Work of the Committee in 2020–21

This is a House of Commons Committee report.

Fourth Report of Session 2021

Author: Speaker’s Committee on the Electoral Commission

Date Published: 24 November 2021

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Contents

Work of the Committee in 202021

1. The Speaker’s Committee on the Electoral Commission (SCEC) is a statutory body established under the Political Parties, Elections and Referendums Act 2000 (PPERA). Its work relates to the Electoral Commission and the Local Government Boundary Commission for England (LGBCE).

2. Under paragraph 1(1) of Schedule 2 to the PPERA, the Speaker’s Committee is required to report to the House of Commons not less than once a year on the exercise of its functions. The last annual report covered the period from 1 April 2019 to 31 March 2020. This report covers the period from 1 April 2020 to 31 March 2021.

Membership

3. The Committee has nine members, five of whom are members of the House of Commons who are not Ministers and are appointed by the Speaker. One member—a Member of the House of Commons who is a Minister with responsibilities in relation to local government—is appointed by the Prime Minister. The ex officio members are the Minister for the Cabinet Office, the Chair of the Public Administration and Constitutional Affairs Committee, and the Speaker of the House of Commons, who chairs the Committee.

4. The ex-officio members of the Committee over this period were:

Speaker

  • Rt Hon Sir Lindsay Hoyle MP

Minister for the Cabinet Office

  • Rt Hon Michael Gove MP

Chair of the Public Administration and Constitutional Affairs Committee

William Wragg MP

5. The appointed members of the Committee over this period were:

Member appointed by the Prime Minister as a minister with responsibility for local government

  • Simon Clarke MP (from 18 May 2020 until 22 September 2021)
  • Luke Hall MP (from 22 September 2020)

Members appointed by Mr Speaker

  • Karl McCartney MP
  • Craig Mackinlay MP
  • Christian Matheson MP
  • Bridget Phillipson MP (until 11 May 2020)
  • Cat Smith MP (from 11 May 2020)
  • Owen Thompson MP

Meetings

6. The Committee met five times during the period covered by this report. It also took some decisions by correspondence between meetings. The minutes of the Committee’s meetings are reproduced in Appendix A.

Parliamentary Accountability

7. The Committee provides a mechanism for Members of Parliament to ask questions in the House of Commons about the work of the Electoral Commission and the LGBCE. Christian Matheson replaced Bridget Phillipson as Committee spokesperson in May 2020. He answered nine written questions on behalf of the Committee. Along with Owen Thompson, who deputised for him on 15 October, Mr Matheson answered 20 substantive oral questions and 20 supplementaries.

Appointment of Electoral Commissioners

8. The Electoral Commission was established by Parliament as a body independent of the Government. The Political Parties, Elections and Referendums Act 2000, as amended by the Political Parties and Elections Act 2009, provides for the Electoral Commission to have nine or ten Commissioners.1 Up to six are ‘ordinary’ Commissioners who may not be members or employees of a political party.2 These Commissioners are recruited by competition, under a procedure put in place and overseen by the Speaker’s Committee. Four Commissioners are persons put forward by the registered leader of a qualifying political party3 for consideration for appointment; they are described in the statute as ‘nominated’ Commissioners. While there are restrictions on their political activity, they are permitted to be members of parties, and to have been active in their party within the previous five years.4

9. Pursuant to Section 3 of the PPERA, the Speaker’s Committee on the Electoral Commission is responsible for determining and overseeing the procedures for selecting candidates to be put forward for appointment or re-appointment as Electoral Commissioners. The candidates for these posts are approved by the House of Commons and appointed by Her Majesty the Queen.

10. Over the period covered by this report, the Committee oversaw the processes for the appointment of the Chair of the Electoral Commission and the Electoral Commissioner for the smaller parties. It also oversaw the processes for the re-appointment of three Electoral Commissioners.

11. The Committee’s Third Report of 2020 set out the procedure followed in respect of the re-appointment of Alasdair Morgan as the Electoral Commissioner nominated by the Scottish National Party. On 7 September, the House approved a motion that an humble Address be presented to Her Majesty to re-appoint Mr Morgan for a further two-year term.

12. The Committee’s Fourth Report of 2020 set out the procedures followed in respect of the re-appointment of Dame Susan Bruce as the Electoral Commission with responsibility for Scotland, and Dame Elan Closs Stephens as the Electoral Commissioner with responsibility for Wales. On 18 November, the House approved a motion that an humble Address be presented to Her Majesty to re-appoint Dame Susan for a further three-year term and Dame Elan for a further four-year term.

13. The Committee’s Fifth Report of 2020 set out the procedures followed in respect of the appointment of Alexander Attwood as the Electoral Commissioner nominated by the smaller parties. On 20 January 2021, the House approved a motion that an humble Address be presented to Her Majesty to appoint Mr Attwood for a three-year term.

14. The Committee’s First Report of 2021 set out the procedures followed in respect of the appointment of John Pullinger CB as Chair of the Electoral Commission. On 22 March, the House approved a motion that an humble Address be presented to Her Majesty to appoint Mr Pullinger for a four-year term.

Appointment of the Chair of the Local Government Boundary Commission for England

15. Under the Local Democracy, Economic Development and Construction Act 2009, which created the Local Government Boundary Commission for England (LGBCE), the Speaker’s Committee is responsible for overseeing the process for appointing the Chair of the Commission. All other appointments to the Commission are the responsibility of the Ministry for Housing, Communities and Local Government. The Committee’s Second Report of 2020 sets out the procedures followed in respect of the re-appointment of Professor Colin Mellors OBE as Chair of the LGBCE. On 7 September, the House approved a motion that an humble Address be presented to Her Majesty to re-appoint Professor Mellors for a further five-year term.

Financial Scrutiny

16. The Committee’s role is to examine the estimates of resources needed for both the Electoral Commission and the LGBCE. It must also consider one statutory five-year plan and one value for money study in relation to each body during the life of a Parliament. The Speaker’s Committee has the power to require further such studies and reports to be produced as and when it sees fit.

17. The Speaker’s Committee must decide whether it is satisfied that the estimates and plans are consistent with the economical, efficient and effective discharge of each body’s functions. If it determines that they are not, it must modify them as necessary. In carrying out its work, the Committee consults with the Treasury and has regard to reports received from the National Audit Office concerning each body’s use of resources.

18. In the period covered by this report the Committee considered and approved a Supplementary Estimate for the Electoral Commission for the 2020–21 financial year. It also considered and approved Main Estimates for the 2021–22 financial year for both the Electoral Commission and the LGBCE.

19. The Electoral Commission’s Supplementary Estimate for 2020–21 returned £798,000 of Resource Departmental Expenditure Limited (DEL) to the Consolidated Fund. The main reasons for this reduction were: the deferral of the May 2020 elections; savings in the legal budget; and income received from the Scottish and Welsh Governments. The Supplementary Estimate also involved switching £235,000 of Resource DEL to capital to meet additional costs in respect of the Political Finance Online project, and reducing the Annual Managed Expenditure (AME) budget by £150,000.

20. In relation to the Electoral Commission’s Main Estimate for 2021–22, the Committee agreed a voted Resource DEL of £17,158,000, a voted Capital DEL of £713,000, and a voted resource AME of £200,000, as consistent with the economical, efficient and effective discharge of its functions in that year. The Committee also noted a document setting out how the Electoral Commission planned to apportion its funding between the Main Estimate and income from the Scottish and Welsh Parliaments.

21. In relation to the LGBCE’s Main Estimate, the Committee agreed a voted Resource DEL for 2021–22 of £2,257,000, a voted Capital DEL of £50,000, and a voted Resource AME of £60,000 as consistent with the economical, efficient and effective discharge of its functions in that year.

22. In examining the two bodies’ Estimates, the Committee took account of the latest report from the Comptroller and Auditor General. It consulted the Treasury which, in all cases, noted the Estimates without further comment.

Appendix: Minutes of the Speaker’s Committee

Speaker’s Committee for the Electoral Commission Formal Minutes of the meeting on 22 January 2020 in the Speaker’s Study

Mr Speaker, in the Chair

Karl McCartney

Craig Mackinlay

Christian Matheson

Bridget Phillipson

Apologies: Oliver Dowden, Owen Thompson

(Private)

1. Declaration of interests

Members declared their interests as listed in the Register of Members’ Financial interests as at 11 January 2020.

2. Committee spokesperson

Mr Speaker informed the Committee that he had asked Bridget Phillipson to continue acting as spokesperson.

3. Consideration of formal minutes of previous meeting

The Committee agreed the minutes without modification.

4. Discussion with Electoral Commission

Bob Posner, Chief Executive, and Kieran Rix, Director of Finance and Corporate Services, Electoral Commission, were questioned on the Commission’s Supplementary Estimate for 2019–20.

5. Electoral Commission Supplementary Estimate 2019–20

The Committee agreed the Electoral Commission’s Supplementary Estimate for 2019–20, subject to the removal of £220,000 included for possible elections to the Northern Ireland Assembly, which was no longer required.

6. Electoral Commission designation of posts

The Committee agreed to a proposal from the Chief Executive of the Electoral Commission to extend the designation of posts under paragraph 11B of Schedule 1 to the Political Parties, Elections and Referendums Act 2000.

[The Committee adjourned

Speaker’s Committee for the Electoral Commission Formal Minutes of the meeting on 24 March 2020 in the Speaker’s Study

Mr Speaker, in the Chair

Karl McCartney

Christian Matheson

Bridget Phillipson

Apologies: Michael Gove, Craig Mackinlay, Owen Thompson

(Private)

1. Minutes of last meeting

The Committee agreed the minutes without modification.

2. Local Government Boundary Commission for England Main Estimate 2020–21 and five-year plan 2020–21 to 2024–25

The Committee noted the changes to the LGBCE Estimate arising as a result of revisions to Treasury accounting guidance. It considered the advice provided by the Treasury and agreed the revised Estimate and five-year plan as being consistent with the Commission’s economical, efficient and effective discharge of its functions.

3. Electoral Commission Main Estimate 2020–21 and five-year plan 2020–21 to 2024–25

The Committee noted the letter the Speaker had received from the Minister for the Constitution and Devolution. It agreed to seek further information about the Electoral Commission about its plans to increase its capacity for prosecutions.

The Committee considered the advice provided by the Treasury and agreed the Estimate and five-year plan as being consistent with the Commission’s economical, efficient and effective discharge of its functions.

4. Committee Annual Report 2018–19

The Committee agreed its Annual Report for 2018–19.

5. National Audit Office reports on the Electoral Commission and Local Government Boundary Commission for England

The Committee considered the reports produced by the National Audit Office on the Electoral Commission and Local Government Boundary Commission for England. It agreed that thanks should be passed to the NAO for their work on the reports, and that the NAO should be given permission to publish them.

6. Appointments to the Electoral Commission and Local Government Boundary Commission for England.

The Committee considered correspondence from the Chief Executive and Chair of the Electoral Commission and the Chief Executive of the LGBCE. It agreed to a number of steps in relation to forthcoming appointments:The Committee agreed to seek written feedback on the performance of the Chairs of the LGBCE and Electoral Commission before considering whether they should be recommended for reappointment.

  • The Committee agreed to recommend Alasdair Morgan for reappointment as the SNP-nominated Electoral Commission and to commence a process of consultation with the leaders of registered political parties.
  • The Committee agreed to put in place a process for the appointment of the Electoral Commissioner for the smaller parties.
  • The Committee agreed to consult the Scottish Parliament and National Assembly for Wales respectively on the appointment of the lead Commissioners for Scotland and Wales.
  • The Committee agreed to put in place a process for the recruitment of a lead Commissioner for Northern Ireland.

7. Appointments to the Electoral Commission and Local Government Boundary Commission for England.

The Committee came to the following resolution—

That the Committee may take decisions by email correspondence, provided that: a) proposed decisions are first sent by email to all members of the Committee; and b) members of the Committee are given 24 hours from the email being sent to object to any proposed decision.

[The Committee adjourned

Speaker’s Committee for the Electoral Commission

Record of Decisions taken between meetings

Mr Speaker proposed to the Committee by email the appointment of the following panels to carry out the selection processes and report back on appointable candidates:

Recruitment panel for lead Electoral Commissioner for Northern Ireland

Chair of the panel: Dolores O’Reilly

Members: Sir John Holmes, Christian Matheson MP, Mr William Wragg MP

Recruitment panel for Electoral Commissioner for the Smaller Parties

Chair of the panel: Philippa Helme CB

Members: Sir John Holmes, Christian Matheson MP, Mr William Wragg MP

No objections were received to Mr Speaker’s proposal. In accordance with the Committee’s resolution of 24 March 2020, Mr Speaker’s proposal was therefore agreed to.

It was subsequently proposed that Karl McCartney replace Mr William Wragg on the panel to appoint the Commissioner for the Smaller Parties. No objections were raised, and Karl McCartney was therefore appointed.

Speaker’s Committee on the Electoral Commission Formal Minutes of the meeting on 16 July 2020

Virtual meeting

Attendance throughout the meeting:

Mr Speaker, in the Chair

Simon Clarke

Karl McCartney

Craig Mackinlay

Christian Matheson

Cat Smith

Owen Thompson

Mr William Wragg

(Private)

1. Declarations of interests

Simon Clarke, Cat Smith, Owen Thompson and Mr William Wragg declared their interests as listed in the Register of Members’ Financial Interests as at 6 July 2020. Owen Thompson additionally declared that his partner was a councillor in Scotland.

2. Minutes of last meeting

The Committee agreed the minutes without modification.

3. Chair of the Local Government Boundary Commission for England

The Committee considered a draft report commending to the House of Commons the reappointment of Professor Colin Mellors OBE as Chair of the Local Government Boundary Commission for England for a further period of five years. Mr Speaker asked each member in turn whether they were content for the report to be laid before the House:

Aye

Simon Clarke

Karl McCartney

Craig Mackinlay

Christian Matheson

Cat Smith

Owen Thompson

Mr William Wragg

It was therefore agreed that the Committee would lay before the House a report recommending the reappointment of Professor Colin Mellors for a further period of five years.

4. Electoral Commissioner nominated by the Scottish National Party

The Committee considered a draft report commending to the House of Commons the reappointment of Alasdair Morgan as a nominated Electoral Commissioner for a further period of two years. Mr Speaker asked each member in turn whether they were content for the report to be laid before the House:

Aye

Simon Clarke

Karl McCartney

Craig Mackinlay

Christian Matheson

Cat Smith

Owen Thompson

Mr William Wragg

5. Lead Electoral Commissioner for Scotland

The Committee considered whether to recommend Dame Sue Bruce for reappointment as the lead Electoral Commissioner for Scotland for a further period of three years. It noted an appraisal of Dame Sue’s performance by the Chair of the Electoral Commission and a letter from the Presiding Officer of the Scottish Parliament.

Mr Speaker asked each member in turn whether they were content to recommend Dame Sue for reappointment on the basis proposed, subject to the statutory consultation with party leaders:

Aye

Simon Clarke

Karl McCartney

Craig Mackinlay

Christian Matheson

Cat Smith

Owen Thompson

Mr William Wragg

It was therefore agreed that the Committee would recommend Dame Sue for reappointment for a further term of three years, subject to the statutory consultation with the party leaders.

6. Lead Electoral Commissioner for Wales

The Committee considered whether to recommend Dame Elan Closs Stephens for reappointment as the lead Electoral Commissioner for Scotland for a further period of four years. It noted an appraisal of Dame Elan’s performance by the Chair of the Electoral Commission and a letter from the Llywydd of Senedd Cymru.

Mr Speaker asked each member in turn whether they were content to recommend Dame Elan for reappointment on the basis proposed, subject to the statutory consultation with party leaders:

Aye

Simon Clarke

Karl McCartney

Craig Mackinlay

Christian Matheson

Cat Smith

Owen Thompson

Mr William Wragg

It was therefore agreed that the Committee would recommend Dame Elan for reappointment for a further term of four years, subject to the statutory consultation with the party leaders.

7. Chair of the Electoral Commission

The Committee considered whether to recommend Sir John Holmes for re-appointment as Chair of the Electoral Commission. It noted feedback gathered by Mr Speaker from serving Commissioners, former Commissioners, the Chief Executive and a key stakeholder.

Mr Speaker asked each member in turn whether they were content to recommend Sir John for reappointment:

No

Simon Clarke

Karl McCartney

Craig Mackinlay

Mr William Wragg

It was therefore agreed not to recommend Sir John Holmes for reappointment.

Mr Speaker then proposed a procedure for selecting a new Chair of the Electoral Commission. This procedure would involve the Committee delegating to Mr Speaker the appointment of a panel to carry out a recruitment competition and to report back on appointable candidates. Mr Speaker asked each member whether they were content to put in place this procedure:

Aye

Simon Clarke

Karl McCartney

Craig Mackinlay

Christian Matheson

Cat Smith

Owen Thompson

Mr William Wragg

The procedure, as proposed, was therefore agreed to.

8. Update on other appointments

The Committee noted the ongoing recruitment processes for a lead Electoral Commissioner for Northern Ireland and the Electoral Commissioner for the smaller parties.

9. Any other business

There was no other business.

[The Committee adjourned

Speaker’s Committee for the Electoral Commission

Record of Decisions taken between meetings

The Committee was consulted on two proposals:

1. That a report be laid before the House recommending that Alexander Attwood be appointed to the Committee for a three year term. The Committee was informed that no objections had been raised to the appointment in the statutory consultation with qualifying party leaders.

2. That the contents of a reply from Mr Speaker to the Chief Executive of the Electoral Commission be approved. The letter agreed with Mr Posner’s suggestion that the submission of a revised. strategy by the Electoral Commission await the appointment of the new chair

No objection was received to either proposal. In accordance with the Committee’s resolution of 24 March 2020, the proposals were therefore agreed to.

Speaker’s Committee on the Electoral Commission Formal Minutes of the meeting on 30 September 2020

Virtual meeting

Mr Speaker, in the Chair

Karl McCartney (virtual)

Craig Mackinlay

Christian Matheson

Michael Gove

Luke Hall

Cat Smith

Owen Thompson

Mr William Wragg

(Private)

1. Declarations of interests

Michael Gove and Luke Hall declared interests as listed in the Register of Members’ Financial Interests as at 14 September 2020.

2. Minutes of last meeting

The Committee agreed the minutes without modification.

3. Electoral Commission devolved funding arrangements

Bob Posner, Chief Executive, and Kieran Rix, Director of Finance and Corporate Services, Electoral Commission, briefed the Committee on proposals for part of the Electoral Commission’s funding to be provided by Senedd Cymru and the Scottish Parliament with effect from the 2021–22 financial year.

Mr Speaker left the meeting and Christian Matheson was called to the Chair.

Christian Matheson reported back on a meeting he had held with the Deputy Presiding Officer of Senedd Cymru.

4. Electoral Commissioner nominated by the smaller parties

The Committee agreed to recommend Alexander Attwood for appointment as Electoral Commissioner for the smaller parties, subject to the statutory consultation with party leaders.

The Committee agreed to recommend that Mr Attwood be appointed for a three-year term.

5. Electoral Commissioners with responsibility for Scotland and Wales

The Committee considered the outcome of the statutory consultation on the re-appointment of Dame Sue Bruce as lead Electoral Commissioner for Scotland, and Dame Elan Closs Stephens as lead Electoral Commissioner for Wales.

It agreed to lay before the House a report commending Dame Susan’s re-appointment for a further three years, and Dame Elan’s re-appointment for a further four years.

6. Chair of the Electoral Commission

The Committee noted the panel Mr Speaker had appointed to select candidates for the post of Chair of the Electoral Commission.

The Committee agreed that the panel should be asked to provide Mr Speaker with a ranked list of appointable candidates. The Committee also asked to panel to review and sign off the job description and person specification.

The Committee agreed to appoint GatenbySanderson as consultants to assist with the search.

The Committee agreed that it would hold a public session with its preferred candidate before deciding whether to recommend their appointment to the House.

7. Annual report 2019–20

The Committee agreed its annual report for 2019–20 and asked that it be laid before the House.

8. Any other business

There was no other business.

[The Committee adjourned

Speaker’s Committee on the Electoral Commission Formal Minutes of the meeting on 26 January 2021 in the Speaker’s study and virtually via Microsoft Teams

Mr Speaker, in the Chair (physical)

Karl McCartney (virtual)

Craig Mackinlay

Christian Matheson (physical)

Michael Gove (virtual)

Luke Hall (virtual)

Cat Smith (virtual)

Owen Thompson (virtual)

Mr William Wragg (virtual)

(Private)

1. Minutes of last meeting

The Committee agreed the minutes without modification.

2. Electoral Commission Supplementary Estimate 2020–21

Rob Vincent, Electoral Commissioner, Bob Posner, Chief Executive, and Kieran Rix, Director of Finance and Corporate Services, Electoral Commission, briefed the Committee on the Electoral Commission’s Supplementary Estimate for 2020–21. After taking questions from Members, they left the meeting.

The Committee then examined the Estimates and was satisfied that the estimated level of income and expenditure was consistent with the economical, efficient and effective discharge by the Commission of their functions.

3. Appointment of Chair of the Electoral Commission

The Committee considered the report of the panel appointed to assess candidates for the post of Chair of the Electoral Commission. In line with the panel’s recommendation, it agreed to put John Pullinger forward for consultation with the party leaders. The Committee noted that, subject to the outcome of this consultation, it would hold a meeting in public with Mr Pullinger before making a final decision on whether to recommend him for appointment.

4. Appointment of Electoral Commissioner for Northern Ireland

The Committee noted progress towards appointing a Commissioner for Northern Ireland. It decided that, if the House agreed to John Pullinger’s appointment, he should replace Sir John Holmes on the panel for the interview stage.

[The Committee adjourned

Speaker’s Committee on the Electoral Commission Formal Minutes of the meeting on 1 March 2021

Virtual meeting

Mr Speaker, in the Chair

Karl McCartney

Craig Mackinlay

Christian Matheson

Luke Hall

Cat Smith

Owen Thompson

Mr William Wragg

(Private, via Microsoft Teams)

1. Minutes of last meeting

The Committee agreed the minutes without modification.

2. Discussion of lines of questioning

The Committee discussed lines of questioning.

(Public, via Zoom)

3. Meeting with proposed candidate for Chair of the Electoral Commission

The Committee questioned John Pullinger CB, proposed candidate for Chair of the Electoral Commission, about his suitability for the role.

(Private, via Microsoft Teams)

4. Appointment of Chair of the Electoral Commission

The Committee agreed to recommend to the House the appointment of John Pullinger CB as Chair of the Electoral Commission. It agreed the contents of a report to be laid before the House.

5. Appointment of lead Electoral Commissioner for Northern Ireland

The Committee noted progress towards the appointment a lead Electoral Commissioner for Northern Ireland.

[The Committee adjourned)

Speaker’s Committee on the Electoral Commission Formal Minutes of the meeting on 23 March 2021

Virtual meeting

Mr Speaker, in the Chair

Karl McCartney

Craig Mackinlay

Christian Matheson

Michael Gove

Cat Smith

Owen Thompson

Mr William Wragg

(Private, via Microsoft Teams)

1. Minutes of last meeting

The Committee agreed the minutes without modification.

2. Discussion of lines of questioning

The Committee discussed lines of questioning.

(Public, via Zoom)

3. Hearing with the Local Government Boundary Commission for England

The Committee questioned Professor Colin Mellors OBE, Chair, Jolyon Jackson CBE, Chief Executive, and Lynn Ingram, Director of Finance and Resources, Local Government Boundary Commission, about the Commission’s Main Supply Estimate for the 2021–22 financial year.

4. Hearing with the Electoral Commission

The Committee questioned Rob Vincent CBE, Acting Chair, Bob Posner, Chief Executive, and Kieran Rix, Director of Finance and Resources, Electoral Commission, about the Commission’s Main Supply Estimate for the 2021–22 financial year.

(Private, via Microsoft Teams)

Mr Speaker, Michael Gove, Craig Mackinlay, Christian Matheson, Owen Thompson and Cat Smith were present for the following two items.

5. Local Government Boundary Commission for England: Main Estimate 2021–22

The Committee examined the Estimate having regard to the latest report from the Comptroller and Auditor General. It observed that the Chief Secretary to the Treasury had noted the Estimate without comment.

The Committee agreed to lay the Estimate before the House. All Members present assented to this decision.

6. Electoral Commission: Main Estimate 2021–22

The Committee noted the statement of funding intentions provided by the Electoral Commission, setting out how it was intended the Commission’s funding would be apportioned between the Welsh and Scottish Parliaments and its Main Estimate.

The Committee examined the Estimate having regard to the latest report from the Comptroller and Auditor General. It observed that the Chief Secretary to the Treasury had noted the Estimate without comment.

The Committee agreed to lay the Estimate before the House. All Members present assented to this decision.

[The Committee adjourned


Footnotes

1 PPERA s1(3) as amended by s6 of the Political Parties and Elections Act 2009

2 PPERA s3(4)

3 PPERA s3A(2)

4 PPERA s3(4) and s3(4A)