requirement to provide a NINo as part of their application. Late registration provisions 50. The current l ate-registration requirements in Northern Ireland are an outdated and unnecessary barrier to registration. They require that additional documentary evidence to support an application must always be provided by anyone trying to register just before an election, even if the data match is clear. 17 OFFICIAL OFFICIAL 51. Unless the provisions are repealed they are likely to be a particular barrier to younger electors who have fewer forms of documentary evidence than those over 18. To remedy this, the Government intends to amend these requirements so that the CEO will only ask for additional supporting documentation if the routine data checks do not provide a clear address and identity match. ‘Calling Out’ in polling Stations 52. The current ‘calling out’ law in Northern Ireland is outdated, unnecessary and can be unwelcome and intimidatory for electors. The law requires poll clerks to shout out the name and electoral number of everyone to whom they deliver a ballot paper, so that anyone seeking to commit personation may be caught out by anyone present and also facilitated political party representatives sitting within the polling station (polling agents) to write down who has voted. 53. This provision was originally UK wide, but was removed for GB in the Elections Act 2022 when voter ID was introduced. The majority of the Northern Ireland political parties, the CEO and the EC have all asked that NI move into line with GB and repeal these provisions. Amending electoral ID cards 54. There is a concern that the Electoral Office for Northern Ireland is, from limited budgets designed for electoral delivery, supporting a de facto national ID card system and issuing cards to some people who never intend to use them to vote. Third party organisations are using the card as a primary piece of documentary evidence to support identity for people applying for goods and services, which is not the primary purpose of this document. 55. Enabling EONI to produce a card that is sufficient to meet a narrow electoral requirement will prevent misuse. This could be achieved by including on new cards the month and year of birth only, not the day. This would still be a sufficient check for electoral purposes i.e. the intended purpose of the electoral ID card, but would be likely to make it less accepted as primary ID elsewhere. B. Policy objective 56. The Government has been clear on its aims to strengthen democracy and reinforce the resilience of our electoral system . Broadening and deepening engagement in the democratic process is seen a critical part of restoring trust in politics which has fallen in recent years. 57. The Government’s manifesto21 set out commitments to: 21 Change - Labour Party, 2024 18 OFFICIAL OFFICIAL • “…improve voter registration and address the inconsistencies in voter ID rules that prevent legitimate voters from voting…” • “... increase the engagement of young people in our democracy, by giving 16- and 17-year-olds the right to vote in all elections…” • “…protect democracy by strengthening the rules around donations to political parties...” 58. These commitments underpin three overarching policy objectives aimed at strengthening democratic participation and safeguarding electoral integrity: • Broaden democratic engagement • Reduce the major risks in election delivery, electoral registration, electoral campaigning and political finance • Remove barriers to participation in democracy. B.1 Votes at 16 59. The votes at 16 policy has two main objectives: • To build long lasting engagement with our democracy. By engaging people eligible to voter early, when they are young, the intention is to build the foundations for their participation in our electoral processes. In doing so, the policy aims to close the participation gap with younger voters and build lifelong voting habits. • To enfranchise a younger cohort of electors and ensure consistency for which elections 16 - and 17-year-olds can vote in regardless of where in the UK they live. The current system is not consistent. In Scotland and Wales, 16- and 17-year-olds can already vote in local council elections and in elections to the Scottish Parliament and Senedd Cymru. B.2 Improving Registration 60. The improving registration policy has five main objectives: • To improve the completeness and accuracy of the electoral registers. This will result in more people being correctly registered at their current address and a higher percentage of eligible people being registered overall, ensuring a greater proportion of the population has the opportunity to exercise their democratic right to vote. 19 OFFICIAL OFFICIAL • To improve registration rates among groups which are currently under - registered. Disproportionately affected g roups include young people, pri vate renters, some socio-economic groups, some minority ethnic groups and those who have moved address recently22. • To make it easier to register to vote , while ensuring that any new and enhanced approaches remain as accessible as possible. A shift towards more automated processes should enable more effective use of data across the Government estate and support individuals to quickly and easily register and keep their details up to date, in the way that suits them best. • To modernise the process for citizens to be added to the open electoral register. We will move from the existing opt -out process to require citizens to opt-in to appear on the open register. This is a truer form of consent and ensures that citizens can make informed choices about their data. Moreover, this shift will facilitate the grad ual introduction of direct registration by strengthening safeguards against individuals appearing on a publicly available version of the register without their explicit consent. • To improve provisions for anonymous electors (AEs). A new arrangement extending the period of time that AE status remains valid would relieve AEs from the disproportionate burden of having to re-register to vote every year. B.3 Voter ID 61. The voter ID policy has one main objective: • To minimise the possibility that legitimate elector s are prevented or discouraged from voting by the voter ID requirements, whilst also ensuring the security of our electoral system. Amending the li st of accepted documents , should address concerns that current voter ID requirements may pose too great a barrier for some elector s and make it easier for eligible electors to meet the requirements when voting in polling stations. B.4 Candidate ID and Nominations Changes 62. The candidate ID and nominations changes have one main policy objective per sub-policy, outlined below: Candidate ID and declaration • The policy objective is to strengthen the integrity and transparency of the candidate nominations process by introducing clearer legal 22 Electoral registers in the UK - Electoral Commission, 2023 20 OFFICIAL OFFICIAL accountability and proportionate identity safeguards . It will do so by requiring candidates to sign a statutory declaration confirming the truthfulness of their nomination information, and by mandating the submission of a scanned form of ID to be held securely by the Returning Officer for use only in the event of a formal challenge. Withdrawal of political party support for nominations • This policy objective is to strengthen public trust in the electoral process by enabling political parties to formally withdraw support for a candidate where serious concerns arise during the nomination period. By introducing a statutory mechanism for revocation, up to 48 hours before the close of nominations, the policy ensures voters are not misled about party endorsement, allows parties to uphold standards, and provides a clear legal route for disassociation without compromising the integrity or operational feasibility of the election. B.5 Outcomes of the Elections Review 63. The outcomes of the elections review policy areas have one main objective: • To strengthen the resilience and efficiency of electoral administration in the UK. It aims to reduce operational risks, streamline key processes , such as registration and postal voting, and improve the experience for voters and administrators. 64. Together, the reforms offer a practical, proportionate package that works within the existing legal framework while addressing the most pressing challenges in electoral delivery. An objective is set out for each sub-policy below. Electoral timetable • The policy objective is to reform the electoral timetable to better reflect operational realities. The current schedule compresses critical tasks like nominations and postal vote production, increasing the risk of delays. Proposed changes, such as moving the postal vote application deadline and aligning registration cut -offs, would ease pressure and facilitate more contingency. Absent voting • The policy objective is to address risks created by the ongoing increase in postal votes, and the pressure this puts on supply chains. With demand rising, reforms will allow earlier reissue of lost postal votes, clarify determination deadlines, and offer limited flexibility for voters to change their voting method close to polling day, The changes will help 21 OFFICIAL OFFICIAL Returning Officers to manage postal voting and provide additional contingency to help ensure electors can cast their vote. Election resourcing • The policy objective is to ensure that appointments are made at a level where LA officials will have the ability to command use of the resources of a LA if and when needed . These steps recognise elections as critical public functions requiring strong leadership and support. Election information power • The policy objective is to provide electors with clear, factual and accessible information about how to take part in elections . The policy will deliver this by taking powers in primary legislation to require ROs and EROs to provide relevant data to the EC or the Government . By standardising and centralising this information, the policy aims to improve education of electors and reduce administrative burden arising from subsequent confusion. Election forms consolidation measures • The policy objective is to simplify the complex process for updating various forms set out in legislation (e.g. poll cards, ballot papers and polling station voting instr uctions) by taking powers in primary legislation . This will be achieved by enabling the creation of a single statutory instrument which will reduce complexity, reduce the unnecessary burden on parliamentary time and increase efficiency. B.6 Harassment and Intimidation 65. The harassment and intimidation policy has one main objective: • To minimise the risk that any individual is discouraged from participating in democracy due to harassment or intimidation. Strengthening protections for those involved in public life and in the administration and delivery of elections, combined with appropriate sanctions for those who seek to damage democratic processes should contribute to this objective. B.7 Political Finance 66. The political finance policies have one main objective: • To reduce the risk of foreign interference and underhand practice in our democratic processes by making it harder for malign actors to subvert the rules around donations to political parties . These reforms will make it easier to detect and manage the risks of foreign interference, 22 OFFICIAL OFFICIAL strengthen the rules and close loopholes to protect against foreign interference. B.8 The Electoral Commission and Enforcement 67. The EC and enforcement policy has one main objective: • To strengthen the role and powers of the EC in regulating political finance, address historical enforcement gaps, and improve operational effectiveness. These changes will ensure that enforcement provides a clear deterrent against breaches of the political finance framework whilst remaining proportionate. B.9 Imprints 68. The imprints policy has one main objective: • To address transparency gaps in the digital imprint rules, place enforcement on a clearer and more proportionate footing , and enable the EC to make minor corrective changes to digital imprint gu idance more responsively. These changes will help facilitate appropriate scrutiny of political messaging and ensure voters can continued to make informed decisions in relation to political campaigning material. B.10 Northern Ireland Measures 69. The Northern Ireland measures have one main policy objective per sub -policy, outlined below: The Northern Ireland canvass ● The policy objective is to modernise and reform the canvass system in Northern Ireland, allowing for the CEO to retain those electors that they are satisfied are still resident where registered, avoiding the arbitrary removal of large numbers of voters and protecting the integrity of the register. This will bring Northern Ireland into closer alignment with GB. Adding National Insurance numbers to elector records ● The policy objective is to improve registration by helping ensure electoral records are complete without seeking new or additional information from an applicant. This policy should allow the CEO to add NINo to an elector’s record where they have not already included it on their registration form. Late registration provisions ● The policy objective is to remove an unnecessary barrier to registration in Northern Ireland, particularly for younger electors, by repealing unique requirements that additional documentary evidence to support an 23 OFFICIAL OFFICIAL application must always be provided by anyone trying to register just before an election, even if the data match is clear. This policy intends to amend these requirements so that the CEO will only ask for additional supporting documentation if the routine data checks do not provide a clear address and identity match. ‘Calling Out’ in polling stations ● The policy objective is to remove the outdated, unnecessary practice of ‘calling out’ in polling stations which can be unwelcome and intimidatory for electors. This also brings Northern Ireland into line with GB, where the practice of ‘calling out’ was removed in 2022. Amending electoral ID cards ● The policy objective is to ensure that electoral ID cards are used primarily for electoral purposes rather than be commonly used as a form of ID to support identity checks for non -electoral purposes such as people applying for goods or services. This will also alleviate some resource pressure on the Electoral Office for Northern Ireland who are responsible for producing the cards. C. Rationale and evidence to justify the level of analysis used in the IA 70. The approach taken in this IA is considered proportionate to the proposed changes outlined in the Elections Bill, as it quantifies the economic impact of the various components of the Bill where possible. 71. Where evidence is not readily available, qualitative analysis has been produced to better understand the potential impacts of the Bill. Some areas of the analysis, such as the percentage of the 16 - and 17- year-old franchise that choose to register , are subject to uncertainty. Therefore, sensitivity analysis has been conducted in Section H to test these assumptions. 72. Alongside the IA, literature reviews have been carried out to gather further evidence to assess the Bill’s wider impacts. These reviews have informed our analysis and policy development, particularly in relation to improving registration, democratic engagement, and examining the economic benefits associated with democracy. D. Description of options considered 73. A range of options have been considered to achieve the overall policy objectives of strengthening democracy and reinforcing the resilience of our 24 OFFICIAL OFFICIAL electoral system . This includes a doing nothing approach; a non-legislative approach centred around driving democratic engagement through effective communications, enhanced guidance and increased funding; and a legislative approach aimed at tackling systemic issues facing the electoral system through a range of mechanisms requiring legislation. 74. A summary of the extent to which these options would deliver the policy objectives is found in table 1 below. Do nothing 75. Without intervention of any kind, the current arrangements for the electoral process will continue. This option assumes that none of the Government proposals are implemented, which risks weakening trust in the democratic process, reducing participation and representation, and leaves the electoral system exposed to evolving risks. In particular: • The voting age would remain at 18 with 16- and 17-year-olds only able to participate in devolved and local elections in Scotland and Wales . This discrepancy creates a poor experience for young people in Scotland and Wales, making it difficult to articulate and understand their rights. It also leaves their peers in England unable to have the same level of engagement, leaving them without the opportunity to participate. • Missed opportunities to promote engagement and participation through civic opportunities and encouraging participation at a younger age. • An estimated 7-8 million eligible people would continue to be unregistered or registered incorrectly. The Government would miss the opportunity to address the registration gap and improve the completeness and accuracy of the register, as well as not supporting certain groups that are disproportionately affected by barriers to registration. • An opportunity to improve the registration system and better serve end users would be missed , as the potential benefits of utilising improved technology, streamlining and joining up services and supporting enhanced data sharing would be left unrealised. • Voter ID requirements would continue to pose a barrier to voting for a small proportion of voters who may find themselves unable to vote or dissuaded from doing so. • The nominations process would continue without any additional deterrents against false or misleading candidate declarations . This would limit the ability to challenge suspicious nominations and may fail to discourage individuals from providing inaccurate or deceptive information. 25 OFFICIAL OFFICIAL • Political parties would remain unable to formally withdraw support for a candidate once nominated, even where serious concerns arise. This would prevent parties from upholding standards and risk misleading voters about the level of party endorsement on the ballot paper. • The system would be at risk of worsening delays in postal vote delivery and subsequent return , increasing administrative burdens, and poor access to resources for ROs. These issues, if left unaddressed, could undermine voter confidence and the resilience of the system. • The longstanding, systemic issue of harassment and intimidation towards candidates, campaigners and electoral staff would continue to worsen as it has done in recent years. • The electoral donation system would remain at risk of foreign interference, with weak existing controls on donors and recipients leading to vulnerabilities in the system. • Existing transparency gaps for digital imprint rules, and fragmentation of enforcement would remain. 76. This option will not meet the policy objective, nor would it deliver the government’s manifesto commitments. This option is used as the counterfactual throughout this IA. To provide a counterfactual , this option assumes no other changes to the electoral system over the 10 year appraisal period. Therefore, there are no additional costs and benefits to the baseline associated with this option. Non-legislative approach 77. If implemented, a range of non-legislative interventions could contribute to addressing the issues faced by the electoral sector. This option assumes none of the legislative interventions are implemented. However, without such legislative change, these measures can only go so far in delivering the policy objectives. 78. Non-legislative interventions considered include: • A dedicated democratic engagement programme including civic and political education to close the participation gap. • Increased communications to promote awareness and use of the VAC , in particular for those groups who may be less likely to hold ID or less likely to be aware of the need to show ID when voting in person. • Strengthened guidance for prospective candidates to make them better aware of the rules for standing for election. 26 OFFICIAL OFFICIAL • Improved guidance, sector-led initiatives, and voluntary adoption of best practice are examples of non -regulatory interventions considered in the elections review. • Providing guidance to LAs to make clear the current expectations and legal powers around data sharing , in advance of new legislation which will further clarify the position around data sharing. • Signposting the registration to vote service to users as part of other government service journeys, to encourage more people to register. • Working with universities, the Further Education sector and other settings, where high numbers of people could be engaged in the democratic process, through innovative approaches and sharing of best practice. • A new code of conduct for candidates and campaigners, and new guidance for police on how to use existing law in an electoral context to help tackle harassment and intimidation issues. 79. Non-legislative interventions alone would not be sufficient to address the underlying challenges facing the electoral system . Consequently, the overarching policy objectives would remain unmet, and key government manifesto commitments undelivered. As such, a purely non-legislative approach falls outside the analytical scope of this IA. Legislative approach (preferred) 80. The preferred option is to augment the non -legislative interventions discussed above by implementing a complementary suite of legislative interventions, including: • Lowering the voting age to 16, engaging voters early, to build the foundations for their participation in our electoral processes and to help close the participation gap. • Transforming registration practices, to simplify the registration process by facilitating a move towards a system of more automated voter registration. • Introducing an opt-in system for the open register, replacing the status quo with a new default where individuals will only be included if they actively choose to opt in. 27 OFFICIAL OFFICIAL • Extending the duration of an AE entry from one year to three years , helping alleviate the disproportionate administrative burden currently placed on AEs and promote more inclusive democratic participation. • Allowing the use of bank cards as an accepted form of ID for voting. • Introducing an ID requirement for candidates along with a statutory declaration and allowing political parties to withdraw their support for nominated candidates before the deadline. • Adjusting key electoral deadlines , including moving the deadline for the submission of nominations papers, the registration deadline and postal vote application deadline • Improving the rules around postal and proxy voting to make sure electors have alternative options where their postal vote does not arrive in time to be returned before close of poll. • Centralising and standardising the collection and publishing of election data by Introducing for a duty on ROs and EROs to provide standardised election data to the EC or the Government. • Strengthening and building on existing deterrents against harassment and intimidation to ensure that no one is prevented or discouraged from participating in democracy. • Strengthen the role and powers of the EC, to ensure that enforcement provides a clear deterrent against breaches of the political finance framework whilst remaining proportionate. • Improve the transparency of digital imprint rules , give the EC primary responsibility for the enforcement of imprint offences , and enable the EC to make minor correcti ve changes to digital imprint guidance more responsively. 81. By integrating legislative measures with non -legislative interventions, this approach offers a comprehensive solution to the challenges confronting the electoral system and is best positioned to realise the stated policy objectives. Furthermore, it facilitates the government's delivery of its manifesto commitments. 82. A detailed description of the preferred options for and implementation of each policy can be found in section E. 28 OFFICIAL OFFICIAL Table 1: Extent to which options will deliver policy objectives Extent to which options will deliver policy objectives Policy Objective Do nothing Non-legislative approach Legislative approach Broaden democratic engagement X Without any action, the status quo would be maintained, meaning this option would not offer any additional value in achieving the goal of building long lasting engagement with our democracy. There would continue to be inconsistency in which elections 16- and 17-year- olds can vote across the UK. An estimated 7-8 million eligible voters would remain incorrectly registered or not registered at all. The Government would risk failing to support underrepresented groups who make up a disproportionate amount of those incorrectly registered or not registered at all. ~ There is no non-legislative option to extend voting rights to 16- and 17- year- olds. It is possible that building a long-lasting engagement with our democracy could be partially achieved without extending the franchise, through a dedicated democratic engagement programme. However, there is little evidence to suggest that civic and political education could close the participation gap in isolation meaning any proposals that are not accompanied by legislative change may not be effective. Attempting to drive registration rates through the existing system by focusing on improved democratic engagement is likely to only have limited effect and not necessarily reach those groups who are less likely to be registered. Current legislation hinders the ability of EROs to identify people who are incorrectly registered or not registered at all as it can be misinterpreted and it ✔ Lowering the voting age to 16 can only be achieved through primary legislation. By legislating, the Government intends to ensure that processes are in place to support all young people to participate, including measures to enable those with less conventional routes to registration, such as children looked after by LAs and those who reside overseas due to their parents’ being posted abroad. Evidence points to the act of participation and voting as the key enabler of increased participation. Hence, extending the parliamentary franchise could result in increased participation. Strengthening the data sharing legislation will allow for the proactive sharing of relevant data by departments and public bodies. This will ensure data sharing can be done in a timely and targeted way that supports EROs identify people who are incorrectly registered or not registered at all. 29 OFFICIAL OFFICIAL Extent to which options will deliver policy objectives Policy Objective Do nothing Non-legislative approach Legislative approach The electoral register in NI would still face the risk that a significant number of electors will be lost from the register every 10 years, impacting its integrity and maintaining a situation where eligible voters are incorrectly registered or not registered at all. Inaction in these areas would perpetuate inconsistency between Northern Ireland and the rest of the UK. does not allow for the proactive sharing of relevant data by departments and public bodies. To ensure that the approach to data sharing can be timely and targeted, legislative changes are necessary. Non-legislative options will not address the cliff edge faced periodically by the requirements of the current system whereby large numbers of electors in Northern Ireland who are entitled to be registered are required to be removed from the register. As with the do nothing option, without legislative change, the current canvass system would continue to pose a risk to the accuracy and integrity of the Northern Ireland register. Legislative change to data sharing powers and versions of more automated registration could lead to a meaningful improvement in the accuracy and completeness of the registers. The Government is committed to ensuring new approaches to registration are fully tested before implementation, to ensure that any unintended consequences can be resolved. This groundwork should reduce the risk that changes to the electoral system could compromise processes which are integral to the democratic process. Legislative change will enable the Government to modernise and reform the canvass system in Northern Ireland and encourage participation by removing the outdated and unnecessary practice of ‘calling out’ in polling stations. Reduce the major risks in election X Maintaining the current system without intervention would risk worsening delays in postal vote ~ The government is committed to taking forward a range of non-legislative measures, such as an updated Code of ✔ Legislative change will allow strengthened controls around company donations, encourage a "Know-Your- 30 OFFICIAL OFFICIAL Extent to which options will deliver policy objectives Policy Objective Do nothing Non-legislative approach Legislative approach delivery, electoral registration, electoral campaigning and political finance delivery and subsequent return, increasing administrative burdens, and inconsistent access to resources for ROs. These issues, if left unaddressed, could undermine voter confidence and the resilience of the system. The nominations process would continue without additional safeguards or deterrents, leaving limited ability to challenge false or misleading candidate declarations and preventing political parties from formally withdrawing support for candidates once nominated. This would risk undermining public confidence and restrict parties’ ability to uphold standards during the nomination period. Conduct for campaigning and improved guidance for police and ROs. While these measures will help improve the general tone of political debate in elections and make the application of existing law more consistent, they do not go far enough to address the scale and systematic nature of the problem. Other non-regulatory approaches such as improved guidance, sector-led initiatives, and voluntary adoption of best practice could somewhat reduce risk in election delivery and electoral registration, as well as in the nominations process. However, in practice, these measures would be inconsistently applied and would not resolve systemic issues like the legal constraints on postal vote reissue or the absence of a central registration look-up tool. The loopholes that enable foreign interference within our democratic processes would continue to persist. Non-legislative measures such as donors voluntarily disclosing their sources of funding and other details are unlikely to be Donor" culture, and introduce other measures such as increasing transparency around source of funding of unincorporated associations. These measures will help reinforce electoral legislation against foreign interference, ensuring the policy objective is met to the highest level possible. Adjusting electoral deadlines would strengthen the resilience of electoral administration across the UK. Delivering a package of targeted legislative changes with operational improvements including clarifying legal responsibilities, enabling better use of technology and facilitating the provision of accessible information about elections to the public should deliver proportionate and practical improvements while minimising disruption. Introducing targeted legislative changes to strengthen candidate declarations and enable party 31 OFFICIAL OFFICIAL Extent to which options will deliver policy objectives Policy Objective Do nothing Non-legislative approach Legislative approach The electoral donation system would be left at risk of foreign interference. There would continue to be less proportionate and proactive scrutiny of candidate, local third party and recall petition campaigner political finance offences, as they would remain subject only to criminal investigation and prosecution, and administrative offences would for the most part remain criminal offences. The EC would continue to lack a solid legal basis for sharing information with other regulators and enforcement authorities, undermining effective collaboration on cross- cutting regulatory issues. Transparency gaps would remain in the digital imprint rules, enforcement would applied uniformly and would fail to comprehensively address transparency issues in political finance. There is no non-legislative option to strengthen the role and powers of the EC or address the existing enforcement gaps. As with the do-nothing option, the enforcement of political finance would remain fragmented and would lack a proportionate and effective deterrent for offences. Improving collaboration on cross-cutting regulatory issues could be improved through non-legislative means. However, any proposals short of providing an explicit statutory gateway to share information are unlikely to provide the solid legal foundation the EC needs to share information dynamically. It is arguable that some campaigners could seek to close these transparency gaps on a voluntary basis but, as with the do-nothing option, without legislative change, there would remain transparency gaps in the withdrawal of nominations would provide clearer legal accountability, reinforce public confidence, and offer proportionate safeguards against misuse. These changes would deliver practical improvements to the nominations process while maintaining operational stability and minimising disruption. Delivering the proposed package of reforms will improve the transparency of digital imprint rules, and enforcement of all imprint rules, strengthening the integrity and public confidence in political campaigning. The measures will also enable the EC to make minor corrections to digital imprint guidance without the need to seek ministerial and parliamentary approval. Taken together, the proposed package of legislative reforms to the role and powers of the EC will address concerns about the proportionality of enforcement and current enforcement gaps, provide a greater deterrent for more 32 OFFICIAL OFFICIAL Extent to which options will deliver policy objectives Policy Objective Do nothing Non-legislative approach Legislative approach remain fragmented, and the EC would be unable to make minor corrections to digital imprint guidance without needing to seek ministerial and parliamentary approval. It would also risk worsening the administrative and resource burden for the CEO in Northern Ireland. digital imprint rules, enforcement would remain fragmented and the EC would continue to be required to seek ministerial and parliamentary approval for minor corrections to digital imprint guidance. Non-legislative interventions would have no impact on mitigating the current challenges to registration in Northern Ireland. serious offences, and improve the EC’s operational effectiveness. Legislative change will protect young people’s data in Northern Ireland by removing the legal obligation on the CEO to share details of 16- and 17-year-olds with the court service. Remove barriers to participation in democracy X If no action were taken, the Voter ID requirements would continue to pose a barrier to voting for a small proportion of voters who may find themselves unable to vote or dissuaded from doing so. The longstanding, systemic issue of harassment and intimidation towards candidates, campaigners and electoral staff would continue to worsen as it has done in recent years. ~ As with the do nothing option, without legislative change, the Voter ID requirements would continue to pose a barrier to voting for a small proportion of voters. The VAC already exists to support electors without other accepted forms of ID, but awareness of the VAC is somewhat low. It is possible that a larger communications campaign for voter identification could increase awareness but it seems unlikely that this measure alone will be effective in achieving the policy objective. ✔ Legislative change will allow the use of bank cards as an accepted form of ID for voting. Allowing the use of widely held bank cards will help to close the existing gap in ID ownership, ensuring the policy objective is met as fully as possible. Removing the requirement for candidates acting as their own election agents to have their home address made public will remove a barrier to such candidates safely standing for election without putting themselves at risk of harassment and intimidation in private home. 33 OFFICIAL OFFICIAL Extent to which options will deliver policy objectives Policy Objective Do nothing Non-legislative approach Legislative approach There would continue to be insufficient protections for electoral staff, who are often subject to similar abuse to candidates and campaigners. Candidates acting as their own election agent would continue to have their home address made public in many cases, posing a serious security risk to those candidates and discouraging them from standing for election. AEs would continue to be disproportionately burdened by the requirement to reregister to vote annually. As with the do nothing option, without legislative change, there would continue to be insufficient protections for electoral staff, no deterrent for those who seek to damage our democracy and have no intention to stand for elective office, and candidates acting as their own election agent would continue to have their home address made public in many cases. As with the do nothing option, without legislative change, AEs would continue to be disproportionately burdened by the requirement to reregister to vote annually. Legislative measures will strengthen and build on existing deterrents and protections. Extending the disqualification order to cover electoral staff will bring them under the same protect given to candidates, campaigners and elective office holders. Extending the period that an AE entry remains valid from one year to three years can only be made possible through legislative change. E. Summary and preferred option with description of implementation plan 83. These measures will require both primary legislation and secondary legislation. Supporting secondary legislation will be brought forward based on priority and complexity of the policy measures, following Royal Assent. 84. A description of the preferred option and implementation plan for each policy and sub-policy can be found in table 2 below. 34 OFFICIAL OFFICIAL Table 2: Summary and preferred option with description of implementation plan Policy Sub-policy Preferred Option Implementation Plan Votes at 16 The preferred option is to implement the franchise change through primary and secondary legislation. This will be accompanied by an implementation plan supported by the government (encompassing the Ministry of Housing, Communities, and Local Government (MHCLG), DfE, and the Department for Digital, Culture, Media, and Sport (DCMS), EROs and the EC, working alongside civil society organisations. Improving Registration Direct registration The preferred option is to introduce a new duty on EROs to register eligible people on the electoral registers for reserved and excepted elections (UKPGEs, all Northern Irish elections and English local elections) without them making an application, following a notification to those people. This will include a power to make regulations on the content of the notification, which will include the reasons why a person might opt-out of being registered in this way (for example, to register manually or register as an AE or service voter) and the time period in which a person has to respond, if they are choosing to opt-out. A similar process is expected to be provided for updating existing entries on a register where a person’s name or address (within the same electoral area) has changed. It is expected that the 'direct registration’ provisions would not be commenced until aspects of the new provision have been successfully tested or piloted. 35 OFFICIAL OFFICIAL Policy Sub-policy Preferred Option Implementation Plan Pilot powers The preferred option is to introduce a new power through which the Secretary of State for MHCLG can make secondary legislation to run pilots that relate to improving and amending electoral registration matters (including direct registration). This is intended to be broad enough to test known potential approaches to registration, including aspects of ‘direct registration’, soon after the Bill but also provide for testing in future years. Data sharing powers – direct and assisted registration The preferred option is to enable government departments and other public bodies across central and local government and the education sector to share data with EROs, for electoral registration purposes. This shared data would then be used to identify and contact unregistered eligible citizens, to assist them to register to vote (assisted registration) with their consent. The data obtained may also be used to register eligible citizens - following a notification - with no need for them to complete an application (direct registration). Additional secondary legislation setting out the detail of specific data sharing agreements would follow this primary legislation. It is expected that new data flows would be used in parallel with existing registration methods immediately and then gradually be used to support more digitally- enabled approaches. Anonymous Electors The preferred option is to introduce legislation extending the period of time that AE status is valid from one year to three years. In addition, a new duty on EROs will be introduced whereby EROs are required to ‘check in’ with AEs once a year. This ‘check in’ will involve sending a form of communication containing relevant information such as a These changes will be implemented though primary legislation, supported by updates to EC guidance. MHCLG will work with electoral administrators to ensure operational readiness. 36 OFFICIAL OFFICIAL Policy Sub-policy Preferred Option Implementation Plan reminder of their current AE arrangement, expiry date, voting arrangement, etc. In addition, the current duty of EROs to contact postal voters ahead of their postal vote expiry will be amended. The amendment will require that, in cases where the postal voter is an AE, additional relevant information is provided to them. Future of the Open Register The preferred option is to move from a presumption that people will be on the open register, unless they actively opt out; to a presumption that they will not be on the open register, unless they actively opt in. These changes will be implemented through a combination of primary and secondary legislation, supported by updates to EC guidance and changes to EMS systems to accommodate. Voter ID The preferred option is to use primary legislation to amend the Representation of the People Act (RPA) 1983 to allow the use of bank cards as ID for voting at polling stations. These changes will be implemented through a range of primary and secondary legislation, supported by updates to EC guidance. The Department will work with electoral administrators to ensure operational readiness. Candidate and Nominations Changes Candidate ID and declaration The preferred option is to introduce a statutory declaration form and candidates to provide proof of ID as part of the nominations process. These changes will be implemented through a range of primary and secondary legislation, supported by updates to EC guidance. The Department will work with electoral administrators to ensure operational readiness. Withdrawal of political party support The preferred option is to introduce a statutory power for parties to revoke nominations up to 48 hours before close. These changes will be implemented through a range of primary and secondary legislation, supported by updates to EC guidance. The 37 OFFICIAL OFFICIAL Policy Sub-policy Preferred Option Implementation Plan Department will work with electoral administrators to ensure operational readiness. Outcomes of the Elections Review Electoral timetable The preferred option is to adjust key electoral deadlines. This includes moving the deadline for the submission of nominations papers from 4pm to midday on the final day for submitting nominations, moving the registration deadline from midnight to 5pm on the 12th working day before the poll and bringing the postal vote application deadline earlier in time to 5pm on the 14th working day before the poll. These changes will be implemented through a range of primary and secondary legislation, supported by updates to EC guidance. The Department will work with electoral administrators and suppliers to ensure operational readiness. Absent voting The preferred option is to allow earlier reissue of lost postal votes, enabling cancellation of postal votes and change of voting method in specific circumstances, clarifying the deadline for determining postal vote applications and improving wider legislative framework for absent voting. Amendments will be made to primary and secondary legislation to reflect the new deadlines and discretionary powers. The EC will update its guidance to reflect the changes, and the department will engage with the sector to ensure they are aware of the changes and in a position to implement them Electoral resourcing The preferred option is to require the role of ROs to be held by a senior officer and clarify their access to council staff. Legislative changes will be introduced to define the eligibility criteria for the RO role and to clarify the statutory duty of LAs to provide staff. The Department will work with local government bodies to support implementation and ensure consistency across GB. Guidance will be updated to reflect the new requirements 38 OFFICIAL OFFICIAL Policy Sub-policy Preferred Option Implementation Plan Elector information power The preferred option is to legislate for a duty on ROs and EROs to provide standardised election data to the EC or the Government. The duty will be introduced through primary legislation, with supporting regulations to define the scope and format of the data required and specify to whom the data must be provided (the EC or the Government). The EC or the Government will be responsible for collecting and publishing the data and managing the services through which this information is provided to the public. Election forms consolidation measures The preferred option is to legislate to amend the relevant forms powers to enable a consolidation of the forms into regulations. The consolidation will be implemented through regulations. Policy officials will work closely with the EC and other stakeholders to ensure implementation is properly co-ordinated with the upcoming form changes resulting from the Elections Bill. Harassment and Intimidation Aggravating factor for intimidatory offences in an electoral context The preferred option is to create a new statutory aggravating factor in law which applies to intimidatory offences in an electoral context to underline the severity of seeking to damage democratic processes. The aggravating factor will apply to offences listed in Schedule 9 to the Elections Act 2022 motivated by hostility towards candidates, future candidates, campaigners, elected representatives, and electoral staff. This will mirror the existing disqualification order. Courts will be required to take this aggravating These changes will be implemented through primary legislation. There will be a role for prosecutors to establish the evidential base to prove hostility for both the disqualification order and the aggravating factor and bring these to the court's attention. Ultimately, both the disqualification order and the aggravating factor will be imposed by courts at the point of sentencing. 39 OFFICIAL OFFICIAL Policy Sub-policy Preferred Option Implementation Plan factor into account when determining the sentence. This will apply to sentences in England, Wales and Northern Ireland. There is an existing aggravating factor in Scottish Law. The Department will work with the Ministry of Justice (MOJ), the Crown Prosecution Service (CPS) and the Sentencing Council to develop guidance on how the aggravating factor should be applied consistently. The Department will engage with judicial and prosecutorial bodies to understand whether additional guidance is required to ensure consistent application of these measures. Extending the disqualification order to cover electoral staff The preferred option is to extend the remit of the disqualification order to cover the following electoral staff: - ROs and members of their staff - registration officers and members of their staff - counting officers, including the chief counting officer, a deputy of the chief counting officer, a counting officer, a deputy of the counting officer, a member of the chief counting officer’s staff and a member of the counting officer’s staff - petition officers and members of their staff This will apply to all UK elections apart from Scottish parliamentary and local elections, which are covered by equivalent Scottish law. Removing outstanding requirements for The preferred option is to amend Section 67(6) of the RPA 1983 to remove the requirement for publishing the home addresses of candidates This change will be implemented through primary legislation. The Department will work with the EC to ensure that guidance for candidates regarding 40 OFFICIAL OFFICIAL Policy Sub-policy Preferred Option Implementation Plan candidates addresses to be published acting as their own election agents in the notice of election agents. We will also add that all election agents may use a correspondence address. This is for all UK parliamentary elections, and local elections in England. the nominations process clearly sets out how they can choose not to have their home address made public. Political Finance Unincorporated associations The preferred option is to significantly lower the transparency thresholds so that UAs will need to register with the EC if they make donations over £11,180, and report all gifts over £2,230. Extend these disclosure requirements to cover unincorporated associations that contribute directly to candidates. Additionally, mandate that each unincorporated association nominates a responsible individual to be publicly listed on the register, ensuring greater accountability. Also requiring UAs which wish to make political contributions above the £11,180 threshold to conduct permissibility checks on gifts they receive for the purpose of making political contributions. All political finance measures will require primary legislation, with the exception of provisions on connected sources of funding under section 54A. The EC is expected to issue both statutory and non-statutory guidance in line with its regulatory responsibilities. To promote coherence and consistency in electoral regulation across the UK, and subject to devolution analysis and the outcome of legislative consent motions, these measures are intended to apply to reserved, excepted, and devolved elections, pending ongoing engagement with the Scottish and Welsh Governments. The measures are not intended to have retrospective effect and are expected to come into force following Royal Assent. Certain provisions, such as the new UAs threshold, will be commenced by regulation on a specified date after Royal Assent, applying only to regulated periods beginning thereafter. Company donation rules The preferred option is that companies and limited liability partnerships will only be permitted to make a political donation if they have made sufficient revenue to cover the donation, and they meet eligibility criteria on UK headquarters and on ownership to ensure they have a genuine connection to the UK. 41 OFFICIAL OFFICIAL Policy Sub-policy Preferred Option Implementation Plan Forfeiture of donations The preferred option is to ensure that when illicit funds do enter the system via impermissible donors (e.g. individuals not on the electoral register), they will be subject to full forfeiture, and no exception can be made to allow for partial forfeiture where donors are eligible to vote, but not registered in a UK electoral register at the time of donation. Know Your Donor guidance The preferred option is that recipients of donations will be required to consider the risk of those donations being illegitimate, such as considering sources of funding where the risk of foreign interference may be higher. The EC will also provide guidance on conducting risk assessments around accepting donations The Electoral Commission and Enforcement Closing the enforcement gap The preferred option is to extend the EC’s Remit and Civil Sanctioning Powers to RPA and Recall of MPs Act (RoMPA) Election Finance Offences by extending the EC’s civil sanctioning and investigatory powers to these offences. Candidates, local third parties and recall petition campaigners will also now send returns directly to the EC rather than ROs. All enforcement measures will require primary legislation. Secondary legislation will be required to amend the list of prescribed offences and prescribed restrictions and requirements subject to civil sanctions and the level of the EC’s maximum fine. It is intended that reforms to apply UK-wide at all elections, including national elections and local government elections. To ensure coherence and consistency across electoral regulation in the UK, our intention is for this to include reserved, excepted and devolved Reclassifying administrative offences The preferred option is to reclassify an extensive range of administrative offences across PPERA, the RPA, and RoMPA so that they are for the most part punishable through civil sanctions. 42 OFFICIAL OFFICIAL Policy Sub-policy Preferred Option Implementation Plan Increase the EC’s maximum fine The preferred option is to increase the EC’s maximum fine to an amount of up to £500,000 with safeguards in place to ensure fines are proportionate for political parties which are less well resourced. elections (pending ongoing discussions with the Scottish and Welsh Governments). It is the expectation that that all regulations will come into force after Royal Assent. The extension of EC remit and powers to RPA and RoMPA election finance offences may need savings provisions to allow the EC to build up its resources and capacity and amend its guidance. Enhancing EC’s information sharing powers The preferred option is to give the EC an explicit statutory gateway to enable the EC to share information with certain law enforcement bodies and regulators. The bodies will be listed in primary legislation with the SoS having a power to add additional bodies to the list through secondary legislation. Leave to pay The preferred option is to transfer responsibility for granting leave to pay claims from the courts to the EC. Imprints Extending the digital imprint rules to ‘organic material’ promoted by third party campaigners who are not recognised The preferred option is to extend the UK-wide digital imprint rules to require ‘organic material’ (i.e. digital material which has not been paid to be advertised) and which is promoted by or on behalf of third party campaigners that are not recognised, to include an imprint, with the exception of individuals. This will ensure that the rules promote transparency around organic digital campaigning material promoted by third-party campaigning organisations who are not registered with the Electoral Commission, while protecting freedom of expression and avoiding undue Delivery of the preferred changes to imprints measures will require a mixture of primary and secondary legislation. The expectation is that the EC would update its guidance to support campaigners and enforcement authorities in understanding how the rules will be enforced across the imprints measures. 43 OFFICIAL OFFICIAL Policy Sub-policy Preferred Option Implementation Plan burdens on individuals simply expressing their political opinions online. Streamlining the enforcement of the digital and print imprint regimes The preferred option is to streamline the enforcement of the imprint rules, so that the EC take responsibility for enforcing all imprint offences in the first instance. This will bring greater clarity, consistency and proportionality to the enforcement of the imprint rules. Amending the procedure in relation to the EC’s guidance on digital imprints The preferred option is to remove both the requirement for Secretary of State approval and the 40-day parliamentary process for implementing minor corrective updates to the digital imprint guidance. By removing these procedural requirements for minor corrective changes, the EC will be able to update its guidance more responsively, where for example, changes in platform names arise. Northern Ireland Measures The Northern Ireland canvass The preferred option is to amend primary legislation to give the Secretary of State powers to reform and modernise the NI canvass, the details of which can be set out in secondary legislation. This option should also allow for any future reform of the system which may be required to be made without the need for primary legislation which has been a significant barrier to reform of the current outdated system Additional secondary legislation setting the detail of how the reformed NI canvass will operate would follow this primary legislation. We will be able to set out the direction of the reform and its intent at introduction to facilitate passage of the Bill. Adding National Insurance The preferred option is to amend primary legislation to facilitate giving the CEO for NI the This change will be implemented through amendments to primary legislation facilitating a 44 OFFICIAL OFFICIAL Policy Sub-policy Preferred Option Implementation Plan numbers to elector records powers to add a NINo to an electors record without them providing the information. new power for the CEO. The details of this power will be set out in additional secondary legislation. The Northern Ireland Office will work with the CEO for Northern Ireland to ensure operational readiness following RA/commencement. ‘Calling Out’ in polling stations The preferred option is to amend legislation removing the requirement for ‘calling out’ of an elector’s name and number at a polling station. This change will be implemented through primary legislation, supported by updates to the Electoral Office for Northern Ireland guidance. The Northern Ireland Office will work with the CEO for Northern Ireland and EC to ensure operational readiness. Amending electoral ID cards The preferred option is to amend primary legislation removing the requirement for the day of birth to appear on a NI electoral ID card. This change will be implemented through primary legislation, supported by updates to the Electoral Office for Northern Ireland guidance. The Northern Ireland Office will work with the CEO for Northern Ireland and EC to ensure operational readiness. 45 OFFICIAL OFFICIAL F. Appraisal 85. The analysis focuses on the impacts of primary legislation. Some measures in the Bill will require supporting secondary legislation to set out more fully how they will operate. This secondary legislation will be subject to its own consultation, scrutiny, and assessment. As a result, there are limits to how fully the potential impacts can be assessed at this stage. 86. Each policy is assessed against a ‘Do Nothing’ counterfactual scenario, where the government takes no legislative or non-legislative action to address issues in the electoral system. A new burdens assessment will also be undertaken for these policies. 87. As with any form of economic modelling, there is a certain degree of uncertainty as the final scope of the policy is yet to be determined (this will be done at secondary legislation stage). Some of the cost components have yet to be quantified, such as digital costs, and others are based on current best assumptions, such as the estimated uptake of each policy. To account for this variability around cost estimates, a range of +/-50% of the central scenario has been applied to create a high and low scenario f or the quantifiable components of the bill. These ranges have been used throughout the IA. 88. An appraisal period of 10 years is used as per standard practice for IAs, from 2025. This is the earliest point from which reforms may take effect. Implementation timings will be dependent on the timing of Royal Assent, secondary legislation. Costs are presented in 20 25/26 prices. Figures are rounded to the nearest £0.1 million and totals may not sum exactly due to this rounding. 89. The EC ha s assessed the impact of the proposed bill measures on the Commission and estimated the resource required by the Commission to support implementation of bill measures . The costs associated with a given measure are presented alongside the other costs estimated for that measure. The Electoral Commission has indicated that the implementation of the Bill will require additional staffing beyond that associated with the new enforcement powers, for example its engagement and public awareness work to support Votes at 16 and the new regulatory functions not covered as part of the enforcement powers. However, other than those associated wit h the enforcement measures, wider staffing costs have been excluded from this Impact Assessment . This reflects the fact that the Commission will take on new and expanded responsibilities as a direct result of the proposed reforms around enforcement measures. The staffing costs included here are therefore a direct impact of the policy itself, rather than being associated with transitional or implementation support as in the other policy areas . This approach 46 OFFICIAL OFFICIAL is consistent with the treatment of MHCLG departmental staffing costs stemming from other policy measures included within this Impact Assessment. 90. The impacts of the policies in this Bill on the costs of conducting Police and Crime Commissioner (PCC) elections have been included in this appraisal. Although the government has announced its intention to abolish PCCs (and their elections as a result), this change will be implemented through separate future legislation. Consequently, the appraisal reflects the current statutory position, under which PCC elections will continue unless and until future legislative change dictates otherwise. 91. The Government announced its intention to introduce digital VACs and has since announced the introduction of a new digital ID scheme which will be implemented through separate future legislation . Consequently, this appraisal reflects the current statutory position, and we assume that demand and associated costs for paper VACs, remain unaffected by the potential introduction of either of these digital products. Option 1 – Legislative Approach F.1 Votes at 16 F.1.1 Methodology 92. This analysis begins by estimating the eligible population. To do this, first the number of eligible 14- to 17-year-olds is estimated using population data2324. This figure is then multiplied by eligibility factor s to give the eligible population for different types of election , as not all 16- and 17-year-olds will meet the criteria to vote. To vote in UKPGEs you must be a UK or Irish citizen, or a qualifying Commonwealth citizen living in the UK 25. To vote in local and PCC elections in England you must meet the criteria to vote in UKPGEs or be a qualifying EU citizen living in the UK. 93. The eligibility factors are assumed to be 96.9% for UKPGEs and 99.6% for local and PCC elections, based on the proportion of the 18- to 25-year-olds who report being eligible to vote in each respective election based on waves 29 and 30 of the British Election Study Internet Panel2627. 23 Estimates of the population for the UK, England, Wales, Scotland, and Northern Ireland - Office for National Statistics, 2025 24 Constituency data: Population, by age - Barton, 2025 25 Who can vote in UK elections - Electoral Commission, 2025 26 British Election Study Internet Panel waves 29 – British Election Study, 2024 27 British Election Study Internet Panel waves 30 – British Election Study, 2025 47 OFFICIAL OFFICIAL 94. The eligible population is then adjusted by population forecasts 28293031 to estimate how the franchise changes over the 10 -year appraisal period. The relevant cost components are then applied to these forecasts to estimate the total impact. The cost components are as follows: • Registration costs • Canvass costs • Conduct costs • Communications costs 95. The overseas elector franchise of 16- and 17-year-olds is forecast separately. This is based on internal MHCLG modelling used for the Elections Act 2022 Overseas Electors IA32. It is assumed that 14.2% of overseas electors will be added to the electoral register in years with a UKPGE and 3.3% in years w here there is not. 96. It is assumed that 88.9% of the population will be added to the electoral register. This is higher than the current completeness of the register for comparable age groups (60% of 18- to 19-year-olds are correctly registered as of 202233). Th e assumption is aligned with the assumed level of register completeness at the end of the appraisal period, used in the Improving Registration policy model. 97. Table 3 below shows the estimated size of the franchise for 16- and 17-year- olds and the number added to the electoral register per year in the appraisal period. This covers franchises/electoral registers for both local government elections and UKPGEs. The figure for the number of UKPGE electors also includes overseas electors. It should be noted that 16 - and 17-year-olds in Scotland and Wales who can already vote in certain elections are included in these figures. 28Subnational population projections for England - Office for National Statistics, 2020 29 National population projections: 2021-based - Stats Wales, 2024 30 Projected Population of Scotland: 2020-based - National Records of Scotland, 2023 31 Population Projections for Northern Ireland: 2022-based - Northern Ireland Statistics and Research Agency, 2025 32 The Representation of the People Act – Extension of franchise to British citizens overseas – MHCLG, 2023 33 Electoral registers in the UK - Electoral Commission, 2023 48 OFFICIAL OFFICIAL Table 3: Summary of estimated franchise and registered 16 - and 17-year-olds (millions, 2027/28 - 2034/35) Year Estimated Franchise Estimated Registered Electors Domestic Overseas Electors Local Government Elections UKPGE UKPGE Local Government Elections UKPGE 2027/28 1.7m 1.7m >0.1m 1.5m 1.5m 2028/29 1.7m 1.7m >0.1m 1.5m 1.5m 2029/30 1.7m 1.7m >0.1m 1.5m 1.5m 2030/31 1.7m 1.7m >0.1m 1.5m 1.5m 2031/32 1.7m 1.7m >0.1m 1.5m 1.5m 2032/33 1.7m 1.7m >0.1m 1.5m 1.5m 2033/34 1.7m 1.6m >0.1m 1.5m 1.5m 2034/35 1.6m 1.6m >0.1m 1.5m 1.4m 98. The costs of the policy are modelled separately for GB and Northern Ireland. This is due to differing electoral systems and data availability between the two. Costs for Northern Ireland were estimated with the support of the EONI. The analysis described below refer to costs in GB unless specifically stated to be Northern Ireland. F.1.2 Monetised impacts F.1.2.1 Direct costs Registration costs 99. The costs for registration services are estimated using the number of eligible 14 - to 17-year-olds, data on costs collected from LAs, methodologies and assumptions from the Elections Act 2022, and administrative data on applications. Register to Vote Costs 100. There will be costs for LAs in processing additional applications from 14- to 17-year- olds. Several assumptions are made around demand for this service: • Demand in first year eligible to vote (for 16- and 17-year-olds in 2027/28, and 16-year-olds from 2028/29 onwards) – 94.9% of the eligible population per year, this is based on the proportion of the population assumed to be added to the 49 OFFICIAL OFFICIAL register and the average application rejection rate (6.3% of applications, based on data collected from LAs34). • Demand for other years (17-year-olds from 2028/29 onwards) - 13.5% of the eligible population per year, this is based on volumes from administrative application data , to reflect the proportion who change their details or newly register each year35. • Demand for attainers - 24.5% of the eligible population per year, also higher than current rates, this is based on the approximately same level of improvement of register completeness for 16 - and 17-year-olds (i.e. increasing the current 60% of 18- to 19-year-olds registered to 92% of the newly enfranchised 16- and 17-year-olds registered). The level of completeness for attainers was 16% in 202236. 101. The costs are estimated based on data collected from LAs 34 on the proportion of applications with no issues, minor issues and major issues for paper and online applications, and how much they cost to process each type. 102. Costs are also modelled for sending the decision outcomes for all applications. Key assumptions (based on data collected from LAs 34 and administrative application data35) include: • Proportion of Register to Vote applications submitted online – 89.9% • Proportion of decision outcomes sent with paper – 19.4% • Cost of sending physical decision outcome - £1.18 • Cost of sending digital decision outcome - £0 103. These assumptions are then used to calculate the total costs of processing the applications. The assumptions are combined with the estimate of franchise size, to give the number of applications, and then the number of applications of each type (online, paper, no issues, minor issues, major issues), then finally the total costs. 104. Currently the identity check for most register to vote applications is done using the applicant’s NINo. But most 14- and 15-year-olds do not have NINos, meaning different methods will need to be used. It is assumed that the proportion of applications with no issues, minor issues and major issues are the same as for applicants with NINos. 34 MHCLG Survey Data: Survey to Local Authorities and Valuation Joint Boards in March 2025 (185 responses of 360 LAs and VJBs in Great Britain). 35 Register to Vote Application Administrative Data 36 Electoral registers in the UK - Electoral Commission, 2023 50 OFFICIAL OFFICIAL 105. In Scotland and Wales 16- and 17-year-olds can already register to vote. The expected volumes assumed in this appraisal are greater than the current level of register completeness in both Scotland and Wales meaning that LAs in Scotland and Wales will experience increased costs due to the policy. To account for this, we model that all the costs associated with electors already on the register are covered using existing funding, while the costs associated with any electors beyond that will be funded by this policy. 106. The current register completeness in Scotland and Wales is estimated using the number of 16- and 17-year-olds registered divided by the 16- and 17-year- old population 3738. The difference between this and the assumed register completeness (88.9%) is divided by the assumed register completeness to give the proportion of the costs that will be covered by new funding for the policy. The costs for Scotland and Wales are multiplied by this figure (0.28 in Scotland, 0.47 in Wales) to give the costs of additional volumes generated by the policy (rather than the total costs of registering 16- and 17-year-olds). Porting 107. As a transitional measure, LAs in Wales and Scotland will need to port existing eligible electors on their registers for devolved elections on to their registers for UKPGEs and PCC Elections (Wales only). It is assumed that porting will be a largely automated process and will create no additional burden for these LAs. Absent Vote Application Costs 108. Having registered to vote, it is expected that many 16 - and 17-years olds will also apply to vote via post or proxy. It is assumed that there will be no absent vote applications from attainers (14 - and 15 -year-olds). Currently in Wales and Scotland you cannot register for devolved administration and council elections using the Online Absent Vote Application (OAVA) service. We expect this to change before the franchise change is introduced and these estimates assume that all electors can apply for absent votes using the online service for all elections in GB. 109. The following assumptions have been made about demand for absent vote applications per year: • Postal demand in first year eligible (for 16- and 17-year-olds in 2027/28 and 16-year-olds from 2028/29 onwards): 31.1% of electorate, based on the proportion of 18- to 34-year-olds reporting being registered for a postal vote in the public opinion research for the Electoral Integrity Programme 37 Electoral registration in Great Britain in 2023 - Electoral Commission, 2024 38 People registered to vote - National Records of Scotland, 2025 51 OFFICIAL OFFICIAL evaluation39 divided by the rejection rate for postal vote applications for application administrative data40. • Postal demand in other years ( years with UKPGE) (17-year-olds from 2028/29 onwards) : 4.3% of electorate . This is based on volumes from administrative application data40. • Postal demand in other years (years without UKPGE) (17-year-olds from 2028/29 onwards): 1.9% of electorate . This is based on volumes from administrative application data40. • Proxy demand in first year eligible (for 16- and 17-year-olds in 2027/28 and 16-year-olds from 2028/29 onwards): 6.6% of the electorate, based on the proportion of 18 - to 34-year-olds reporting being registered for a proxy vote in the public opinion research for the Electoral Integrity Programme evaluation divided by the rejection rate for postal vote applications for application administrative data41. • Proxy demand in other years (years with UKPGE) (17-year-olds from 2028/29 onwards) : 0.6% of the electorate , based on volumes from administrative application data41. • Proxy demand in other years (years without UKPGE) (17-year-olds from 2028/29 onwards): 0.1% of electorate, based on volumes from administrative application data41. 110. The costs associated with absent vote applications are estimated following the methodology from the Elections Act 2022 OAVA IA42; this methodology has since been updated to include the assumptions above and to reflect the latest administrative data and processing cost information from LAs43. 111. 16- and 17-year-olds are already able to apply for absent votes for devolved elections, but volumes are assumed to increase compared to what they currently are. The same factor is used as for Register to Vote costs to estimate the additional absent vote costs for Welsh and Scottish LAs. Voter Authority Certificate Costs 112. 16- and 17-year-olds may also choose to apply for a VAC. It is assumed that there will be no VAC applications from attainers (14- and 15-year-olds). These costs are estimated using the methodology from the Elections Act 2022 Voter ID I A44. There are two costs that are modelled for the VAC service: i. The cost of processing the application 39 Evaluation of Electoral Integrity Programme: public opinion research wave 3 – MHCLG, 2025 40 Postal Vote Application Administrative Data 41 Proxy Vote Application Administrative Data 42 The Representation of the People (Postal and Proxy Voting) – MHCLG, 2023 43 MHCLG Survey Data: Survey to members of the Elections Expert panel in August 2024 44 The Voter Identification Regulations – MHCLG, 2022 52 OFFICIAL OFFICIAL ii. The cost of printing paper VACs 113. It is assumed that 10% of registered 16- and 17-year-olds will apply for a VAC each year. Based on administrative application data 45 it is assumed that 90.8% of VAC applications will lead to a VAC being printed. 114. As discussed, the Government has announced its intention to introduce digital VACs and has since announced the introduction of a new digital ID scheme which will be implemented through separate future legislation . However, this appraisal reflects the current statutory position, and so it is assumed that demand and associated costs for paper VACs, remain unaffected by the potential introduction of either of these digital products. 115. Total cost is calculated by multiplying the number of applications and VACs sent to print by the unit costs (at current prices) for processing applications and printing VACs used in the Elections Act 2022 Voter ID IA. Overseas elector costs 116. By extending the franchise, there will also be more overseas electors who are eligible to vote in UKPGEs. The following assumptions are made about the demand for the Register to Vote service for overseas electors. These are based on modelling used for Elections Act 2022 Overseas Electors IA46. • Demand in years with a UKPGE: 15.8% of overseas franchise • Demand in years without a UKPGE: 3.7% of overseas franchise. 117. The costs are estimated using the methodology from Elections Act 2022 Overseas Electors IA to model the overseas franchise size of 16- and 17-year- olds. The unit costs and other assumptions of the methodology have been updated based on administrative application data 47 and processing cost information from LAs48. Training and Staffing Costs 118. Extra staff may be needed to deal with the additional demand in some LAs. The LAs that will need extra staff are predicted using an experimental relationship between the size of electorate and the number of registration staff needed, found in internal MHCLG research. The number of 16 - and 17-year-olds expected to be on the regi ster is added to this equation and the LAs that require an additional member of staff are found. 45 Voter Authority Certificate Application Administrative Data 46 The Representation of the People Act – Extension of franchise to British citizens overseas – MHCLG, 2023 47 Overseas Elector Application Administrative Data 48 MHCLG Survey Data: Survey to members of the Elections Expert panel in August 2024 53 OFFICIAL OFFICIAL 119. The total number of extra staff needed when 16- and 17-year-olds are included in the franchise is then multiplied by wages and the costs of required training (based on data collected from LAs49) to find the total cost for each LA. 120. Both existing and new registration staff are expected to need training on processing applications from young people. The total number of staff that require training is found using the relationship described in the above paragraph applied to the expected total electorate aged 16 and over. The training is assumed to last for one day (7 hours), at the standard cost for training delivered by the AEA. This training is expected to only occur in 2027/28. Northern Ireland: Registration Costs 121. Registration costs are calculated based on the existing registration costs provided by the EONI multiplied by the expected percentage increase of the franchise. This is then uplifted by population growth to reflect demographic changes. 122. These estimates are based on the current level of register completeness in Northern Ireland (83% as of 2022 50), which is lower than the assumed completeness rate (88.9%) for 16- and 17-year-olds in GB. 123. The ambition is for the completeness to match what is assumed for GB. To account for this, the costs in Northern Ireland are then uplifted by the ratio of these two completeness rates (88.9%/83% = 1.07). Northern Ireland: Training and staffing costs 124. Training and staffing costs in Northern Ireland are calculated using the same methodology as described for GB. Northern Ireland: Systems costs 125. An estimate was provided by EONI on how much it would cost to update their systems to be able to process and store data from/on young people. 126. In summary, total registration costs are estimated to cost between £11. 2 million and £33. 7 million, with a central estimate of £22. 5 million (2025/26 prices, 10-year PV). Canvass costs 49 MHCLG Survey Data: Survey to members of the Elections Expert panel in August 2024 50 Electoral registers in the UK - Electoral Commission, 2023 54 OFFICIAL OFFICIAL 127. Canvass costs are estimated using the number of eligible 16- to 17-year-olds and data on costs collected from LAs. 128. With the increased franchise size, there will be more people to canvass as part of the annual canvass. In England 16- and 17-year-olds will now be part of the annual canvass. The two costs are modelled for the annual canvass: i. Invitations to Register (ITR) ii. Household Canvassing. 129. The number of ITRs sent to electors and households canvassed as part of the annual canvass is taken from the EC’s annual canvass data from 2020 to 202351. This is then divided by the current eligible population. This is then multiplied by the expected population of eligible 1 6- and 17-year-olds to give the additional volumes associated with the policy. 130. The cost associated with sending ITRs is found by multiplying the above volume, the unit cost of sending paper ITRs and the proportion of ITRs sent via paper (both collected from LAs52). It is assumed that the cost of sending online ITRs is negligible. 131. The cost associated with house canvassing is found by multiplying the above volume with the unit cost of household canvassing. The additional household canvassing costs only apply for the first canvass after the franchise changes comes into effect. Northern Ireland: Canvass costs 132. While the canvass system in Northern Ireland is due to change, the specific details will be set out in forthcoming secondary legislation. The proposed changes are anticipated to be cost neutral. Therefore, for the purposes of this assessment, the cost implications of lowering the voting age on canvass costs in Northern Ireland have been modelled using the existing canvass system, where the canvass is run every 10 years, with it last being run in 2021. 133. These costs are calculated based on canvass costs from 2021 provided by the EONI, multiplied by the expected percentage increase of the franchise. This cost is then uplifted by the expect population change between 2021 and 2030, to reflect the number of 16 - and 17 -year-olds that are expected to be part of canvass. 51 Electoral registers in the UK - Electoral Commission, 2023 52 MHCLG Survey Data: Survey to Local Authorities and Valuation Joint Boards in March 2025 (185 responses of 360 LAs and VJBs in Great Britan). 55 OFFICIAL OFFICIAL 134. Canvass costs are estimated to cost between £0.5 million and £1.5 million, with a central estimate of £1.0 million (2025/26 prices, 10-year PV). Conduct costs UKPGE and PCC conduct costs 135. With additional electors the costs for running elections will increase. Costs for UKPGEs and PCC Elections are reimbursed to ROs via the Consolidated Fund. The additional costs associated with extra electors are based on the Maximum Recoverable Amounts (MRAs) from the 2024 UKPGE and 2024 PCC Elections5354. 136. UKPGEs are assumed to take place in May 2028 and May 2032 on the same day as other May elections. It is not possible to accurately predict when the next UKPGEs will occur, so this analysis presents a possible scenario. This does not reflect any plans of when future elections will take place. 137. If the UKPGE were to take place on a day separate from the scheduled May local and PCC elections, then the cost of the policy would rise. 138. Costs associated with the running of these elections are split into three types. These are costs on a per-elector basis, costs on a per-polling station basis, and costs that are independent of electors or polling stations. 139. The costs on a per -elector basis are costs that vary with the number of electors. These are the costs associated with: i. Poll cards ii. Postal Voting (including training, not including application costs) iii. Overseas Electors (not including application costs) iv. RO Service Fee v. Addressed Candidate Mailing (UKPGE only) 140. For the per -elector costs, the total costs are divided by the electorate for the 2024 elections to give the cost per elector. These are then multiplied by the expected 16- and 17-year-old electorate for both 2028 and 2032, to give the costs at these elections for 16- and 17-year-olds. 141. The costs on a per -polling station basis are costs that vary with the number of electors. These are the costs associated with: i. Polling stations ii. Poll clerks 53 The Parliamentary Elections (Returning Officers’ Charges) - MHCLG, 2024 54 The PCC Elections (Local Returning Officers’ and Police Area Returning Officers’ Charges) – MHCLG, 2024 56 OFFICIAL OFFICIAL 142. The number of poll clerks per polling station is based on EC guidance55 which recommends a maximum of 2,250 electors per polling station. For a polling station with 0 to 1,250 electors, two poll clerks are recommended, and for polling stations with 1,250 to 2,250 electors, three poll clerks are recommended. 143. For every 2,250 16 - to 17-year-old electors, an additional polling station is assigned to the LA/constituency , and for every 1,250 electors on top of that an extra poll clerk is assigned to an existing polling station (for example, if there are 6,000 16- to 17-year-old electors in an LA, it will be allocated two additional polling stations and one additional poll clerk at an existing polling station). 144. Polling station and poll clerk costs are estimated by multiplying the extra demand by unit cost. To estimate additional polling station costs, the 2024 cost per polling station is multiplied by the number of additional polling stations needed. The extra poll clerk costs are estimated as the number of extra poll clerks needed multiplied by the poll clerk day wage. 145. Costs that are independent of electors or polling stations are assumed to not change with the expansion of the franchise. These costs are: i. Costs associated with the count. ii. Unaddressed candidate mailing ( UKPGE only) – as the number of households will not change. 146. When elections in a given area are run on the same day, some costs can be combined across elections. In this case , the costs concerned are those associated with polling stations, as the same polling stations and polling station staff will be used for all elections. These costs are split equally between all the different polls in the given area. Local and Devolved Election Conduct Costs 147. Costs for local (all GB) and devolved (Wales and Scotland only) elections, which are not reimbursed from the consolidated fund, are also expected to increase due to the policy, due to a larger franchise in England, and increased registration rates in Scotland and Wales . Since less granular data is available for these elections, a different approach is used. 148. The costs for these elections are estimated using data on the cost per elector per election collected from LAs56. A different unit cost is used depending on the 55 Guidance for (Acting) Returning Officers administering a UK Parliamentary election in Great Britain - Electoral Commission, 2024 56 MHCLG Survey Data: Survey to Local Authorities and Valuation Joint Boards in March 2025 (185 responses of 360 LAs and VJBs in Great Britan). 57 OFFICIAL OFFICIAL number of concurrent elections taking place, as some costs can be shared between elections run on the same day. Unit costs for standalone, 2 -way combination and 3-way combination are used in the model. Due to a lack of data, in cases where there are expected to be 4 concurrent elections, the unit cost for 3-way combination is used. This could lead to a small overestimate of the costs in these cases. The appropriate unit cost is then multiplied by the expected number of 16- and 17-year- old electors and the expected number of local elections each year to give the total cost. The unit costs are shown below: i. Standalone - £2.85 per elector per election ii. 2-way combination - £1.35 per elector per election iii. 3-way combination - £1.09 per elector per election 149. In Scotland and Wales 16- and 17-year-olds can already vote in local and devolved administration elections. But the turnout is assumed to increase with a greater amount of 16 - and 17-year-olds on the register, meaning there will be increased costs for LAs. The same factor is used as for Register to Vote and absent vote costs to estimate the additional conduct costs for Welsh and Scottish LAs. By-Election Conduct Costs 150. Outside of the regularly scheduled elections there are also by -elections that 16- and 17-year-olds will be able vote in . The following number of by -elections are assumed to happen each year: i. LA by-elections: 63 ii. Parliamentary or PCC by-elections: 0.9 iii. Parish by election and local referendums: 196. 151. The size of the 16- and 17-year-olds electorate for these elections is estimated as the average by-election electorate size, multiplied by the percentage change in the electorate when 16- and 17-year-olds are added to the franchise (based on previous assumptions described). 152. For LA, Parish by election and local referendums the cost per elector is assumed to be the same as for scheduled elections. For UKPGEs and PCC elections the cost per electors is calculated based on the total modelled costs for these elections divided by the expected number of electors. 153. The total by-election costs are estimating by multiplying the expected number of by- elections, the expect number of electors and the unit cost. Northern Ireland: Conduct Costs 58 OFFICIAL OFFICIAL 154. Conduct costs (for UKPGEs, Assembly Elections, and Council Elections) are calculated based on the existing registration costs provided by the EONI multiplied by the expected percentage increase of the franchise. These costs are also uplifted by population growth and the completeness ratio, as described for registration costs. 155. To estimate the costs for candidate mailing (in UKPGEs) and by -elections in Northern Ireland, the costs for GB were multiplied by the ratio of the population in Northern Ireland to the population of GB. 156. Conduct costs are estimated to be between £11. 2 million and £33. 7 million, with a central estimate of £22.5 million (2025/26 prices, 10-year PV). Communication costs Wider communications costs 157. Wider communications costs are calculated using the same methodology for GB and Northern Ireland. These costs are estimated using the number of eligible 16- and 17-year-olds multiplied by the costs of sending a second-class letter57. Looked-after children costs 158. LAs will have a duty to promote the policy to relevant children they have care of. The number of 16 - and 17-year-olds looked after by LAs 58,59,60 is uplifted by population growth61,62,63 to reflect demographic changes. This is then multiplied by the cost of sending a 2-sheet letter via Notify57 to estimate the total costs. This part of the policy will only apply in GB. 159. Communication costs of the Votes at 16 policy are estimated between £1.1 million and £3.3 million, with a central estimate of £2.2 million (2025/26 prices, 10-year PV). Electoral Commission Costs 160. The EC has assessed the impact of the votes at 16 policy on the Commission and estimated the cost it will incur supporting implementation of the policy. The main driver of the EC costs are the costs associated with public awareness campaigns. Wider staffing costs associated with the votes at 16 policy have been 57 Pricing – Notify, 2025 58 Children looked after in England including adoptions – DfE, 2024 59 Children looked after - StatsWales, 2024 60 Children’s Social Work Statistics - Scottish Government, 2024 61 Subnational population projections for England - Office for National Statistics, 2020 62 National population projections: 2021-based - Stats Wales, 2024 63 Projected Population of Scotland: 2020-based - National Records of Scotland, 2023 59 OFFICIAL OFFICIAL excluded, in line with the treatment of MHCLG departmental staffing costs in this impact assessment. 161. Detailed planning of the work required will be undertaken in parallel with the implementation of the policy. Cost estimates are therefore indicative and based on the EC’s current understanding of the proposed changes, as well as learning from the implementation of other major changes in the democratic process. 162. Electoral Commission costs are estimated between £19.9 million and £59.6 million, with a central estimate of £39.8 million (2025/26 prices, 10-year PV). F.1.2.2 Indirect costs 163. There are no monetisable indirect costs resulting from this policy. F.1.2.3 Direct benefits 164. There are no monetisable direct benefits resulting from this policy. F.1.2.4 Indirect benefits 165. There are no monetisable indirect benefits resulting from this policy. F.1.2.5 Summary – Business Net Present Value ( BNPV), Net Present Social Value (NPSV), Equivalent Annual Net Direct Cost to Business (EANDCB) 166. Under the central scenario, the estimated total quantified benefits and costs are £0 and £ 88.0 million, respectively , which provides a NPSV for Votes at 16 under Option 1 of around -£88.0 million (2025/26 prices) over the 10-year appraisal period. Table 4: Summary of monetised impacts for Votes at 16 (£m, 2025/26 - 2034/35) Impact Scenario Low Central High Benefits Total benefits - - - Costs Registration 11.2 22.5 33.7 Canvass 0.5 1.0 1.5 Conduct 11.2 22.5 33.7 Communications 1.1 2.2 3.3 Electoral Commission 19.9 39.8 59.6 Total costs 44.0 88.0 132.0 NPSV -44.0 -88.0 -132.0 Figures may not sum due to rounding 60 OFFICIAL OFFICIAL 167. As there is inherent uncertainty with modelling the Votes at 16 policy, analysis has been conducted to estimate the upper and lower bound of these estimates. To account for this, and other uncertainties, a range of +/ - 50% of the central scenario has been applied to create a high and low scenario: • Under the low scenario, the estimated quantified total costs and benefits are £44.0 million and £0, respectively, thus resulting in an estimated NPSV of -£44.0 million (2025/26 prices, 10-year PV). • Under the high scenario, the estimated quantified total costs and benefits are £132.0 million and £0, respectively, leading to an estimated NPSV of -£132.0 million (2025/26 prices, 10-year PV). 168. Further sensitivity analysis has been conducted in section H that shows the change in outputs when the estimated completeness of the electoral register for 16- and 17-year-olds, the most sensitive assumption, is adjusted. 169. The BNPV and EANDCB are expected to be £0 as there are no impacts on businesses which fall in scope of the BNPV and EANDCB. Whilst some businesses may benefit from increased profit as a result of the introduction of this policy, there is no available evidence on this and it is therefore not proportional to monetise it. F.1.3 Non-monetised impacts F.1.3.1 Direct costs 170. The digital systems used for applying to register to vote, for an absent vote or a VAC may require changes to support the registration of younger people. The exact nature of these changes is yet to be defined, and any costs will be commercially sensitive. Therefore, this cost is not monetised. 171. There will be a time cost for newly enfranchised electors who will be dealing with registration and voting processes for the first time . For many young people, preparing to vote may require a substantial time investment in order to register (potentially navigating government digital services for the first time to do so), to follow voting process and to decide who to vote for. This policy introduces this time cost at an earlier age, and may be higher for younger first time voters due to them having additional new systems to navigate such as government digital services. 172. Lowering the voting age would require the CEO in Northern Ireland to share details of 16- and 17-year-olds with the courts, even though they cannot serve on juries. This is because the law requires the CEO to share the names and details of all registered electors with the court service in Northern Ireland for the purpose of drawing up jury lists, regardless of age. As individuals under 18 are not eligible 61 OFFICIAL OFFICIAL to serve on juries, this would create unnecessary administrative issues for the court service. To address this, there is an intention to amend the law so that the CEO will not be required to share the details of 16 - and 17-year-olds with the court service in Northern Ireland. This change will be made through secondary legislation, and so the relevant provisions are not included in this bill. F.1.3.2 Indirect costs 173. There is likely to be a time cost for parents and families of newly enfranchised young people who may need to support each of the steps involved. While this support might have been needed at age 18, the change means these costs are incurred at a younger age, when individuals may be less familiar with civic processes and more reliant on family guidance. 174. There is also an additional resource implication arising from the collaborative development of this policy, with staff time from other government departments, principally DfE, contributing meaningfully to its design . There is also a potential impact on education staff . H owever, these contributions are not considered significant in cost terms and have therefore not been monetised. F.1.3.3 Direct benefits 175. The non -monetised direct benefits associated with the Votes at 16 policy include the representation of younger people's views in elections, as well as the potential strengthening of democratic engagement and voter turnout among them. Expanding the franchise to give younger people the vote will enable elections to reflect the views of a wider set of individuals in the population. 176. Academic evidence suggests that lowering the voting age may promote young people becoming more democratically engaged citizens who are more likely to turn out at elections if introduced alongside the right conditions . This process could create a more engaged electorate and even lead to an increase in turnout over time. However, this evidence is mixed. 177. Research in Scotland suggests that young people who were eligible to vote for the first time at the age of 16 -17 were more likely to turnout in future 64. It should be noted that this habituation is not necessarily guaranteed in the long term65, and a person’s experiences when they are enfranchised may be fundamental to whether it then becomes a habit 66. Another of the main studies on 64 Longer-Term Effects of Voting Age 16: Higher Turnout Among Young People in Scotland - Eichhorn and Huebner, 2025 65 Is Voting Really Habit-Forming and Transformative? Long-Run Effects of Earlier Eligibility on Turnout and Political Involvement from the UK - Jessen, Kuehnle and Wagner, 2021 66 How Young People in Scotland Experience the Right to Vote at 16: Evidence on ‘Votes-at-16’ in Scotland from Qualitative Work with Young People – Huebner, 2021 62 OFFICIAL OFFICIAL this topic, looking at Austria67, has since been found to have been based on a coding error68. Wider literature is mixed65,69. 178. Initial evidence from Scotland could support the argument that lowering the voting age increases turnout among younger people ; and turnout amongst young people tends to be high, and higher than their slightly older peers. At the 2014 Scottish independence referendum, 75% of registered 16 - and 17 -year-olds claimed to have turned out to vote, significantly higher than amongst 18 –24-year- olds (54%), although still much lower than overall turnout (85%) 70. This effect appears to be lasting; young people who were enfranchised at 16 or 17 (both the first cohort and later cohorts) were more likely to vote in the 2021 Scottish Parliament elections than young people who were first eligible at 18 or older71. However, this may have been impacted by an increased polarisation around the independence referendum. In Wales, turnout among 16 - and 17-year-olds in the 2021 Senedd election was broadly consistent with other young people 72, however due to this first experience of Votes at 16 in Wales occurring at a time of educational disruption due to the COVID-19 pandemic some academics have described it as a ‘false start’73, also noting alongside others that more time and research is needed to fully assess impact74. 179. Lowering the voting age would allow young people to register to vote from the age of 14, and to vote from age 16. As a result, for many young people, registering to vote could become their first interaction with online government services. Designing these services effectively to be easy to use and secure could help to promote trust in government digital services. 180. Implementation of the votes at 16 policy will also provide greater alignment of election processes across the UK . Currently, 16 - and 17-year-olds have the right to vote in devolved and local elections in Scotland and Wales. Introducing votes at 16 for reserved elections across the UK would increase alignment across the nations across the UK and across different election types, making these easier for administrators to manage and for electors to understand. F.1.3.4 Indirect benefits 67 Voting at 16: Intended and unintended consequences of Austria's electoral reform – Bronner and Ifkovits, 2019 68 Revisiting eligibility effects of voting at 16: Insights from Austria based on regression discontinuity analyses - Graf, Partheymüller, Bronner, and Kritzinger, 2024 69 Is voting transformative? Expanding and meta-analyzing the evidence. Holbein, Rangel, Moore and Croft, 2023 70 Scottish independence referendum - Electoral Commission, 2014 71 Votes at 16 in Scotland - Eichhorn and Hübner, 2022 72 May 2021 elections in Wales - Electoral Commission, 2021 73 A False Start - Griffiths, Larner, Jones and Poole, 2025 74 Longer-Term Effects of Voting Age 16: Higher Turnout Among Young People in Scotland - Eichhorn and Huebner, 2025 63 OFFICIAL OFFICIAL 181. The Votes at 16 policy is planned to be implemented alongside communications, engagement and education initiatives for young people, to help them become engaged and informed voters . Academic evidence outlines a range of different possible approaches to this, which could have positive results in enhancing democratic engagement, however there is limited evidence of its impact. 182. In Scotland, schools sought to enable young people to confidently participate in political discussions ahead of the 2014 independence referendum . Research found that although teachers faced various obstacles to deliver this, the impact was largely positive75. 183. In Wales, young people who had an opportunity to discuss votes at 16 either at school or in a youth club or society expressed higher likelihood to vote and greater interest in the 2021 Senedd election than those who had not (though the authors of this study highlighted that they could not rule out the possibility that the former were already more politically engaged). Additionally, the introduction of Votes at 16 in Wales during the COVID -19 pandemic limited the opportunity for formal and informal discussion in contexts such as education76. 184. In Estonia, following the lowering of the voting age for local elections in 2015, the government developed a guideline for political discussions in schools , which was developed with youth organisations and intended to be binding and non- partisan. The guide was revised after the first elections in 2017, to make it more effective in practice77. 185. In Austria, legislation to enhance the teaching of democracy and politics in schools was implemented concurrently to lowering the voting age78,79,80. Their educational provision included a web platform which enabled teachers to access materials and initiatives when they lowered the voting age to 16. Their curriculum shifted to focus upon developing competencies and skills rather than factual knowledge. F.2 Improving registration F.2.1 Methodology 75 Votes at 16 in Scotland - Eichhorn and Hübner, 2022 76 A False Start - Griffiths, Larner, Jones and Poole, 2025 77 Making Votes-at-16 Work in Wales: Lessons for the Future – Eichhorn, Smith, Mycock, Loughran & Hübner, 2023 78 Modernising Elections: How to Get Votes Back – Patel & Swift, 2024 79 Votes at 16: What Effect Would It Have? – Renwick, 2015 80 Votes at 16 Without Investment in Political Education Is a Missed Opportunity: Learning from Scotland and Wales – Hübner, Smith, Loughran, Mycock & Eichhorn, 2022 64 OFFICIAL OFFICIAL 186. The modelling for the Improving Registration policy follows a multistage approach to assess the volume of additional registrations and the associated costs. Stage 1: Estimate volume of incomplete register entries 187. The most recent Completeness and Accuracy report published by the EC81 is used to establish the baseline completeness of electoral registers as 86% for GB and 83% for Northern Ireland, working out to a weighted average of 85.9% for the UK. This corresponds to around 7.7 million people who were not correctly registered or were missing entirely from the register in December 2022. Adjusting this figure in line with ONS population projections 82, the total volume of incorrect and missing registrations, under the counterfactual scenario, is estimated for each year of the appraisal period. Stage 2: Assumptions of new completeness rate under the policy scenario 188. The assumption for the completeness of UK registers at the end of the appraisal period is informed by the completeness of Australian electoral registers, which was 92% as at 30th June 202483,84 – equivalent to an increase of 6 percentage points relative to the GB baseline of 86%. In the central scenario, the model assumes that, by the end of the appraisal period, the completeness of UK registers will have increased by 3 percentage points, equal to half of the total difference between the GB baseline and the Australian completeness rate. The overall increase is assumed to be achieved by uniform annual increases of 0.37 percentage points , in each of the eight years from 202 7/28 to the end of the appraisal period. When weighted in accordance with the respective electorates of Great Britain and Northern Ireland , this works out to a final UK register completeness rate of 88.9% by the end of the 10-year appraisal period. Stage 3: Estimate the additional complete register entries in each year 189. The difference between the assumed future completeness rate and the baseline completeness rate (86% for GB, 83% for NI) is multiplied by the eligible electors (highlighted in Stage 1) in each year of the appraisal period. This results in a total estimated figure of 1.7 million additional correct register entries by the end of the appraisal period. Stage 4: Calculate costs associated with additional register entries 81 Electoral registers in the UK - Electoral Commission, 2023 82 National population projections – Office for National Statistics, 2025 83 Size of the electoral roll and enrolment rate – Australian Electoral Commission, 2024 84 Annual Roll Integrity Review – Australian Electoral Commission, 2024 65 OFFICIAL OFFICIAL 190. The final stage is to calculate the various cost lines, with methodology for the costs outlined in the following section . In line with the policy implementation schedule, registration and conduct costs are modelled from the 2027/28 financial year onwards. 191. The most impactful assumption on the total modelled cost is the assumption for the new completeness rate following the policy interventions, described in Stage 2. F.2.2 Monetised impacts F.2.2.1 Direct costs Registration application processing costs 192. The estimated number of additional registrations is multiplied by the assumption for the staff time cost to process a registration application of £0.71 (2025/26 prices)85. 193. Registration application processing costs are estimated to be between £0.5 million and £1.6 million, with a central estimate of £1.0 million (2025/26 prices, 10-year PV). Postal correspondence costs 194. The model includes a provision for the overall cost of corresponding by post with electors. The unit cost per postal communication is assumed to be £1.14 (2025/26 prices), based on the cost of sending an Invitation to Register by post. The overall cost is calculated assuming that a number of postal c ommunications equal to 60% of the additional annual registrations will be sent , each year from 2027/28 to the end of the appraisal period. 195. Postal correspondence costs are estimated to be between £0.5 million and £1.5 million, with a central estimate of £ 1.0 million (2025/26 prices, 10 -year PV). Duplicate application costs 196. It is possible that interventions designed to increase completeness and accuracy may inadvertently lead to some duplicate electoral registration applications being made. While efforts will be made to avoid this as part of the detailed policy design, an allowance has been made here for costs associated with duplicate applications. 85 Internal survey of EROs – MHCLG, 2025 (Unpublished) 66 OFFICIAL OFFICIAL 197. The cost of processing duplicate registration applications is estimated by multiplying the average duplicate rate across LAs holding elections in a given year, ranging between 46.7% and 47.5%, depending on the year 86, by the number of additional registered electors at given completeness levels from the model. The resulting volume of duplicate applications is then multiplied by the assumed staff time cost to process a registration application of £0.71 (2025/26 prices)87. 198. Correspondence costs are also included . It is assumed that 19.4% of Register to Vote applicants do not consent to be contacted by email 88 and therefore receive postal correspondence in relation to their duplicate application. The unit cost of postal correspondence for each of these applicants is assumed to be the same as the average cost of sending an ITR of £1.14 (2025/26 prices )88. Email correspondence, applicable to the remaining 80.6% of duplicate applicants, is assumed to incur no cost. 199. Duplicate application costs are estimated to be between £0.3 million and £1.0 million, with a central estimate of £0.6 million (2025/26 prices, 10-year PV). In-person voting costs 200. The conduct cost per in-person voter of £0.18 (2025/26 prices)89 is multiplied by the estimated number of additional registered electors who will are expected to cast a vote in an election each year, using turnout rate from the last set of elections as a proxy, of 60.4% in UKPGE years90 and 31.6% in non-UKPGE years90. This is then weighted by the proportion of people who vote in-person, given the election typ e occurring in that year : 66.1% for UKPGE and 67.8% for local elections91. 201. In-person voting costs are estimated to be between £ 0.1 million and £0. 3 million, with a central estimate of £0.2 million (2025/26 prices, 10-year PV). Postal voting costs 202. The conduct cost per postal voter of £3.36 (2025/26 prices)89 is multiplied by the estimated number of additional registered electors who will are expected to cast a vote in an election each year, using a turnout rate of 60.4% in UKPGE years and 31.6% in non-UKPGE years92. This is then weighted by the proportion 86 Electoral registration in Great Britain in 2024 - Electoral Commission, 2025 87 Internal survey of EROs - MHCLG, 2025 (Unpublished) 88 Register to Vote application data - MHCLG, 2020-2025 (Unpublished) 89 Costs of the 2019 UK Parliamentary General Election – MHCLG, 2025 90 2024 UK Parliamentary general election and the May 2024 elections - Electoral Commission, 2024 91 Evaluation of Electoral Integrity Programme: public opinion research wave 3 – MHCLG, 2025 92 2024 UK Parliamentary general election and the May 2024 elections - Electoral Commission, 2024 67 OFFICIAL OFFICIAL of people who vote by post , given the election type occurring in that year : 33.9% for UKPGE years and 32.2% for non-UKPGE years93. 203. Postal voting costs are estimated to be between £0.9 million and £2.8 million, with a central estimate of £1.8 million (2025/26 prices, 10-year PV). Voter Authority Certificate costs 204. The additional registered electors may also choose to apply for a VAC to use as voter identification when voting in elections. The associated costs are estimated using the methodology from the Elections Act 2022 Voter ID I mpact Assessment94. Two cost lines are modelled in relation to VAC: the cost of processing VAC applications, and the production cost for paper VACs. 205. It is assumed that the percentage of registered electors who apply for a VAC is 0.28% in general election year s95. In years without a general election, it is assumed that 0.24% of registered electors in areas holding local elections wi ll apply for a VAC 96. It is assumed that 90% of VAC applications will lead to a VAC being printed97. 206. As discussed, the Government has announced its intention to introduce digital VACs and has since announced the introduction of a new digital ID scheme which will be implemented through separate future legislation . However, this appraisal reflects the current statutory position, and so it is assumed that demand and associated costs for paper VACs, remain unaffected by the potential introduction of either of these digital products. 207. The total cost is calculated by multiplying the number of applications and VACs sent to print by the unit costs (adjusted to 2025/26 prices) for processing applications and printing VACs used in the Elections Act 2022 Voter ID I mpact Assessment. 208. VAC costs are estimated to cost between <£0.1 million and <£0.1 million, with a central estimate of <£0.1 million (2025/26 prices, 10-year PV)98. Electoral Commission Costs 209. The EC has assessed the impact of the improving registration policy on the Commission and estimated the cost it will incur supporting implementation 93 Evaluation of Electoral Integrity Programme: public opinion research wave 3 – MHCLG, 2025 94 The Voter Identification Regulations - MHCLG, 2022 95 Voter Authority Certificate application data - MHCLG, 2024 (Unpublished) 96 Voter Authority Certificate application data - MHCLG, 2023 (Unpublished) 97 Voter Authority Certificate application data - MHCLG, 2023-25 (Unpublished) 98 The total estimated costs for VAC in the model are non-zero, but round to £0.0m when rounded to the nearest £0.1m. 68 OFFICIAL OFFICIAL of the policy. Wider staffing costs associated with the improving registration policy have been excluded, in line with the treatment of MHCLG departmental staffing costs in this impact assessment. 210. Detailed planning of the work required will be undertaken in parallel with the implementation of the policy. Cost estimates are therefore indicative and based on the EC’s current understanding of the proposed changes, as well as learning from the implementation of other major changes in the democratic process. 211. Electoral Commission costs are estimated between £ 0.2 million and £ 0.7 million, with a central estimate of £0.5 million (2025/26 prices, 10-year PV). F.2.2.2 Indirect costs 212. There are no monetisable indirect costs resulting from this policy. F.2.2.3 Direct benefits 213. There are no monetisable direct benefits resulting from this policy. F.2.2.4 Indirect benefits 214. There are no monetisable indirect benefits resulting from this policy. F.2.2.5 Summary – BNPV, NPSV, EANDCB 215. Under the central scenario, the estimated total quantified costs and benefits are £5.2 million and £0, respectively, which provides a NPSV for Improving Registration under Option 1 of around -£5.2 million (2025/26 prices) over the 10-year appraisal period. Table 5: Summary of monetised impacts for Improving Registration (£m 2025/26 - 2034/35) Impact Scenario Low Central High Benefits Total benefits - - - Costs Processing new registration applications 0.5 1.0 1.6 Postal correspondence with new applicants 0.5 1.0 1.5 Duplicate application costs 0.3 0.6 1.0 VAC processing and production <0.1 <0.1 <0.1 In-person voting 0.1 0.2 0.3 Postal voting 0.9 1.8 2.8 Electoral Commission 0.2 0.5 0.7 Total costs 2.6 5.2 7.8 NPSV -2.6 -5.2 -7.8 Figures may not sum due to rounding 69 OFFICIAL OFFICIAL 216. As there is inherent uncertainty with modelling the Improving Registration policy, analysis has been conducted to estimate the upper and lower bound of these estimates. To account for this, and other uncertainties, a range of +/- 50% of the central scenario has been applied to create a high and low scenario: • Under the low scenario, the estimated quantified total costs and benefits are £2.6 million and £0, respectively, thus resulting in an estimated NPSV of -£2.6 million (2025/26 prices, 10-year PV). • Under the high scenario, the estimated quantified total costs and benefits are £7.8 million and £0, respectively, leading to an estimated NPSV of -£7.8 million (2025/26 prices, 10-year PV). 217. Further sensitivity analysis has been conducted in section H that shows the change in outputs when the estimated completeness of the electoral register, the most sensitive assumption, is varied. 218. The BNPV and EANDCB are estimated to be £0 , as there are no direct impacts on businesses that fall within the scope of these measures. 219. While some businesses may be indirectly affected by the open register becoming opt-in, it is not proportional to quantify due to the lack of available information around the profit margin of the businesses involved. Additionally, they are second-order effects and are therefore excluded from the BNPV and EANDCB. For example, if fewer individuals choose to make their information publicly available, the volume of data accessible to these businesses to sell on or use for purposes could decrease, potentially req uiring them to adapt. However, these are considered second order effects, as they are not a direct result of the policy itself and instead depend on behavioural responses that are difficult to predict. As such, they are excluded from the BNPV and EANDCB. F.2.3 Non-monetised impacts F.2.3.1 Direct costs 220. Implementing new registration systems poses practical challenges including resource investment to develop and maintain infrastructure and train staff . The digital systems used for voter registration may require changes to support the implementation of the policy. The exact nature of these changes is yet to be defined, and any associated costs will be commercially sensitive. Therefore, these costs have not been monetised at this stage. F.2.3.2 Indirect costs 70 OFFICIAL OFFICIAL 221. There will be an additional staff cost to MHCLG to implement effective data sharing systems and infrastructure and work with other government departments to build the appropriate service s. The development of this policy has involved collaboration with several other government departments, particularly in relation to the assessment of government digital services. While these contributions involve some staff time, they are not considered significant in cost terms and have therefore not been monetised. 222. Other government departments may also incur some costs associated with supporting data -sharing arrangements , adapting existing digital services, and contributing to cross-government coordination. While these contributions may involve potential system changes, the exact nature of these changes is yet to be defined, and will be commercially sensitive so have not been monetised. 223. As discussed above, some businesses may be indirectly affected by the change to make the open register opt -in. The full register , used for credit referencing purposes, will remain unaffected by the change. However, the open register, used for other commercial purposes including resale by agencies 99, will be affected by the change. While the change will not prevent the open register being used for these purposes, it may result in a reduction in the volume of available entries, depending on the proportion of electors who choose to opt -in under the new model. Should a large proportion of electors choose not to opt-in, it is possible the dataset may be too limited to retain its current utility, diminishing its commercial value. As this impact is contingent on future elector behaviour and the resulting availability of data, it is deemed a second-order impact and therefore it is not monetised. It is also worth noting, the number of voters opted out of the open register has grown steadily in recent years, making it a less useful resource. In England and Wales, the figure was around a third in 2013 and has grown each year since 99. According to data from the Office of National Statistics, in December 2019 27.4 million voters were opted out of the open register in England and Wales. This was 63% of the 43.7 million electors registered to vote in local elections.100 F.2.3.3 Direct benefits 224. All of the legislative interventions have the potential to improve the completeness and accuracy of registration to some extent , as they make it easier for electors to register (assisted registration) or remove the burden of registering from electors (direct registration). This in turn would give a greater proportion of the population the opportunity to exercise their democratic right to vote. 99 Electoral Registers and Access to them - Johnston, 2025 100 Electoral statistics, UK - Office for National Statistics, 2021 71 OFFICIAL OFFICIAL Data sharing powers 225. In line with the Government’s ambition to modernise services and in recognition that technological advances will continue, the data sharing powers have been deliberately designed with broad scope to support both current policy objectives and provide flexibility for future developments . The new data sharing powers will make clear the ability for EROs, government departments, other public bodies across central and local government, the education sector and others to make new arrangements to share data in appropriate ways for electoral registration purposes. 226. Using enhanced data may improve accessibility by reducing barriers citizens may currently face when registering to vote. Through access to improved data, EROs could be better placed to facilitate more automated forms of registration, for example, by piloting ‘directly’ registering or updating entries they know to be eligible, or assisting eligible individuals to register and update current entries (as set out elsewhere in this legislation) , by supporting applicants and presenting them with semi-pre-populated application forms. 227. Enhanced data sharing capabilities could also enable EROs to more effectively identify individuals who are either not registered or incorrectly registered, and carry out their existing duties to invite such people to register and ensure their registers are as complete and accurate as possible. 228. While enhanced data sharing is expected to improve register completeness and accuracy, current evidence is limited and the scale of potential improvements remains uncertain. Further legislation, which will set out the detail of data sharing agreements, p iloting new registration methods , and testing data flows, will be essential to realising the full potential of these powers and ensuring their effective deployment. Direct registration 229. An important benefit of automated systems is that they are more inclusive of those with higher personal costs to registering , such as those from lower socioeconomic groups who may have limited access to information about registering101. 230. Research by the EC indicates there could be public support for automatic registration: In 2024, approximately half of respondents (52%) to the EC’s Winter Tracker survey said automatic registration would be better than the current 101 Do text messages increase voter registration? Evidence from RCTs with a local authority and an advocacy organisation in the UK - Cheng-Matsumo, Foos, John & Unan, 2023 72 OFFICIAL OFFICIAL system102. Additionally, 17% of respondents to the 2023 version of the survey said their satisfaction with the registration system would be most likely to increase ‘if it was possible to automatically be added to the electoral register when you receive your NINo aged 16103. 231. Evidence suggests that automatic/direct registration ha s the potential to increase the completeness of the register , although more research would be beneficial in the UK context. 232. James & Garnett’s (2023) 104 cross national analysis of 159 countries’ electoral registration systems finds that automatic registration systems are seen to significantly increase register completeness by 0.53 points on a 1 -5 scale, where the closer to 5 the better completeness. The same study suggests automatic/direct registration also has the potential to improve accuracy; the effect is statistically significant, but smaller (0.32 points on the 1-5 scale described above). It is important to note, however, that this study relies on the subjective judgements of ‘electoral integrity experts’ as opposed to more objective data on completeness and accuracy. 233. In addition, two US studies find that automatic registration increases completeness. Although these studies were not conducted in the UK, automatic registration appears to have had a positive effect in states of different sizes and characteristics. The first study compared seven states (and Washington DC) to jurisdictions where automatic registration was not in place. It found that registrations increased by between 9% and 94%, depending on the state105106. The second study used statistical techniques and multiple data sources from 2012 -2020. A cross states, it finds that automatic registration increased registration rates by 3% and by 0.2% each month107. Future of the Open Register 234. The policy change introduces a more robust standard of consent by requiring individuals to actively opt -in to the open register. This strengthens personal data autonomy and aligns with wider government objectives around digital safety and responsible data use, including commitments to uphold high standards of transparency, accountability, and individual control in the digital environment. By 102 Public attitudes 2024 - Electoral Commission, 2024 103 Public attitudes 2023 - Electoral Commission, 2023 104 The Determinants of Electoral Registration Quality: A Cross-National Analysis – James & Garnett, 2023 105 The large variation in effect size likely relates to differences in the way automatic registration was adopted and to variations in state characteristics. For example, automatic registration would likely have a greater impact when introduced in a state with a smaller proportion of eligible citizens already registered to vote. 106 Automatic Voter Registration – Morris and Dunphy, 2019 107 The Registration and Turnout Effects of Automatic Voter Registration - McGhee, Hill and Romero, 2021 73 OFFICIAL OFFICIAL reducing the risk of unintended or uninformed data sharing, the policy contributes to a safer digital infrastructure. 235. Key electoral stakeholders have suggested that , in its current form , the Open Register may deter potential electors from registering due to the prospect of having their personal data sold on108. As a result, the change to an opt-in system could enhance public trust in the electoral registration system and in turn potentially have a small positive impact on registration rates. F.2.3.4 Indirect benefits 236. Certain organisations are entitled to purchase copies of the full register and rely on this data to conduct credit checks and identity verification. If the move to an ‘opt-in’ model removes a deterrent to r egistration, it may result in more individuals being added to the full register. This could improve the accuracy and coverage of the data available to such organisations, enhancing their ability to carry out these checks effectively and responsibly. Moreover, removing the deterrent could also benefit the individuals who are able to get credit ratings after getting added to the register. F.3 Voter ID F.3.1 Methodology 237. It is assumed that allowing bank cards to be used as an accepted form of voter identification at polling stations will result in some additional costs to government and LAs. While bank cards are already widely held by electors and do not require new issuance systems, costs are expected to arise from updates to communications campaigns . These costs have been modelled based on information provided by the EC regarding planned updates to national communications and guidance for LAs. 238. The EC has indicated that the introduction of bank cards will not place a significant burden on communications activity. However, it will require updates to existing campaigns and guidance materials, which will result in additional costs. These have been estimated based on information provided by the EC on the planned updates and the advice they intend to issue to LAs. 239. The AEA has indicated that integrating bank cards into polling station guidance would not generate significant operational burdens , provided the changes are clearly communicated and incorporated into routine training. 108 Sale of the Register of Electors – The Association of Electoral Administrators, 2019 74 OFFICIAL OFFICIAL 240. The potential impact on elector behaviour and any resulting impact on costs have not been modelled, as the scale and direction of these effects are highly uncertain and therefore difficult to estimate with precision. While it is clear that some individuals experienced a barrier to in-person voting under the current photo ID requirement, robust modelling of the impact of allowing bank cards to be used is not possible given the limited and variable evidence . For example, fewer than 1% of people who tried to vote in -person at the 2024 UKPGE were turned away and didn’t come back later to vote because they didn’t show an accepted form of ID. This equates to nearly 16,000 individuals who weren’t able to cast their vote 109. A further 3% - 4% of non -voters cited ID as a factor in why they did not vote .110 Expanding the list of accepted ID s to include bank cards should help reduce the risk of voters not presenting a valid form of ID , particularly for individuals who face difficulty accessing the current set of approved IDs. However, there is limited evidence to reliably quantify the impact on voter behaviour. F.3.2 Monetised impacts F.3.2.1 Direct costs Local Authority Communications 241. It is assumed that there will be a justifiable benefit to LA-led communications activity to support the introduction of bank cards as an accepted form of voter identification, alongside the national campaign led by the EC. LAs are well placed to tailor messaging to their communities, drawing on their understanding of local demographics and communication channels to help ensure that all voters are aware of the change. While both national and local campaigns will deliver consistent messages, they will do so t hrough different forums and at different levels of engagement. Local communications are therefore expected to play a complementary role in reinforcing awareness and supporting effective implementation of the policy. 242. Communications costs for LAs have been estimated using a per -elector approach, consistent with the methodology used in the 2022 Elections Bill Impact Assessment111. In that assessment, the average cost per elector for local communications activity to support the full voter identification policy was estimated at £0.21. This per -elector metric allows for variation in LA size and reflects the resource intensity for larger versus smaller areas. For the introduction of bank cards as an additional form of accepted ID, information from the EC indicates that updates required to LA communications should be relatively minor, involving proportionate changes to existing material s. To reflect the more limited scope of this change 109 Voter ID at the 2024 UK general election - Electoral Commission, 2024 110 Voter ID at the 2024 UK general election - Electoral Commission, 2024; Evaluation of Electoral Integrity Programme: public opinion research wave 3 – MHCLG, 2025 111 Elections Bill Impact Assessment - Cabinet Office, 2022 75 OFFICIAL OFFICIAL compared to the original voter ID policy, a scale factor of 2% has been applied to the previous average cost per elector, and uplifted to account for inflation. 243. Total costs are then calculated by multiplying the adjusted cost per elector of £0.01 by the number of electors eligible to vote in each year where communications campaigns are expected to take place. 244. The total cost of LA -led communications activity around bank cards is estimated to be between £0.2 million and £0.6 million, with a central estimate of £0.4 million (2025/26 prices, 10-year PV). Electoral Commission Costs 245. The EC will be responsible for public awareness activities across GB to ensure that all voters, including those who may face barriers to meeting current ID requirements, are aware of the change and understand how bank cards can now be used as an accepted form of identification at polling stations. The EC will also be responsible for providing updated guidance and support to ROs and electoral administrators as they prepare for and deliver the change. 246. The EC has assessed the impact of the voter identification policy on the Commission and estimated the cost it will incur supporting implementation of the policy. Detailed planning of the work required will be undertaken in parallel with the implementation of the policy. Cost estimates are therefore indicative and based on the EC’s current understanding of the proposed changes, as well as learning from the implementation of other major changes in the democratic process. 247. Electoral Commission costs are estimated to be between £0.1 million and £0.3 million, with a central estimate of £0.2 million (2025/26 prices, 10-year PV).112 F.3.2.2 Indirect costs 248. There are no monetisable indirect costs resulting from this policy. F.3.2.3 Direct benefits 249. There are no monetisable direct benefits resulting from this policy. F.3.2.4 Indirect benefits 250. There are no monetisable indirect benefits resulting from this policy. F.3.2.5 Summary – BNPV, NPSV, EANDCB 112 These are not inflated or discounted as they have directly been provided by the EC. 76 OFFICIAL OFFICIAL 251. Under the central scenario, the estimated total quantified benefits and costs are £0 and £ 0.6 million, respectively, which provides a NPSV for Voter Identification under Option 1 of around -£0.6 million ( 2025/26 prices) over the 10 -year appraisal period. Table 6: Summary of monetised impacts for voter identification (£m, 2025/26 - 2034/35) Impact Scenario Low Central High Benefits Total benefits - - - Costs LA communications 0.2 0.4 0.6 Electoral Commission 0.1 0.2 0.3 Total costs 0.3 0.6 0.9 NPSV -0.3 -0.6 -0.9 Figures may not sum due to rounding 252. As there is inherent uncertainty with modelling the voter identification policy , analysis has been conducted to estimate the upper and lower bound of these estimates. To account for this, and other uncertainties, a range of +/- 50% of the central scenario has been applied to create a high and low scenario113: • Under the low scenario, the estimated quantified total costs and benefits are £0.3 million and £0, respectively, resulting in an estimated NPSV of -£0.3 million (2025/26 prices, 10-year PV). • Under the high scenario, the estimated quantified total costs and benefits are £0.9 million and £0, respectively, leading to an estimated NPSV of -£0.9 million (2025/26 prices, 10-year PV). 253. The BNPV and EANDCB is expected to be £0 as there are no impacts on businesses which fall in scope of the BNPV and EANDCB. Whilst some businesses may benefit from increased profit as a result of the introduction of this policy, there is no available evidence on this and it is therefore not propo rtional to monetise it. For example, the inclusion of bank cards as a form of identification could theoretically increase demand for bank cards, but ownership is already near - universal, and any marginal increase is n ot expected to have a material impact on business revenues or costs . As such, this potential effect is excluded from the BNPV and EANDCB. F.3.3 Non-monetised impacts 113 The +/- 50% range has not been applied to the cost line relating to Electoral Commission communications. Instead, a cost range for this cost line was provided by the EC directly, and has been used here. 77 OFFICIAL OFFICIAL F.3.3.1 Direct costs 254. Allowing bank cards to be used as Voter ID may increase the number of acceptable documents polling staff need to check, and could introduce complexity where cards lack photographs, names, or identifying features . Electoral administrators will need to be trained to recognise such cards and apply clear guidance on verification standards. These changes can be incorporated into existing pre-election training at marginal cost, though additional clarity in national guidance may be required. F.3.3.2 Indirect costs 255. Stakeholder feedback has previously emphasised the importance of public confidence in the voter ID policy. Allowing bank cards could prompt concerns about impersonation risk, even if actual incidence is very low. Indeed, survey data on using bank cards in the polling station found that people were less comfortable showing their bank card (73% comfortable) than other prevalently used photographic ID (driving licence – 88% comfortable, travel / concessionary pass – 86% comfortable and passport – 79% comfortab le).114 Safeguarding measures, such as clear eligibility criteria and visual aids for polling staff, may help to mitigate these perceptions. 256. Public confusion over eligibility may increase if the list of accepted IDs becomes more complex. Although awareness of the ID requirement is high (84%), awareness of specific forms of accepted ID, such as the VAC, remains lower (58%), and varied across the population 115. However, d ata from a 2025 public opinion survey carried out by Verian on behalf of MHCLG found th at t he likelihood of carrying a physical bank card outside the home is higher than other types of ID (81% versus 56% who carry a driving licence) which suggests adding bank cards could be easily adopted in practice. F.3.3.3 Direct benefits 257. Allowing bank cards to be used as Voter ID aligns with efforts to ensure all legitimate voters are able to vote at the polling station, should they wish to . Survey data collected by Verian on behalf of MHCLG in 2025 found that 92% of respondents have a physical bank card issued in the UK114. In addition, the research highlighted that adding bank cards to the list of accepted IDs closes the gap to less than 1% who do not have a form of ID. This is in line with data from the World Bank, which indicates that 96.4-99.8% of people aged 15 and over in the UK have a bank account, while Financial Conduct Authority research confirms that even holders of 114 Voter identification research - MHCLG, 2025 115 Voter ID at the 2024 UK general election - Electoral Commission, 2024 78 OFFICIAL OFFICIAL basic bank accounts, typically used by those facing financial hardship, are issued debit cards116. 258. Expanding the accepted ID list to include these may reduce dependency on free VACs, which have had relatively low uptake - just over 210,000 issued despite an estimated 750,000 eligible electors without photo ID. 259. While precise effects on turnout are uncertain, it is plausible that the policy could reduce perceived barriers for vulnerable groups, including those in socio- economically deprived areas, who may struggle to obtain formal photographic identification but do hold a bank card. As the research from Verian indicates, adding bank cards to the list of prescribed IDs closes the gap in ownership to less than 1% which should reduce the likelihood of electors being turned away at polling stations for not having an accepted form of ID. F.3.3.4 Indirect benefits 260. The policy could also support perceptions of fairness and accessibility of the Voter ID policy , especially if implemented alongside a clear communication campaign. Around 87% of people were aware of the need to bring ID when voting in person, but awareness levels varied across the population and were lower for 18 to 24 -year-olds (71%) and people from ethnic minority communities (76%) 117. Moreover, only 58% of people were aware of the VAC. Bank cards are more familiar, frequently carried, and may serve as a more accessible form of ID for day- to-day use. 261. Evidence from the Child Financial Harms Consortium and the Money and Pensions Service also suggests that debit card ownership is increasingly common among 16- to 18-year-olds, though data on 14 - to 17-year-olds remains limited . Therefore, inclusion of bank cards is anticipated to increase ownership levels of accepted ID types among young electors , subject to further evidence on ownership patterns from upcoming research being conducted by MHCLG. F.4 Candidate ID and Nomination Changes F.4.1 Monetised impacts 262. There are no monetisable costs or benefits, either direct or indirect, resulting from this policy. F.4.2 Non-monetised impacts 116 Financial Lives 2022 - Financial Conduct Authority, 2023 117 Voter ID at the 2024 UK general election - Electoral Commission, 2024; Evaluation of Electoral Integrity Programme: public opinion research wave 3 – MHCLG, 2025 79 OFFICIAL OFFICIAL F.4.2.1 Direct costs 263. The introduction of a statutory declaration and ID requirement may require updates to nomination forms, guidance materials, and data handling protocols. Similarly, enabling party withdrawal of nominations will require changes to nomination procedures. These are expected to be absorbed within existing administrative frameworks, with short -term resource implications for Returning Officers and suppliers. 264. The requirement for candidates to provide proof of ID as part of the nominations process are likely to result in a small time cost for candidates as well as elections staff who complete the checks. In the 2025 English local elections, a total of 8,624 candidates118 stood across 1,637 seats in 23 LAs119. This means that, on average, the change would have roughly resulted in an additional 375 ID checks per LA. The figure is much smaller from the recent UKPGE, where an average of seven candidates stood per constituency across the UK 120. Given the quantity of checks and short length of time they take , they are expected to be absorbed within existing administrative framework s and so have been deemed disproportionate to monetise. F.4.2.2 Indirect costs 265. There may be a temporary increase in candidate queries and administrative handling, particularly around ID submission and revocation procedures . Clear guidance and communications will be essential to minimise confusion and ensure consistent application across electoral areas. F.4.2.3. Direct benefits 266. The reforms will strengthen the integrity and transparency of the nominations process. A statutory declaration reinforces candidate accountability, while the ID requirement provides a proportionate safeguard against impersonation. Enabling political parties to revoke support for a candidate prior to the close of nominations will allow parties to uphold standards and respond to emerging concerns during the nomination period, without significant impact on the administration of the ele ction. It ensures voters are not misled about party endorsement and reduces reputational risk, particularly in high -profile contests where party affiliation is a key factor in voter decision-making. F.4.2.4. Indirect benefits 118 May 2025 local elections in England - Electoral Commission, 2025 119 Local elections 2025: Results and analysis - Isabel Buchanan, 2025 120 Who stood in the 2024 general election? - Rachael Harker, 2025 80 OFFICIAL OFFICIAL 267. These changes are expected to enhance public confidence in the democratic process by addressing vulnerabilities in candidate nominations and ensuring voters are not misled about party endorsement . They also support parties in upholding standards and provide Returning Officers with clearer procedures for managing nominations. F.5 Outcomes of the Elections Review F.5.1 Methodology 268. The Review of Electoral Conduct and Registration 121 was commissioned in October 2024 in response to growing pressures on the electoral system. The Review identified several specific issues requiring attention including inefficiencies in the postal vote process, burdensome registration procedures and challenges with high levels of registration activity in the lead up to polls. It also highlighted challenges in securing polling venues, recruiting polling station staff, and ensuring that ROs have access to the resources they need. 269. Upon completion, the review’s recommendations were grouped into the following categories: i. Electoral timetable ii. Absent voting iii. Electoral resourcing iv. Elector information power v. Election Forms Consolidation Measures 270. An assessment of all potential monetised and non -monetised impacts resulting from the policy has been undertaken. The EC has identified a monetised cost it expects to incur as a result of the proposed changes . The appraisal of the outcomes of the elections review policy areas also relies on a qualitative assessment of non -monetised impacts, where the assessment is proportionate to the scale and significance of the relevant policy. 271. To support this appraisal, a theory of change has been developed for the two most impactful categories, electoral timetable and absent voting. These are included in the annex and provide a structured framework for evaluating the key consequences of the reforms. F.5.2 Monetised impacts F.5.2.1 Direct costs 121 Letter from Minister Norris to the electoral sector - MHCLG, 2024