Response to the Levelling Up, Housing and Communities Committee inquiry into electoral registration

Posted on the 8th March 2023

The Electoral Reform Society is the UK’s leading voice for democratic reform. We work with everyone – from political parties, civil society groups and academics to our own members and supporters and the wider public – to campaign for a better democracy in the UK.

Our vision is of a democracy fit for the 21st century, where every voice is heard, every vote is valued equally, and every citizen is empowered to take part. We make the case for lasting political reforms, we seek to embed democracy into the heart of public debate, and we foster the democratic spaces which encourage active citizenship.

What are the advantages and disadvantages of the existing system of electoral registration?

The Society welcomes the introduction of online registration and the annual canvass reforms to help improve the accuracy and completeness of the register. However, there remain problems with the completeness of the register with some voters less likely to be registered than others. The system also creates pressures on local authorities around election time which could be alleviated by modernising the process. There are various mechanisms which could be introduced which would support increasing registrations, and the accuracy and completeness of the register.

  • Motor-voter registration

Provides voters the opportunity to register to vote at often frequented services, for example:  their county or government registration office, motor vehicle agency, schools and hospitals.

  • Automatic-voter registration (AVR)

Voters are entered into the electoral register when they are eligible to vote. This can either be when they reach voting age, or when they are eligible to vote e.g., migrants who are legal residents of the UK.

  • Election day registration

Allows the qualified resident to both register and cast their ballot on polling day.

  • Centralised national register

Electoral registers are held by local government bodies, a centralised national register would streamline the collection of data in one database enabling other election modernisations.

How does the system of Individual Electoral Registration compare to an automatic or assisted system of voter registration?

The ERS supports the introduction of automatic or more automated voter registration. AVR would increase completeness and accuracy of the register and ensure that under-registered groups are on the electoral rolls. Under IER, electors sign up online and are verified against DWP records – each application is determined locally. There is no direct link between the online registration service and electoral registers so it’s not possible to automatically detect duplicate applications. There are an estimated 8.3 to 9.4 million eligible voters not correctly registered and between 4.7 and 5.6 million inaccurate registrations.[1] This equates to around 1 in 10 of current entries being inaccurate[2]. Other issues with IER are discussed below, including time pressures on Electoral Registration Officers (EROs) in the run up to the election, and the individual responsibility of the voter to register entrenching existing barriers to registration e.g. age, social class, ethnicity and disability.

In 2019, the Electoral Commission[3] released feasibility studies on automatic/automated voter registration, which showed that moves to automatic or more automated registration ‘are feasible from a technical and operational perspective and could be implemented without radically altering the structure of the electoral registration system in the UK’.

Automatic or more automated registration combined with other modernisations such as a centralised database and a look up facility, could improve accuracy and completeness of the registers and reduce the pressures on EROs.

Currently individuals opt-in to the register, to remove concerns around lack of citizen consent an opt-out option could be introduced.

Which countries have high levels of electoral registration, and what lessons can the UK learn from these electoral registration systems?

Sweden

Sweden[4] uses an automatic voter registration model. All persons who qualify to be included on the Swedish Tax Agency’s Population Register 30 days before the election day are automatically registered and mailed a polling card. In 2022[5], the voting age population of Sweden was 8.1 million, over 7.75 million people were registered to vote, and turnout was 84%.

Australia

Australia has compulsory voting for all eligible voters over the age of 18. Voters must register on the electoral roll within 8 weeks of becoming eligible and must update the electoral roll with any change of details e.g. address within 8 weeks of the change; a fine can be issued if this is not done. Canvasses also take place in Australia and various states have implemented systems of direct enrolment and direct update via “administrative data from other agencies [which] are used to add individuals to the roll and update their details”[6]. In 2022, the voting age population of Australia was 20.3 million, voter registration was over 17.2 million and the turnout was 89.74%[7].

United States of America

Same-day registration and motor-voter registration have seen a significant increase in the numbers of voter registrations. Between 1995-1996, Federal Election Commission[8] (FEC) found ‘motor-voter’ registration had succeeded in registering 13,722,000 voters, 33.1% of the total number of registration applications in the US.

In 2012[9], turnout rates in states with same-day registration were, on average, 9 percentage points higher than states without same-day registration (67% vs 58%). Overall, 1.5 million voters used same-day registration in 2012.

16 states and the District of Columbia have approved AVR and more states are expected to pass similar provisions[10].  Since implemented in 2016, Oregon has seen registration rates quadruple at DMV offices. In the first six months after AVR was implemented in Vermont in 2017, registration rates jumped 62 percent when compared to the first half of 2016.

How can existing public data and digital methods be better utilised to create a more joined-up electoral registration system?

The ERS believes that an effective way to utilise public data and digital methods is to introduce AVR and move to a centralised national register to streamline the availability of data. AVR would ensure that the register was more accurate and complete and facilitate a range of other election day modernisations. A UK wide electoral register would improve the fragmented individual local authority register approach.

Another option would be to give EROs access to reliable information from other public sources , such as DVLA, HMRC, HM Passport Office, DWP, Department of Education, and to maintain accurate and complete electoral registers.  They could access recent transactional data to identify potentially eligible electors and invite them to register or use data sources to target specific groups of under-registered electors. The Individual Electoral Registration Digital Service (IERDS) could be developed to act as a conduit for data from new data sources and pass this on to EROs.

What issues exist regarding cyber security, data and privacy, and how can these concerns be addressed?

ERS advocates for the removal of the open register. The sale of the open electoral register should be curtailed due to potential for misuse and privacy infringements. The data of people who are registered to vote should not be for commercial sale or turn a profit. To reduce the risk of data misuse the ERS supports the move to AVR with a closed register. The combination of AVR and an open register would increase opportunities for fraud and the undermining of privacy due to the possibility of data linkages between Personally Identifiable Information held on the systems (PII). Removing of the open register and moving to AVR with a closed register would mitigate these dangers.

Issues surrounding micro-targeting and misinformation campaigns have been highlighted under the current system[11]. If the open register remains, the introduction of safeguards to prohibit misuse of data should be considered.

What issues do electoral registration officers face in relation to electoral data, including access to and sharing of data?

EROs store a live electronic database of current registered citizens on their local Electoral Management Software (EMS).  It is estimated that there are 9 million unregistered citizens, work needs to be done to improve the completeness of the electoral register. There is also an issue with the number of duplicate registrations in the lead up to elections, ranging from 30-70% in 2017[12]. To facilitate the completeness, reduce duplicate applications and improve the security of the register, the register could be merged to a single national electoral register which is closed, this would improve usability and security of the dataset and allow access to the data for those with legitimate public interest.

In principle, ERS support data-sharing agreements where they assist with the accuracy and completeness of the register. Only data directly relevant to electoral registration should be covered under any sharing agreement. A principle of agreement of which body/authority is the data controller and/or processor must be established and be applicable across all data sharing agreements to ensure transparency and compliance with UK GDPR principles. Any persons who are included in the electoral roll are entitled to clear and accessible information on how their data is stored, processed and accessed.

What are the challenges presented by event-led registration, and what additional burdens does this place on local authorities?

In 2019, after the General Election was called more than 3 million people registered to vote (29th Oct 2019 – 26th Nov 2019), in the same period before the 2017 General Election the figure was just over 2.3 million[13]. This increased pressure on EROs who were dealing with upwards of 100,000 registration applications per day in 2019 in the run up to the election. To counteract this, more opportunities for registration should be available throughout the year and ‘look up’ tool should be implemented where voters can check whether they’re registered and if their details are correct (this may require a centralised database but could also be done at a local or national level rather than UK wide)[14].

Examples of opportunities for voter registration include the National Voter Registration Act (NVRA) (1993) in the US. The Act provides voters the opportunity to register to vote at their county or government registration office, motor vehicle agency, at universities, schools, and hospitals. This process is often called ‘motor-voter’ registration. In the first election post-enactment of the NVRA, the Federal Election Commission[15] (FEC) found the ‘motor-voter’ registration had registered 13,722,000 voters, 33.1% of the total number of registration applications in the US between 1995-1996. The FEC noted that “States generally have had few problems implementing the NVRA’s motor voter provisions” believing this was due to training of officials. The UK could consider creating more opportunities for voters to register in day-to-day interactions with government.

Same-day registration is available in many states in the US with positive results. In 2012, average turnout rates in states with same-day registration were 9 percentage points higher than states without same-day registration (67% vs 58%). Overall, 1.5 million voters used same-day registration in 2012.  Demos[16] noted that same-day registration:

  1. Increases voter turnout.
  2. Eliminates arbitrary deadlines that curtail registration.
  3. Assists geographically mobile, lower-income citizens, young voters and voters of colour.
  4. Remedies inaccurate voter rolls.

Demos[17] also notes that states with same-day registration:

  • Have fewer provisional ballots.
  • Experience insignificant increases in costs or administrative difficulty.
  • Have the benefit of enhanced citizen participation in democratic processes.
  • Report very few problems with fraud.

How have the changes introduced by the Elections Act 2022 impacted on electoral registration officers? For example, has this introduced additional administrative burdens on EROs specifically, or local authorities more generally?

It is anticipated that with the introduction of the Elections Act 2022 that EROs will have an increased workload due to the production of Voter Authority Certificates for electors who do not have an accepted form of voter ID and Anonymous Elector’s Documents. The AEA[18] and the LGA[19] have noted that the Elections Act 2022, in particular the new voter ID requirements, will have a number of implications for Councils, including; a necessary review of polling stations, sourcing new polling venues, reviewing existing IT systems and ensuring readiness of the systems, facilitating training of staff, and creating and distributing localised awareness campaigns for the new voter ID requirements.

How best can Government support local authorities to alleviate additional burdens and improve accuracy and completeness of their registers?

EROs should be given access to reliable and trusted information from other public data sources to maintain accurate and complete electoral registers.  Sources of data might include: DVLA, HMRC, HM Passport Office, DWP, Department of Education and similar. EROs could access data to identify potentially eligible electors or use data sources to target specific groups of under-registered electors. The Individual Electoral Registration Digital Service (IERDS) could be developed to act as a conduit to receive recent transactional data from new data sources and pass this on to EROs.

This already happens in Australia, where the Federal Direct Enrolment and Update process enrols or updates citizens’ details on the electoral roll using information provided by the Electoral Commission from other agencies.

Have the Government’s recent reforms done enough to improve the annual canvass process, or are further changes required?

The ERS welcomes the introduction of IER and changes in the annual canvass, however these have not gone far enough.  The Electoral Commission[20] noted issues with the 2020 reforms, including;

  • Households being allocated the ‘wrong route’ due to the data matching process and/or the lag between matching and canvassing. Nearly a fifth of responses from Route 1 households reported updates to elector details.
  • Updates to electors’ details may not be reflected on the registers – 2.4 million households, one third of those allocated to Route 2, did not respond to the canvass.
  • A decline in the registration of attainers likely due to the reduced communication with route 1 households. The number of registered attainers dropped by 28.7% relative to 2020.

To ensure the accuracy and completeness of the register are continuously improved further modernisations such as automatic or more automated registration should be implemented alongside a single national electoral register.

What are the barriers to eligible electors registering to vote?

IER puts the onus on the individual to register to vote, it is well documented that some groups are less likely to register to vote than others depending on age, ethnicity, social grade, and disability. Uberoi and Johnstone[21] undertook research for the House of Commons on Political disengagement in the UK, they found:

Age: Young people are less likely to be registered to vote than older people. This in part may be due to young people moving house frequently. The Electoral Commission[22] also found that “lower levels of engagement with politics and voting are also relevant factors”.

Ethnicity: Non-registration is higher among minority ethnic groups[23], 25% of first-generation migrants and 20% for second-generation migrants are not on the electoral roll; in comparison 10% of the White population are not registered to vote. Reasons for this include: false assumptions that they are not allowed to vote, insufficient proficiency in English and more general barriers to voting e.g. age, housing.

Social grade: People with lower DE grades are less likely to be on the electoral roll than those in higher DE grade. Housing tenure is strongly related to this barrier, the longer the tenure at the address the more likely a person is to be on the electoral roll therefore homeowners are more likely to be on the electoral roll than private renters. People with lower DE grades re less likely to be homeowners than those with higher DE grades.

Disability: According to the Electoral Commission[24] research, as of December 2018, people with a physical disability were more likely to be registered (92%) than those without a disability (82%) or those with a mental disability (83%). It is suggested that this is due to those with physical disabilities moving home less frequently than the general population, mobility is one of the key drivers of low registration.

Mencap research[25] found that 60% of people with learning disabilities who didn’t vote said it was because registering to vote was too difficult, however 70% would like to vote in the next election. The survey cites the experience of a voter who describes the registration process noting that the voter registration form was complicated, unclear, had too many boxes, used complex language and did not have enough room for them to write all their information which led to them feeling excluded.

Why are there so many inaccurate entries and duplications on the register? How can they be rectified in a cost-effective manner?

Under IER, electors sign up online and provide some information (date of birth, NI number), which is verified against DWP records. There is no direct link between the online registration service and electoral registers, so it’s not possible to automatically detect and prevent duplicate applications.

Inaccuracies and duplications in the electoral register happen as citizens are not able to check whether they are registered and/or if their details are correct. If the annual canvass misses them any discrepancies at the address are included in the register. To reduce the number of inaccuracies and duplicates, an online database could be introduced where people can check whether they are registered.

This would be helpful for electoral officials who are under pressure at election time with the volume of applications. The practical implementation is harder in the absence of a national, centralised register but a look-up tool can still be implemented without one.

According to the Electoral Commission, a look-up tool could be either voter-focused or ERO-focused:

  • Voter-focused: either at the local authority or centralised/national/UK-wide, where voters can look up if they’re already registered.
  • ERO-focused: This could be: 1. Completely decentralised (single, local register); 2. Separate registers, but other EROs can look up entries on all 372 registers; 3. Four national registers; 4. Single, UK wide register. In all options, a unique identifier for each elector would be required.

Look-up tools are already used in Australia and Ireland.

How can resources be better targeted to ensure better engagement and accessibility for certain demographics?

Academics[26] have highlighted that publishing data on a voter registration dashboard at ward level would be beneficial for campaigners working to increase voter registration. It would allow campaigners to target their efforts in under-represented areas.

 

Response by Thea Ridley-Castle,
Research and Policy Officer for the Electoral Reform Society.

Email: thea.ridley-castle@electoral-reform.org.uk

Available on Levelling Up, Housing and Communities (LUHC) Committee site.

 

References

[1] https://www.electoralcommission.org.uk/who-we-are-and-what-we-do/our-views-and-research/our-research/accuracy-and-completeness-electoral-registers/2019-report-accuracy-and-completeness-2018-electoral-registers-great-britain

[2] https://www.electoralcommission.org.uk/registering-missing-millions

[3] https://www.electoralcommission.org.uk/who-we-are-and-what-we-do/changing-electoral-law/a-modern-electoral-register/modernising-electoral-registration-feasibility-studies

[4] https://www.norden.org/en/info-norden/right-vote-sweden

[5] https://www.idea.int/data-tools/country-view/261/40

[6] Australian Electoral Commission, Direct Enrolment and Direct Update: The Australian Experience. 2012. Available at: https://www.aec.gov.au/About_AEC/research/files/direct.rtf

[7] https://www.idea.int/data-tools/country-view/54/40

[8]  https://www.eac.gov/sites/default/files/document_library/files/The_Impact_of_the_National_Voter_Registration_Act_on_Federal_Elections_1995-1996.pdf

[9] https://www.demos.org/research/what-same-day-registration-where-it-available#footnote1_sg60fgk

[10] https://www.brennancenter.org/our-work/research-reports/automatic-voter-registration-summary

[11] Toby. S. James and Paul Bernal (2023) The UK Electoral Data Democratic Deficit: A vision for digital modernisation, Joseph Rowntree Reform Trust: York.

[12] https://www.electoralcommission.org.uk/who-we-are-and-what-we-do/changing-electoral-law/a-modern-electoral-register/modernising-electoral-registration-feasibility-studies/electoral-registration-need-reform

[13] https://www.theguardian.com/politics/2019/nov/26/voter-registration-rise-boosts-labours-election-hopes

[14] https://www.electoralcommission.org.uk/who-we-are-and-what-we-do/changing-electoral-law/a-modern-electoral-register/modernising-electoral-registration-feasibility-studies/better-detection-and-management-duplicate-registration-applications

[15] https://www.eac.gov/sites/default/files/document_library/files/The_Impact_of_the_National_Voter_Registration_Act_on_Federal_Elections_1995-1996.pdf

[16] https://www.demos.org/research/what-same-day-registration-where-it-available#footnote1_sg60fgk

[17] https://www.demos.org/sites/default/files/publications/EDR_factsheet.pdf

[18] https://www.aea-elections.co.uk/wp-content/uploads/2022/09/AEA-letter-to-Andrew-Stephenson-MP-29-09-2022.pdf

[19] https://www.local.gov.uk/about/news/lga-statement-parliamentary-vote-plans-introduce-voter-id

[20] https://www.electoralcommission.org.uk/who-we-are-and-what-we-do/our-views-and-research/our-research/electoral-registration-great-britain-2021#effectiveness-of-the-reformed-canvass

[21] Uberoi and Johnstone, “Political disengagement in the UK: Who is disengaged?,” House of Commons Library, 2022. Available at: https://researchbriefings.files.parliament.uk/documents/CBP-7501/CBP-7501.pdf

[22] Electoral Commission, The December 2015 electoral registers in Great Britain, July 2016, p. 45-47

[23] Equality and Human Rights Commission, Is Britain Fairer? The state of equality and human rights 2015, October 2015; Anthony Heath, Stephen Fisher, Gemma Rosenblatt, David Sanders and Maria Sobolewska, The political integration of ethnic minorities in Britain, Oxford University Press, 2013, p. 179

[24] The Electoral Commission, 2019 Report: Accuracy and completeness of the 2018 electoral registers in Great Britain, October 2019

[25] Mencap, ‘People with a learning disability’s passion for politics thwarted by system of excludes them,’ 8 October 2014. Available at: https://www.mencap.org.uk/press-release/people-learning-disabilitys-passion-politics-thwarted-system-excludes-them

[26] Toby. S. James and Paul Bernal (2023) The UK Electoral Data Democratic Deficit: A vision for digital modernisation, Joseph Rowntree Reform Trust: York.

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