Individual Electoral Registration and Electoral Administration - Political and Constitutional Reform Committee Contents

3  Completeness and accuracy of the register


13. We welcome the Government's stated commitment to take steps to improve the completeness of the electoral registers.[10] The Cabinet Office and the Electoral Commission are currently conducting research to benchmark current levels of completeness prior to the implementation of individual registration, and this will clearly be necessary to gauge the impact of the change.

14. The introduction of individual electoral registration in Northern Ireland led to a significant fall in voter registration levels over the following years. While some of this resulted from the removal of names that should not have been on the register in the first place, some eligible people also fell off the register. The Government hopes that such a situation can be minimised in Great Britain by carrying forward people already on the register until after the general election in 2015, giving many existing electors a second opportunity to register, and the use of data matching (discussed below), coupled with the absence of any requirement for each person to re-register and provide personal identifiers each year.[11]

15. We have heard concerns during our inquiry, however, that some aspects of the Government's proposals risk having a negative impact on completeness, especially in areas with high population turnover. The fact that electoral registers are currently used for setting constituency boundaries makes even levels of completeness across the country particularly important. Having large numbers of eligible electors uncounted in future boundary reviews would also be detrimental to democracy.


16. One of the most controversial aspects of the Government's proposals is the proposal that "there should be no compulsion placed on an individual to make an application to register to vote".[12] This is on the basis that "while we [the Government] strongly encourage people to register to vote the Government believes the act is one of personal choice".[13] The Government makes the distinction between the current system, under which the householder's failure to complete and return the annual canvass form could disenfranchise other electors, and the proposed system, under which a failure to return the individual application would have no direct impact on other electors. The Government proposes therefore that it should remain an offence in future to fail to respond to attempts by electoral registration officers to discover who in a household is eligible to vote.

17. The Government also proposes to "allow a person to respond to an invitation to register by indicating that they do not wish to be chased", so as to "ensure that people are not repeatedly asked to register during a canvass period when they have no intention of doing so and that Electoral Registration Officers (EROs) direct their resources to finding eligible electors who want to be registered".[14]

18. There are two issues at stake here. First, should it be legal for people to choose not to register to vote? Second, if yes, how easy should it be made for them to opt out of the registration process?

19. There is a logic to the Government's argument for making registration voluntary, but the Electoral Commission has warned us of possible "unforeseen consequences" for civic society more generally

    The register performs an important civic function, beyond enabling us to vote, and those functions are also important in a democracy. It ensures the public are counted for purposes of representation and drawing boundaries. It ensures that political parties and candidates can contact electors and try and persuade them to vote, and of course it is the register from which potential jurors are drawn. It is also used in law for the purpose of credit reference agency checks and for detecting fraud.[15]

20. John Turner, from the Association of Electoral Administrators agreed

    There seems to me a sort of pervasive logic that gets us to a position where people will drop off the register, for reasons that have very little to do with voting, politics or even engagement with the democratic system. They would be persuaded for other reasons, such as jury service, not wanting to receive unsolicited mail, wishing to remain anonymous—for all sorts of security and perhaps other reasons.[16]

21. The Electoral Commission has also expressed strong concerns about making registration voluntary during the transition to the new system, describing the proposal as "confusing".[17]

22. In Northern Ireland, under a system of individual registration, it remains a criminal offence to fail to complete a registration form when asked to do so. There appears to be no reason why failure to complete and return a registration form should be a criminal offence in Northern Ireland but not in Great Britain. The Government should take steps to remedy this inconsistency.

23. Witnesses were also concerned about the way in which the Government proposed to make it easy for people to opt out of being contacted more than once during an annual registration cycle.[18] The Minister recognised that many witnesses, including the Electoral Commission and the Association of Electoral Administrators, had concerns about the ease at which people could 'opt out' of the current proposals. The Deputy Prime Minister indicated in the House that he had some sympathy for those concerns, and giving evidence to us the Minister stated "we would look at those and change those provisions when we bring forward the final legislation".[19] When challenged that the language of the White Paper could 'nudge' people into not registering to vote, the Minister replied

we will look at that evidence and certainly take on board the point about whether the combination of the opt-out and the language nudges, to use your phrase, people in the wrong direction, because that is absolutely something we are not trying to create.[20]

We welcome the Government's acknowledgment that care needs to be taken not to make it too easy for people to opt out from what is still regarded as a public duty, even under the Government's current proposal that failure to register to vote should not be a criminal offence. We urge the Government to take the necessary steps in this direction in the Bill.

24. Electoral Registration Officers have also expressed concern about the proposal. Julian Bassham from the London Borough of Southwark, told us "30%-odd of people who eventually we get registered are not really interested, they only go on for credit purposes and because we are going to fine them".[21] Louise Stamp from Tower Hamlets made clear that the current offences were by no means an empty threat, and were used to get people to complete annual canvass forms.[22] In his evidence to us, Chris Ruane MP agreed that the threat of fines for failure to complete a registration form had significantly improved electoral registration rates in his constituency.[23]

25. We heard concerns about the impact that this specific proposal could have on the completeness of the registers. The Electoral Commission has suggested that registration levels could fall to match turnout, in other words from around 90% to as little as 60%.[24] It is hard to say how accurate this prediction is. Large numbers of people with no intention to vote would presumably want to remain on the registers nonetheless, as being listed on the electoral register is one of the factors used for assessing applications for credit.

26. What seems likely, however, is that registration levels would fall by different amounts in different parts of the country, depending on their social and economic profile and the transience of the population. Using estimates based on what percentage of a constituency fills and returns a canvass form without receiving a reminder, John Turner of the Association of Electoral Administrators (AEA) agreed with this analysis, stating that once the 'carry forward' expires after the General Election in 2015 "in these sorts of leafy shires you could be talking about a drop of 10% or 15%. In inner city areas I think ...(a fall of up to 30%) is somewhere near the mark".[25]

27. Julian Bassham of the London Borough of Southwark agreed with the AEA's analysis. He told us "the problem is going to emerge after 2015 when, as an urban inner London authority, we will see a significant fall-off in the register".[26] His colleague from Stratford-on-Avon District Council, with a relatively stable population, was less concerned.[27]

28. We recommend that it should initially be an offence to fail to complete a voter registration form when asked to do so by the relevant electoral registration officer. This should be reviewed after five years of operation of the new system of individual registration, by which time registration levels may be high enough and a culture of individual registration sufficiently embedded for compulsion to no longer be necessary.

Constituency boundaries

29. Under the Parliamentary Voting System and Constituencies Act 2011, the Boundary Commissions are required to use the number of names on electoral registers as a basis for drawing constituency boundaries, with a narrow margin for manoeuvre. If levels of completeness come to vary significantly between different parts of the country, constituency boundaries will be redrawn on a basis that may be perceived as unfairly disadvantaging one party.

30. Unless addressed, this issue is likely to come to a head in 2015. On current plans, the Boundary Commissions will be conducting their next review on the basis of the electoral registers as they stand in December of that year. This is at a point when those electors carried over under the old system will have fallen off the registers, but will not yet have needed to exercise their vote under the new system: the first such elections—to local authorities and devolved bodies—are likely to take place in May 2016.[28] While there is a risk that there will be an ongoing variation in levels of completeness across the country, as anecdotal evidence already tells us urban areas have lower registration rates than rural areas,[29] that variation is likely to be at its most extreme in late 2015.

31. The Minister did not agree that there could be a fall in the completeness of the register after the carry-forward expires in Autumn 2015, and he therefore did not think there was a risk of the register being inaccurate for the redrawing of boundaries in December 2015. He told us "It is really the only data set that you can use for doing boundary reviews because it is the right group of people, eligible voters. We want it to be as accurate as possible, both for elections and for boundary review purposes, so we are very focused on that as well".[30]

32. For the next parliamentary constituency boundary reviews to be fair and representative, electoral registers across the country need to be at least as complete—and as consistently complete—as they are now. The Government needs to ensure that its proposals will achieve this end.

33. There is a risk that the electoral registers in December 2015 will be particularly varied in their levels of completeness: this matters because they will be used under current legislation as the basis for the next boundary review. We recommend using instead the registers as they stood on or before general election day in May 2015.


34. Witnesses have suggested that people in groups that are already under-represented on the registers, such as young people, electors from some BME communities, home movers, and those in private rented accommodation, are at particular risk of dropping off the register during the transition to IER. The Electoral Commission told us that even under the current system "under-registration and inaccuracy are closely associated with the social groups most likely to move home".[31]

35. Simon Woolley, Director of Operation Black Vote, told us that the introduction of IER would reduce registration rates amongst the groups he represents, at least initially: "that is going to happen, we have to brace ourselves for that".[32] Dr Toby James of Swansea University,[33] the British Youth Council,[34] and the National Union of Students raised similar concerns. The NUS called for "greater powers to the Electoral Commission, targeting of registration rates, coordinated campaigns together with local organisations and community groups, such as students' unions, and engagement with young people still in school or college even before they are eligible to vote".[35]

36. Louise Stamp, Electoral Services Manager for the London Borough Tower Hamlets, outlined the work that Tower Hamlets was doing to try and break down some of the cultural barriers (38% of the population of Tower Hamlets is Bengali) that some electors could have with registering to vote individually. She also highlighted the high turnover of electors in a dense urban area such as Tower Hamlets made the EROs role particularly challenging: "we get 60% movements in our annual canvass period, so that is a massive churn".[36] We recommend that the Electoral Commission's public information campaign around the launch of individual registration include as an important element strands aimed at encouraging those in groups currently under-represented on the electoral rolls to register to vote.

37. The Government proposes that those who are "unable or unwilling"[37] to provide a national insurance number (NINO) will normally have to produce two other items of identification from an approved list, such as a passport or photo driving licence. Those who cannot provide a form of photographic identification will have to present themselves to the local electoral registration office and sign a declaration. Disability charities have suggested to us that some disabled people, especially those in residential care, "may not only not have a national insurance number but also have difficulties in producing alternative evidence such as utility bills",[38] while the requirement to travel to an office could also be problematic for people with mobility or mental health problems.[39]

38. The Minister stated that the Government was committed to ensuring that every eligible elector could use his or her vote. He told us the Government would "make sure that, in all of those groups you particularly mention, no one is disenfranchised".[40] We welcome the Government's commitment to ensuring that all eligible electors will be enfranchised.

39. By providing for a variety of ways in which people can verify their identity, the Government has ensured that most of those entitled to vote should be able to register successfully if they want to. There may be a small number of people who neither have the required documentation nor are able to travel to an office to attest to their identity. We recommend that the Government ensure that people in this situation are not deprived of their right to vote.


40. We have heard during our inquiry of a variety of ways that might help encourage people to register to vote.

41. The edited register is available for general sale and is used by organisations for commercial activities, such as marketing, as well as by the political parties for campaigning. Electors who do not want their details to appear on the edited register need to opt out. The Ministry of Justice consulted on the future of the edited register in 2009-10; the Government's response to the consultation has not been published, possibly due to the change of Government in 2010.

42. The Electoral Commission and the Association of Electoral Administrators have both called for the publication of the edited register to cease. A 2008 survey conducted by the Local Government Association and the AEA found that "almost 9 in 10 electoral officers surveyed believed that the practice of selling the electoral register discouraged people from registering to vote".[41]

43. Some businesses, notably direct marketing agencies, rely on the edited electoral register to identify and access customers. In their written evidence to us, a people-finding website, stated that the edited register brings significant benefits to businesses and charities.[42] The Credit Services Association, which also incorporates the Debt Buyers and Sellers Group (DBSG), states that use of the full electoral register should be made available to debt collection agencies, as "not all financial crime occurs at the point credit is granted ... use of the register should be permitted throughout the lifetime of the agreement".[43] We thoroughly disagree with the CSA's proposal. Whatever benefit it might bring, we cannot justify the sale to commercial organisations of personal details gathered by the Government for electoral purposes. The Electoral Commission has suggested that if Government decides to keep the edited register that it should be changed to an opt in system, instead of opt out. We suspect that this option might well make the edited register too incomplete to be of much use. We recommend that the edited register should be abolished.

44. The AEA told us that traditional means of encouraging registration, even house to house canvassing, have only limited success in boosting registration rates: "it cost an awful lot of money to add about 5% of people to the register".[44] This suggests that it may be worth considering more unconventional techniques.


45. One of the main reasons for moving to a system of individual registration is to improve the accuracy of the registers, in particular by removing people who are ineligible to vote. However, they look less likely to be successful in ensuring that entries which become ineligible are subsequently removed in a timely way.


46. A central electoral register, such as the one that is in place in Northern Ireland, would have made identifying duplicate entries much simpler, but in July 2011 the Government decided to abandon plans for a Coordinated Online Register of Electors (CORE) on the basis that it was not "proportionate, cost effective or consistent with the Government's policy on databases and reducing the number of non-departmental public bodies".[45]

47. The Electoral Commission and Dr Stuart Wilks-Heeg, Director of Democratic Audit, both told us that without a central register, identifying duplicate entries would be difficult and resource-intensive, and in some cases impossible.[46] It would not be possible, as in Northern Ireland, to say "if I looked in at Belfast I could see someone is registered in Londonderry".[47]

48. The Government's alternative to a central database relies largely on data matching with information held by other public bodies. We discuss this in detail below.[48]

49. We recommend that the Government explore ways of improving the sharing of information between local authorities, especially where potential electors move house.


50. Individual registration should help to reduce the risk of some types of electoral fraud. The current system of household registration involves almost no verification of the data provided in response to the annual canvass, and is thus extremely vulnerable to fraud. It is unclear the extent to which such fraud in fact takes place. There does seem to be evidence, however, of a strong link between electoral register entries and other forms of fraud. A recent Metropolitan Police Service (MPS) and National Fraud Initiative Operation Amberhill, analysed identifiers on forged or counterfeit documents and found that 45.6% of these were positive matches on electoral register entries, because criminals had either stolen real identities or added bogus entries to the register to facilitate fraud.[49]

10   Cm 8108, para 2 Back

11   Cm 8108, paras 27-28 Back

12   Cm 8108, para 64 Back

13   Cm 8108, para 64 Back

14   Cm 8108, para 74 Back

15   Q 184 Back

16   Q 143 Back

17   Q 188 Back

18   Cm 8108, para 74 Back

19   Q 221 Back

20   Q 228 Back

21   Q 92 Back

22   Q 92 Back

23   Ev w30 Back

24   Q 201 Back

25   Q 169 Back

26   Q 85 Back

27   Q 82 Back

28   Q 261 Back

29   Electoral Commission, The completeness and accuracy of electoral registers in Great Britain, March 2010, pp 69-70 Back

30   Q 262 Back

31   Ev 100 Back

32   Q 96 Back

33   Ev w4 Back

34   Ev w24 Back

35   Ev w31  Back

36   Q 81 Back

37   Cm 8108, para 51 Back

38   Ev 84 Back

39   Ev w20 Back

40   Q 263 Back

41   Ev 104 Back

42   Ev w14 Back

43   Ev w14 Back

44   Q 158 Back

45   HC Deb, 17 July 2011, col 71WS  Back

46   Ev 70; Q 199 Back

47   Q 164 Back

48   Paras 79-84 Back

49   Cabinet Office, Individual Electoral Registration Impact Assessment, Cm 8109, June 2011, p 9 Back

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Prepared 4 November 2011