Memorandum by The Electoral Commission
The Electoral Commission welcomes the opportunity
to submit evidence to this joint inquiry launched by the ODPM
and Constitutional Affairs Committees on the issue of voter registration.
Please find the written evidence attached.
In its written evidence The Electoral Commission
has highlighted a number of recommendations to Government related
to electoral registration that are already in the public domain.
In particular, we have reiterated our belief that the adoption
of a system based on individual registration is the right approach
in principle for the whole of the UK. This is one of a series
of reforms to the electoral process proposed in our review The
electoral registration process. It formed part of our wider
modernisation agenda outlined in our report Voting for change.
Both reports were published in 2003.
1.1 The Electoral Commission (the Commission)
welcomes the opportunity to submit evidence to the joint ODPM
Select Committee and Constitutional Affairs Select Committee inquiry
into voter registration. We also particularly welcome the joint
approach to this inquiry, reflecting the shared Departmental lead
on electoral matters within government, and the role of local
government in managing electoral registration services.
1.2 The Commission will be happy to expand
upon or supplement any of the points made below in oral evidence
to the Committee.
2. THE ELECTORAL
2.1 The Electoral Commission was established
as an independent statutory authority on 30 November 2000, following
the commencement of the Political Parties, Elections and Referendums
2.2 The Commission is headed by a Chairman
with four other Commissioners. The Chairman and Commissioners
do not have connections to any political party, nor is the Commission
accountable to the Government. It reports directly to Parliament
through a committee chaired by the Speaker of the House of Commons.
The Commission has a UK-wide remit and has offices in London,
Edinburgh, Cardiff and Belfast.
2.3 The Electoral Commission is responsible
for overseeing a number of aspects of electoral lawthe
registration of political parties and third parties, monitoring
and publication of significant donations to registered political
parties and the regulation of national party spending on election
campaigns. In addition, the Commission has the role of managing
referendums in the UK and promoting voter awareness and advising
those involved in elections on practice and procedure, as well
as reporting on the administration of every major election.
2.4 Since its establishment in November
2000, the Electoral Commission has undertaken an extensive programme
of policy reviews and proposals for electoral modernisation. The
key recommendations for legislative reform were summarised in
Voting for change (June 2003). In general, the recommendations
made by the Commission have been well received and the Government
has already committed to the implementation of around 70% of the
proposals put forward in Voting for change.
3.1 This submission provides an overview
of the Commission's views on the issues raised in the Terms of
Reference for the Select Committee inquiry and outlines the Commission's
recommendations for modernisation of the electoral registration
3.2 The Commission considers electoral registration
to be the lynchpin of the electoral system and a key element of
the Commission's programme of reviews of electoral law and practice,
both past and present. The Commission places electoral registration
at the centre of its electoral modernisation programme. Our wider
modernisation agenda is outlined in our report Voting for change
(June 2003), appended as Annex 1.
3.3 The Electoral Commission draws the Select
Committee's attention to the Commission's report entitled The
electoral registration process (May 2003), appended as Annex
2. This report sets out the Commission's views on the current
arrangements for electoral registration in the UK. It details
matters relating to managing and creating the register, security
issues, tackling under-registration and sets out ways forward
in the reform and modernisation of the electoral registration
3.4 The Commission remains committed to
the findings and recommendations set out in The electoral registration
process. In particular, the Commission continues to believe
that individual registration is the right approach in principle
for the whole of the UK.
3.5 The Commission firmly believes that
a system based on individual registration is more consistent with
human rights and data protection legislation than current registration
3.6 The Commission also considers that individual
registration is necessary to best meet the increasing demands
from the voting public for postal voting (whether all-postal voting
or the increased take-up of postal voting "on demand").
More broadly, individual registration would also enable greater
voter choice by facilitating the development of multi-channel
voting, which necessarily demands a more robust system of registration.
3.7 The Commission acknowledges that there
are elements critical to the effective implementation of individual
registration, which need to be addressed in order to protect and
strengthen the integrity of the register. These include:
The development and delivery of concurrent
communication and outreach strategies, both general and those
aimed specifically at hard-to-reach groups that are most vulnerable
to being lost from the register; and
The need to consider a carefully
managed, phased approach to implementation.
3.8 The Commission is committed to working
with the Government and others to develop appropriate and pragmatic
strategies in this regard. The Commission acknowledges that this
may entail a programme of staged change towards the goal of individual
registration, built into a realistic timetable for wider electoral
modernisation that includes the development of multi-channel elections,
4.1 Registration in England, Wales and Scotland
is currently based on a combination of annual household registration
and individual "rolling" registration, which allows
for changes of personal details to be registered during the year
at the initiative of an individual. Registration in Northern Ireland
is now on an individual basis. 
4.2 In England, Wales and Scotland, at the
annual canvass, a form is sent for completion to the householder
(or a named person) who is obliged to complete and return the
form on his or her own behalf and on behalf of anyone else who
resides in the household and is eligible to vote. The form must
include details of those resident and eligible on a prescribed
date: 15 October.
4.3 In February 2001, the process of "rolling
registration" was introduced, providing a voluntary means
by which entries can be added to the register or deleted throughout
the year. The
onus is on the individual to amend their registration details.
Unlike the procedure for the annual canvass, each individual must
sign the application personally, providing details of previous
4.4 An additional factor has been the advent
of two versions of the register, the full version and the edited
version. An edited version of the register, from which individuals
have the right to "opt out" is available for sale to
any person or organisation. The consequence of this is that the
householder is asked at the annual canvass to indicate (in relation
to each individual on the form) whether individuals want to opt
out of the version of the register available for sale.
4.5 In addition to the overriding principle
that a right as fundamental as voting should only be secured by
personal initiative (no-one would suggest, for example, that voting
itself should be exercised by the head of household on behalf
of other householders), the Commission has identified five main
reasons for recommending a move to individual rather than household
Enhanced compliance with data protection
and human rights legislation;
Increased participation, over time;
Increased security and accuracy;
Support for modernisation of voting
These are examined in more detail below.
4.6 A move to individual registration in
England, Scotland and Wales would achieve both consistency within
the UK and remove the current distinction between individual "rolling"
registration and household "annual" registration. The
task of explaining the registration process to those eligible
to be registered would be made far simpler if there were to be
only a single process involved.
Enhanced compliance with data protection and human
4.7 The Commission firmly believes that
a move to individual registration is likely to be more compliant
with data protection and human rights legislation than existing
arrangements. Under a system of individual registration, each
individual would be required to provide information about him
or herself, rather than one individual (the "head of household")
providing information about others in the same household. Current
arrangements in which the responsibility for asking each individual
for his or her preference lies with the "head of household"
may provide some scope for abuse. These arrangements can prove
particularly problematic in multiple occupancy "households"
such as student residences and care homes for the elderly.
4.8 The majority of respondents to the consultation
process in the development of the Commission's report The electoral
registration process recognised the data protection and human
rights considerations and either supported the move to individual
registration as a matter of principle or felt it was inevitable
sooner or later. The Information Commissioner, responding to our
consultation, commented: ". . . household registration is
a remnant of the Victorian requirement of property qualification
for voters. In our view this arrangement is somewhat anachronistic
and we wonder how well it fits into today's framework of individual
rights and responsibilities."
4.9 The small minority of respondents to
this consultation process who preferred to stay with the current
method did so on grounds of practicality rather than principle,
in that the current system of household registration is known
and trusted by the public and its management and administration
are known quantities.
Increased participation, over time
4.10 Although the experience of introducing
individual registration to Northern Ireland might suggest an initial
impact of a drop in registration rates (the Commission is happy
to expand on this point in oral evidence), we believe that the
ultimate outcome of individual registration should be to empower
and encourage some under-registered groups to participate in the
democratic process and vote. For example, 18-24 year olds are
the least likely of all age groups to vote
and our research shows that many have little idea of how to register
or even of the need to register. This may be exacerbated by the
fact that their parents or (if students in university accommodation)
hall warden do the job for them. Within our current system of
household registration, these young people risk growing into householders
who are unaware of their responsibilities in relation to registration.
Inculcating the habit of registration from an early age could
be beneficial in maximising registration rates in later life.
4.11 As already noted, explaining the registration
process to potential electorsand so encouraging registrationwould
be easier for both the Commission and Electoral Registration Officers
if both the annual canvass and rolling registration operated on
an "individual" basis. Moreover, an effective public
awareness campaign on individual registration for under-registered
groups could well, over time, impact positively on participation
4.12 Individual registration would also
facilitate the introduction of more user-friendly systems of registration.
We have previously recommended a move away from a system that
is entirely reliant on the completion of paper forms in order
to encourage registration and increase accessibility. For example,
the Commission has supported moves to pilot telephone and online
registration. Although some local authorities have already initiated
such pilots, we believe that they would be more secure (and be
more able to secure public confidence) if a system of individual
registration were in operation. In addition, individual registration
could facilitate greater accessibility by enabling individual
electors to choose their preferred mode of voting at the point
Increased security and accuracy
4.13 One of the Commission's primary concerns
is to enhance the security of both the registration and voting
processes. We believe that individual registration offers two
key advantages in this regard:
First, the "household"
system currently operating at the annual canvass does not allow
for the collection of individual identifiers. Individual voter
identifiers could be used to check the identity of the individual
both at the point of registration (by reference to another existing
database) and/or when casting a ballot (when the identifier provided
at the point of registration could be checked with that provided
Second, the issue of a single form
to each household provides an opportunity for the "head of
household" to include (or exclude) information about residents
which renders the form inaccurate. This might be done deliberately
or accidentally (for example, because the head of household does
not realise that they are required to include certain household
members). A clear personal responsibility for completing a registration
form would reduce the scope for such errors and deliberate fraud.
Support for modernisation of voting arrangements
4.14 In the past, both the Commission and
the ODPM Select Committee have identified a clear link between
the use of all-postal voting and individual registration. The
Commission has recently recommended against any extension of all-postal
we continue to believe that individual registration is a necessary
part of the modernisation of the electoral process.
4.15 In particular, the Commission considers
that individual registration is necessary to:
(a) provide a robust framework for meeting
the increasing demands from the voting public for postal voting
on demand. At the 2004 European Parliamentary elections, postal
ballots were issued to 8.6% of the electorate across those regions
in Britain not holding all-postal pilots, higher than the 3.9%
across Britain at the 2001 general election. In some local authority
areas the take-up was higher still with around a quarter of the
electorate requesting a postal vote (in Stevenage, more than half52.6%did
so). With the growing level of postal voting on demand, the arguments
applying in relation to all-postal voting clearly need to be applied
equally to "traditional" voting.
(b) underpin the development of the Commission's
proposed new "foundation model" of voting. This new
model is being developed to ultimately achieve multi-channel voting
for all UK elections. It is intended to give voters choice whilst
learning the lessons from all-postal voting. The Commission will
be reporting later this year and the Government has indicated
that it will take account of the Commission's proposals in considering
the future of elections in the UK;
(c) provide a key building block in enabling
electronic and other multi-channel voting in future elections,
which necessarily demand a more robust system of registration.
4.16 The Government remains committed to
the goal of an "e-enabled general election", and has
indicated that it intends to publish an "electoral modernisation
strategy" shortly. We believe that the implementation timetable
for the Government's electoral modernisation programme and the
necessary steps towards an e-enabled general election need to
be carefully staged, managed and monitored, and considered alongside
other key policy commitments that could have a significant effect
on the success of the modernisation programme.
4.17 The Commission considers that the way
in which individual registration is taken forward is critical
to its success and to the integrity of the register. The practicalities
could have a significant impact on registration levels. Experience
from Northern Ireland suggests that, at least initially, it is
possible that registration levels could drop. Concern about this
has been expressed by a number of organisations and individuals,
both directly to The Electoral Commission and more publicly. Furthermore,
concerns have also been expressed about the practical difficulties
of implementation, including potential public resistance to what
might be perceived as increased bureaucracy.
4.18 The Commission takes these practical
concerns seriously. Nevertheless, the Commission continues to
believe that individual registration is the right approach in
principle for the whole of the UK. We also hold the view that
effective communication and outreach strategies must be an important
part of implementation in order to minimise unintended losses
from the register. We are committed to working with the Government
and others to develop appropriate strategies, building on our
experience in Northern Ireland. The Commission, in line with its
responsibilities under section 13 of the Political Parties, Elections
and Referendums Act 2000, would propose to mount a major public
awareness campaign around the introduction of individual registration
as well as contribute to other initiatives. This would include
both general responses and those aimed specifically at hard-to-reach
groups that are most vulnerable to being lost from the register.
4.19 We are pleased that in the Government's
recent response to our report Voting for change, the Government
expressed sympathy for the principles of individual registration,
whilst also noting the potential implications in terms of the
impact on registration data. We
are committed to working with the Government and all other interested
parties to develop a pragmatic and practical scheme for individual
4.20 An example of a possible staged approach
to the introduction of individual registration might include reducing
the frequency of the annual canvass, thereby placing more incentive
on electors to utilise the individual based "rolling registration"
arrangements and enabling resources to be redirected towards canvassing
under-represented groups. Whilst the Commission's report The
electoral registration process recommended that the annual
canvass be retained as an interim measure, it also indicated that
there was a case for introducing more local flexibility on the
use of the canvass or audit, within a statutory framework that
could specify maximum and minimum periods between canvasses.
4.21 The Commission notes that in November
2004, the Government announced that the annual canvass in Northern
Ireland would be abolished. This has resulted from concerns across
the political spectrum that the requirement on voters to reregister
and provide their personal identifiers afresh each year was leading
to a downward drift in the overall numbers registered.
5.1 The Commission has undertaken (and funded
others to undertake) considerable research over the last four
years in relation to understanding public motivations for participation
in the electoral processboth registration and voting. This
research programme is designed to inform our work programme and
provide a robust evidence base for others. All final research
reports are in the public domain.
5.2 Analysis in 1993 found 93% of those eligible
to vote in Britain were actually on the register. The
Commission is currently undertaking a major research project to
enhance our understanding of registration and in particular the
extent and nature of non-registration. A systematic comparison
of population data and electoral registers has not been repeated
since 1993. The research project will draw on statistical analysis
by the Office for National Statistics (ONS) estimating the extent
of non-registration in Britain
as well as case studies to investigate administrative practice
and the impact of "rolling registration" and public
opinion research. It is anticipated that this research will be
published in summer 2005.
5.3 Strategies for encouraging registration
and tackling non-registration need to reflect the root causes
of current behaviour. For example, in a 2003 public opinion survey
carried out for the Commission by MORI, the most common reason
given by those (of all ages) not registered was "just moved
house", mentioned by 23%.
5.4 The Commission's 2002 report Voter engagement
and young people (appended as Annex 3) considered the reasons
for the particularly high levels of non-registration among young
people and identified a number of contributory factors: "ignorance,
administrative inefficiency, having recently moved, alienation
from the political system and deliberate avoidance of registration
in relation to the secondary use of the register".
5.5 The Commission, in line with its responsibilities
under section 13 of the Political Parties, Elections and Referendums
Act 2000, has undertaken a range of public awareness work over
the last three years. In working to devise effective communication
strategies, the Commission has sought to acknowledge the diversity
of public experience identified in our research.
Public awareness work in Great Britain
5.6 In Great Britain, The Electoral Commission
currently carries out two strands of work aimed at encouraging
registration and tackling resistance to it. These strands are
defined by the target audience to which they are addressed.
5.7 The first strand tends to be targeted
at the entire electorate, and reminds voters to check that they
are registered prior to a forthcoming election or referendum.
This activity usually consists of high-profile advertising and
media relations across the geographical area covered by the election
or referendum. The campaign encourages people to call our helpline
or visit our website, to find out more information or to fill
in a registration form.
5.8 The second strand of activity is made
up of micro-campaigns targeted at tightly-defined and often hard
to reach areas of the population. Examples include students, those
moving home, overseas voters, and service voters - and uses media
best suited to address these groups, whether advertising, direct
mail, media relations, online communication or working in partnership
with third parties. These "micro-campaigns" encourage
people to register at any time of the year through filling in
a rolling registration form.
5.9 Since 2003, the Commission's pilot "Outreach
Programme" has also been working to encourage registration
specifically among young people aged 16-24 outside formal education.
The Outreach Team runs regular "democracy workshops"
with young people, encouraging them to register to vote. In the
run up to the European Parliamentary elections in June 2004 the
programme ran "The Box" tour of Great Britain which
informed young people about the forthcoming elections and encouraged
them to register. In addition, the Outreach Team distributes information
packs for youth workers and teachers for use with 18-24 year olds,
explaining to them how to register and the importance of registering.
5.10 Alongside these two main strands of activity,
the Commission produces and distributes registration forms, as
well as leaflets encouraging different groups to register, throughout
the year. Forms for rolling registration are available in a variety
of languages and formats. The Commission works in partnership
with commercial and public sector organisations to provide access
points for forms and leaflets, as well as online access via our
website. The Commission also produces materials promoting the
annual canvass for electoral administrators to use at the time
of the annual canvass. All materials are available for administrators
and other third parties to order free of charge.
5.11 Research and evaluation show the Commission's
activities to have positive effects on registration rates. For
example, the spring 2004 micro-campaign targeting home-movers
generated 53,000 individual registrations as a direct result of
a mailing from the Commission, with a further 6,000 people clicking
through to our website from online advertisements on home-mover
websites. "The Box" tour of Great Britain achieved over
1,000 registrations among young people. The all-electorate campaign
prior to the registration deadline for the 10 June 2004 European
Parliamentary elections resulted in over 12,000 visits to our
website during a two-week period, as well as over 3,000 calls
to our helpline.
Public awareness work in Northern Ireland
5.12 In Northern Ireland, where individual
registration is already in use, The Electoral Commission also
employs a two strand approach to encouraging registration, although
in this case both strands are aimed at the general public rather
than more targeted "micro campaigns".
5.13 The first strand aims to remind the
electorate of the need to register personally every year. Since
the introduction of the Electoral Fraud Act (Northern Ireland)
in 2002, the Commission has run an annual campaign reminding people
of the new processes involved in annual registration. This campaign
consists of high-profile, multi-media advertising, leafleting,
media relations and youth work, supported by a website and helpline.
Research shows that awareness of the need to register every year
now stands at 84%.
5.14 The second strand reminds voters of
the deadline to register prior to a forthcoming election. It is
designed to target any people who may not have registered through
annual registration, prior to relevant pre-election registration
deadlines. It consists of high-profile advertising and media relations.
5.15 In 2004, for the first time, the Commission's
Outreach Programme also ran a tour of university campuses in Northern
Ireland to encourage young people to register to vote.
Other initiatives to encourage registration
5.16 There is some evidence to suggest that
there is scope for successful interventions to increase registration
levels, especially in relation to well-defined audiences.
5.17 The Commission's research study Making
an Impact: the local promotion of electoral issues
(2002), describes what is being done at local level to encourage
registration, and provides best practice guidance for local authorities.
The researchers concluded that: "What is clear
that local promotion can have small but significant effects at
the margins. Raising awareness of how to register to vote is an
integral part of the electoral process. Doing it as well as possible
has to be the aim."
5.18 It is therefore a concern that, at
the local level, the Commission has identified a divergence of
views among Electoral Registration Officers as to how far they
should go in promoting registration, especially in targeting traditionally
under-represented groups. They have a duty to maintain the electoral
register and to include the names of all persons who appear to
them to be eligible for inclusion. Whilst some Electoral Registration
Officers do take a proactive approach to electoral registration,
including specific activities to encourage registration by under-represented
groups, others do not see targeted campaigning as part of their
role. Some have objections of principle, and express concerns
that targeted campaigning would be "political" as this
could be seen as boosting support for a particular political party
or parties. Electoral Registration Officers who express those
concerns also point to the risk that local politicians might seek
to intervene to influence the targeting.
5.19 The Commission understands the concerns
of Electoral Registration Officers in seeking to guard against
the possibility of political bias in the registration process
locally. However, given that the ultimate goal would be to ensure
(as near as possible) 100% registration of local communities,
it is difficult to see that not tackling under-registration in
certain sections of society is an acceptable position either.
5.20 The Commission's report The electoral
registration process (2003) recommends that Electoral Registration
Officers review their promotional strategies for electoral registration
and adopt the best practice put forward in the Commission's 2002
report Making an Impact: the local promotion of electoral issues.
We have also recommended that the Government should clarify the
legal position in relation to Electoral Registration Officers'
powers to undertake promotional work, and if necessary introduce
new legislation to put this on a clear footing. The Government's
recent response indicated that they were in agreement with the
desirability of such activity but were not currently persuaded
of the need for legislation in this regard. We
hope that the situation will be established beyond doubt in the
6. THE ADVANTAGES
6.1 It is a common perception that registration
is already compulsory. In fact, as the Select Committee will be
aware, the present situation is a curious hybrid of compulsion
6.2 At the annual canvass a registration form
is sent to the householder (or named person) who is obliged to
complete and return the form on their behalf and on behalf of
anyone else who resides in the household and is eligible to vote.
It is an offence under the Representation of the People (England
and Wales) Regulations 2001 to fail to comply with the request
for information or to give false information, thus making compliance
effectively compulsory. Since 1986, the penalty has been a fine
not exceeding £1,000. At present, no similar offence exists
for the provision of false information on a rolling registration
6.3 However, prosecutions are brought rarely
and the penalty is therefore not widely used. Many of those involved
in the delivery of electoral services have pointed out to the
Commission that the current sanction is largely unworkable. Many
electoral administrators consider that pursuing penalties would
be time-consuming, lengthy and not cost-effective. They point
out that if the identity and details of an individual who has
not registered are known, sufficient to pursue a case to court,
that individual could simply be registered rather than the authority
going to the expense and trouble of legal proceedings. In reality,
only individuals who deliberately intend not to register would
be pursued through the current mechanism.
6.4 There is also no compulsion on eligible
voters to register should their circumstances change between annual
canvasses. Whilst "rolling registration" is available
and designed to allow the updating of the register where changes
occur, notification of such changes mid-year remains voluntary
under current arrangements.
6.5 Representative organisations and electoral
administrators have pointed out to the Commission that, were a
more assertive line to be adopted on prosecution and penalties
for failure to return the annual canvass form, this could be frightening
and arguably inappropriate particularly for some groups in society,
notably elderly people, people with disabilities, those with learning
difficulties, and those with English as a second language, who
may have difficulty understanding the registration process.
6.6 The Commission holds the view that resources
are more effectively and appropriately spent on programmes and
initiatives designed to encourage and educate about the importance
of registration, rather than focused on deterrents for non-compliance
with regard to the return of the annual canvass form.
6.7 Were individual registration to be introduced,
it would be appropriate to apply the current sanction for failure
to provide information or false information to individuals rather
than householders as at present. There is no automatic link between
individual registration and compulsion. However, the nature of
any penalties and process for pursuing non-registrants would require
7. ISSUES OF
7.1 The available research suggests that
the reasons for under-registration are many and various. They
can be summarised as follows:
Disengagement from the political
process and politics generallyin other words, people do
not register because they are not interested in voting;
Avoiding "the authorities"those
seeking to avoid identification for criminal or other reasons;
Concern about other uses of the registerthe
fact that the register is for purposes other than electoral purposes
only, although this has been limited by regulation since 2002;
The lack of a facility for anonymous
Assumption that data provided to
one part of the local authority (eg council tax) will automatically
lead to the electoral roll being updated or resentment by some
members of the public to supplying their details to different
7.2 Registration rates also vary across
different socio-economic groups and the primary reasons for non-registration
will be different for different groups. Based on 1993 data from
OPCS (the Office of Population Censuses and Surveys and the predecessor
of ONS), non-registration rates appear to vary by geographical
area, by age, ethnicity and property ownership/tenure. The Commission's
review of research in Voter engagement among back and minority
ethnic communities supports these findings. Men were less
likely to be registered than women, and those living in inner
London are less likely to be registered than those living elsewhere.
Those aged 17-29 are significantly less likely to be registered
than older age groups, and there are higher levels of non-registration
among BME communities and those in privately rented accommodation.
7.3 The Electoral Commission's 2002 research
report Voter engagement among black and minority ethnic communities
considers the issue of ethnic variations in levels of voter registration
and provides an overview of research in this area. This is summarised
briefly in the following paragraphs.
7.4 Reasons given for non-registration among
BME communities include: newness, language difficulty, alienation,
concerns about anonymity and confidentiality, fear of harassment,
fear of officialdom, administrative inefficiency and doubts about
residence status. Some
of these factors can affect BME communities disproportionately
not only in relation to the wider community, but also in relation
to individual cases, particularly those relating to language difficulties
and concerns about safety and fear of harassment.
7.5 Registration among various communities
can also vary in relation to the methods used by local Electoral
Registration Officers. Local
authorities have contrasting policies on updating the register,
resulting in different levels of accuracy. 
7.6 The report also found that BME registration
levels have increased substantially over recent years, though
not uniformly for all groups. For example, Saggar's research into
the 1997 general election found that people of black African heritage
had one of the lowest registration levels at 87.1% compared with
those of black Caribbean (96%), white (96.9%), Indian (96.9%),
Pakistani (90.2%) and Bangladeshi (91.3%) heritage. 
7.7 These findings shed more light on some
of the variations across BME communities. It should be noted,
however, that these particular findings are based upon relatively
small numbers. Detailed analysis is also problematic because of
the limited breakdown of ethnic categories available.
Geography, tenure and deprivation
7.8 In urban areas and areas of economic
deprivation, levels of non-registration are substantially higher,
and it is not clear why this is so. In part, it is likely to be
linked with wider social disengagement from key public institutions
and deeper levels of political alienation. It is also likely to
reflect a more transient population in metropolitan areas; where
residents are in more settled communities the register experiences
less change over time.
7.9 There is also a link to the previous
issue, as it is estimated that a high proportion of people from
BME groups in the UK live in metropolitan areas. 
7.10 In Northern Ireland, variations were
pronounced between wards within constituencies and across Northern
Ireland registration rates were highest in rural wards located
in the west and south. We also found that people living in areas
of high social deprivation were less likely to be registered and
that owner-occupiers were more likely to be registered than those
in housing executive or private rented accommodation.
7.11 The Commission's current research project
on registration is examining further the impact of geography and
socio-economic factors on registration rates.
8.1 The Commission sees the primary objective
of an online register as helping to create a national register
of electors, collated and managed locally. The Commission has
reiterated this objective in several of its reportsand
this also appears to be a goal shared by the Government, political
parties and most electoral administrators.
8.2 The issues relating to electronic registers
and national registers are closely intertwined, as an electronic
register is logistically and practically the only sensible way
of achieving a national register.
8.3 An online register could also facilitate
the introduction of greater choice for electors in voting location.
With paper-based records, the only way of minimising to an acceptable
extent the risk of duplicate votes is by limiting electors to
a single polling station at which their name can be checked on
a paper record. With an electronic register which can be updated
in real time, it would be possible to offer electors a choice
of voting locationnear their home, place or work or elsewhere.
8.4 Furthermore, an electronic register
could also facilitate greater access to voting for disabled people.
The report by SCOPE, (Polls apart: a future for accessible
democracy, 2002) noted with particular reference to pilot
schemes with electronic electoral registers, that the schemes
"allowed voters to vote at any polling station which may
have enabled disabled people to visit the most accessible polling
station or the one that best met their needs ie close to work,
bus route etc."
8.5 A move to an electronic register would
also facilitate the further development of rolling registration,
by enabling electoral registers to be continuously updated. This
should ensure the production of the most-up-to-date register at
any one time and so enhance the security and accuracy of the register.
8.6 In January 2004, the Government announced
in Parliament its Co-ordinated On-line Register of Electors Project
(CORE), to be managed by the Office of the Deputy Prime Minister
and co-sponsored by the Department for Constitutional Affairs.
This project has been promoted by Government as an essential part
of its electoral modernisation agenda and underpinning the goal
of multi-channel, e-enabled elections. The Commission welcomes
this initiative as well as the opportunity to contribute to its
8.7 The Commission strongly believes that
CORE should provide a basis for the introduction of individual
registration, laying the foundations for the collection and management
of additional information that would be necessary. It is therefore
essential that any fundamental change to the registration process
and the co-ordination of registers should be developed with clear
objectives relating to business processes, and this should be
an integral part of the planning and development of the CORE project.
8.8 Moreover, the Commission considers that
the CORE project is a key part of any future work relating to
e-voting and e-counting pilots and the Government's goal of an
e-enabled general election. It is therefore essential that the
CORE project considers from the start the necessary synergies
with the wider electoral modernisation programme and future electoral
8.9 The Commission understands that the
Government intends to publish shortly a strategy paper outlining
its vision for electoral modernisation. In the context of the
significant number of individual projects likely to be contained
within the overall strategy, it is important that the Government
makes clear its view of the relationship between the CORE project
and other projects, including the possible introduction of individual
9.1 The Electoral Commission places a high
importance on ease of access to the registration process. Being
able to register as an elector is fundamental to the whole electoral
process. If potential electors are unable to complete their forms
and register for whatever reason, they will not be able to vote
and so be denied any further access to the electoral process.
This can be particularly relevant for people with visual impairments
that prevent them from reading forms and for those people who
have low levels of literacy or for whom English is not their first
9.2 The Commission recognises that the current
electoral registration form itself can be a barrier to registration.
It is currently prescribed by statute, including the detail of
what must be included. A lot of information has to be included
on electoral registration forms and in some cases this has meant
that very small print has been used, so that all the information
can be fitted on to the form. Furthermore, because the information
included has been prescribed by statute, it can appear bureaucratic
and not friendly for users who have difficulties reading or understanding
English. These people may need extra help in completing forms
or have guidance produced in an alternative format, if possible.
9.3 The Commission realises that this is
a significant problem. In response to SCOPE Cwmpas Cymru's review
of disability access (2003), volunteers reported that only a quarter
of electoral registration officers made registration materials
easily available in a variety of accessible formats. SCOPE Cwmpas
Cymru's volunteers specifically stated that they would have liked
Braille, large print forms and audiotape. Their research team
requested examples of good practice from all 22 local authorities
on improving access to the registration process. None were received.
9.4 While recognising the limitations of
the current legislation, and the necessity to produce a form to
the same effect as that specified in regulations, the Commission
has recommended that the electoral registration form be redesigned
to make it more user-friendly.
9.5 We have also recommended that, where
possible, all electoral registration forms should:
be written in clear, precise English
or Welsh, where appropriate;
give details of a helpline number
that people can ring if they require assistance. It is helpful
to also provide a textphone number, website address and email
offer help with registration form
filling for visually and learning impaired people;
be printed in a clear font and using
a minimum of 12 point whenever possible, although 14 point is
preferably be printed in black ink
on a white background; and
alternative formats and languages
should be available on request.
9.6 Some Electoral Registration Officers
have provided guidance notes explaining how to complete forms.
The Commission believes that this can be helpful to all electors
and may make it possible to reduce the amount of text on the actual
form. The guidance should be written in plain English and include
symbols and pictures. This will help all electors, including those
with low levels of literacy or who have limited understanding
of the process.
9.7 In the Commission's report on Equal
access to democracy (2003), we recommended that the existing
legal provisions for electoral pilot schemes should be extended
to allow for piloting of schemes which involve Electoral Registration
Officers asking for the individual access needs of electors at
the point of registration, in order to meet those needs at election
times. Our separate report The electoral registration process
2003) also recommended measures which would broaden access to
registration, including registration on-line and extended opportunities
for telephone registration.
9.8 We are pleased that the Government has
accepted many of the Commission's recommendations with regard
to making voting more accessible for disabled and minority groups.
However, we urge the Government to reconsider its position on
some of the Commission's other recommendations such as alternative
polling stations for the disabled, and Returning Officers having
the power to provide sample ballot papers in polling stations
in a variety of languages, Braille and large print.
10.1 In terms of access to, and appropriate
uses of, electoral registration data, the Commission's view remains
as stated in our May 2003 report The electoral registration
"the electoral register should be compiled
exclusively for electoral purposes and other limited statutory
purposes (such as summoning jurors) and it should not be made
available for sale."
10.2 The Commission has also been reviewing
the related issue of access to the marked version of the electoral
register. This review has examined, for example:
whether the register should be available
to political parties, constituency parties, candidates and holders
of elective office for electoral purposes;
whether the marked register should
be available for public scrutiny;
the role of the marked register in
providing an audit trail for electoral administrators for security
purposes by showing that a person has voted and thus safeguards
against fraud and double counting.
10.3 The Commission is due to release its
report on access to the marked register within the next few weeks.
A copy will be sent to the Committee on publication.
11. BASIS FOR
NI NUMBER OR
Means of ensuring the security of the register:
PIN numbers, electoral voting cards, signatures
11.1 We consider these two issues together,
as they are closely linked. Under the current registration system
in England, Wales and Scotland, the "head of household"
is required to complete the annual canvass form or an individual
registering through "rolling" registration is required
to sign the form but is not required to provide any other means
11.2 In our report, The electoral registration
process, the Commission considered that individual voter identifiers
would be an important contributor to the successful introduction
of individual voter registration in England, Wales and Scotland.
The Commission recognised that this is a complex matter and that,
if individual registration were introduced, this need not be solely
related to residence, as it is at present, and that other individual
identifiers could be introduced.
11.3 Accordingly, the Commission recommended
that the following individual identifiers be required in England,
Wales and Scotland:
Location-identifier (primarily an
address plus other categories currently provided for, such as
a declaration of local connection or service declaration).
Unique registration number.
11.4 The Commission's recommendation recognised
the preference to maintain the link to local government and local
constituency and so a location-identifier, primarily an address,
would continue to be a necessary part of voter identification.
11.5 The Commission believes that these
identifiers should be enabled through primary legislation and
the detail be addressed in secondary legislation, allowing more
time for detailed consideration of the practical implementation.
11.6 Individual voter identifiers are likely
to be particularly important if means of broadening access to
registration were introduced, such as online registration and
means of registering by telephone were extended (currently only
in operation in some localities and where there is "no change"
of personal details). The Commission recognises that there is
a balance to be struck between increasing the accessibility of
registration and maintaining security and guarding against fraud.
11.7 The question of voter identifiers is
clearly also linked to elections themselves becoming fully electronic
or "e-enabled". The availability of secure voter identifiers
would not only allow for casting and recording a vote at any polling
station within a constituency or ward, but would potentially assist
in establishing remote voting from any location. Currently, a
voter can vote only at a designated polling station, which may
or may not be convenient or fully accessible to that particular
voter. Broadening of access to polling stations and remote voting
may assist voters with disabilities, particularly where their
designated polling station is difficult to access. It would also
remove a barrier to voting which analysts of voter behaviour identify
as a significant reason for electors not turning out at electionsbeing
unable to vote in their designated polling station on polling
day for whatever personal reasons arise.
11.8 In the case of Northern Ireland, those
registering are also required to provide their date of birth and
national insurance number as well as individual signature in addition
to the information already required in the rest of the UK. Voters
in Northern Ireland are required to produce one of four forms
of prescribed photographic ID before being issued with a ballot
paper. Those without the necessary photographic ID can apply for
an electoral identity card.
11.9 The Commission believes it important
to recognise, however, that the additional identifiers required
in Northern Ireland were introduced to combat allegations/perceptions
of electoral fraud.
11.10 In the rest of the UK, perception
of electoral fraud is still considered to be low. The Commission
is concerned in this case to ensure that opportunities for fraud
do not increase as a result of broadening accessibility. The Commission
recognises that public confidence in the paper based electoral
system has traditionally been high and that the introduction of
electronic systems will raise fears among some members of the
public, justifiable or not, that on-line and electronic systems
will be prey to hackers and fraudsters. It is a key issue for
the Commission, therefore, to maintain high levels public confidence
in the electoral process.
11.11 It is important, in ensuring that
the security of the electoral registration process is maintained,
that new barriers to registering are not created which are likely
to lower registration levels.
11.12 The Commission believes that the allocation
of a unique individual registration number upon registration,
to be introduced at the same time as the introduction of individual
registration, is the best way to proceed for England, Wales and
Scotland. This number would remain unique to each individual for
life and be maintained on the electoral register. Voters would
not be required to remember his or her own number; the individual
identifiers would provide sufficient identification where necessary
where an individual moves residence, for example, and registration
details need to be revised.
11.13 The Commission notes the emergence
of the ID card scheme as Government policy in the period since
it published The electoral registration process. This initiative
may provide the Government with a comprehensive national system
of identification that might facilitate an individual voter registration
system. However, the Commission would emphasise that it does not
have any policy view on the introduction of the ID card scheme
as proposed by the Government and it continues to believe in principle
that measures which are introduced for electoral purposes should
be concerned as far as possible with the electoral processes alone
and not linked, unless clearly necessary, with non-electoral matters.
12. THE DESIRABILITY
12.1 Section 8 of this report has already
noted the link between issues relating to electronic registers
and those relating to national registers. The Commission supports
the concept of having locally maintained registers across the
UK that conform to common data standards and so enable a national
approach to be taken.
12.2 One potential benefit relates to the
statutory requirement for political parties and the Commission
to confirm the permissibility of individuals who make donations
to political parties (who must be on the electoral register).
Given the number of different data formats currently used to store
electoral registers, it is currently quicker for the Commission
to check with local authorities in order to confirm the permissibility
of donors, despite the fact that we receive copies of the registers.
National access would enable the Commission to fulfil its statutory
duties in relation to the rules on permissible donors more efficiently
and more accurately. Being able to undertake searches ourselves
would also ease the burden on Electoral Registration Officers,
as they would no longer need to submit register data to the Commission
and we would not need to contact them for information relating
to the electoral register.
12.3 National access would also allow parties
a more efficient and accurate method for checking donor permissibility
and should therefore enable them to comply more effectively with
the requirements of the Political Parties, Elections and Referendums
Act 2000 (PPERA).
12.4 One further benefit that might be gained
from national access mechanisms could be to facilitate periodic
research keeping under review the extent of non-registration and
the impact of rolling registration and other practical initiatives
designed to increase registration levels. At present, the absence
of a centrally held electronic register (in lieu of numerous,
dispersed individual registers) creates significant logistical
challenges for any research seeking to compare the registered
and eligible populations to ascertain non-registration. As well
as improving accessibility, an electronic register would permit
the electronic matching of registration and population recordsa
less time and resource-intensive process than manual matching.
(1996) Race and Elections, Routledge,
(1990) "Ethnic minorities and the
electoral process: some recent developments", in H Goulbourne
(ed), Black Politics in Britain, Gower, London.
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