With pressure mounting on Boris Johnson, it’s looking increasingly possible that Britain could well soon have a new Prime Minister. Who it would be, would be a decision for Conservative MPs and, possibly, Conservative party members. But this isn’t how things would go in every country. So, let’s take a look at how other countries choose a new Prime Minister.
Parties Choose Their Candidates
First, a political party needs a candidate. In Britain, if there are multiple candidates, both main parties choose their leader by a ballot of their party members, though they both have preliminary rounds where potential candidates are whittled down by MPs. But membership elections elsewhere are fairly rare – Canada being one of the few countries where all major party leaders are selected this way. Though this is changing, with membership elections becoming more and more common.
Across Europe, there is significant variation in how a party leader is chosen – both between countries and between parties within them. But the most common method of selection is some form of election by party delegates. While members may have some input, the final decision often rests with party officials and/or elected representatives. However, this is only the case if a vote is needed. In many European countries, it is the norm for there to only be a single candidate – with consensus being reached by party elites without need for an election.
There is also the German model where the position of Chancellor candidate is distinct from that of the party leader. The position is usually chosen by party delegates in the run-up to a federal election and, while it does normally go to the party leader, it gives parties the opportunity to recognise that different skills are required to govern than to lead a party. This has been the case with current Chancellor Olaf Scholz. He is not the leader of the SPD, rather somebody with a history of governing successfully and popularly at the state and federal level.
Positive vs Negative Parliamentarism
But, in many countries, being elected party leader is just the first step, you can’t automatically become Prime Minister just because your party is in power. Unlike in countries like the United Kingdom that operate a policy of ‘negative parliamentarism’, whereby parliamentary support for the incoming government is often assumed, many European countries opt for ‘positive parliamentarism’.
Under positive parliamentarism, a new potential government needs to explicitly prove that it is supported by parliament before it can be formed. This ‘proof’ takes the form of an investiture vote – whereby MPs vote on either the nomination of one Prime Ministerial candidate or between several. Exact rules vary from country to country, but you can’t form a government without winning it. Positive parliamentarism can be found in Germany, Ireland and Belgium, as well as the devolved parliaments of Scotland and Wales.
In Germany, positive parliamentarism is strengthened by the rule of constructive votes of no confidence. There, governments can only be defeated in a vote of no confidence if there is a majority in support of an alternative government. If parliament cannot find an alternative, the incumbent government remains in place. This system has since been adopted by other countries, including Spain, Italy and Poland.
However, some ‘negative’ countries do also have investiture votes, just with different rules to positive countries. This is the case in Sweden where a majority of all MPs have to vote against a proposed government for it to be defeated. Last November, Social Democrat Magdalena Andersson (who was unanimously chosen as party leader) was elected PM despite more MPs voting against her than for her. However, as only 49.6% of MPs voted ‘No’, and crucially 21.5% abstained, there was not a majority against her election.
Effectively, under positive parliamentarism a government can only be formed if a majority of MPs have explicitly endorsed it, while under negative parliamentarism a government will be formed unless a majority of MPs explicitly reject it.