Guidance

Elections Act New Burdens funding methodology: voter identification and accessibility

Updated 8 December 2023

A. Introduction

1. The Elections Act will introduce a suite of measures to improve the integrity of the electoral system, and this will include policies such as requiring photographic identification at polling stations and improvements to accessibility for disabled voters.

2. The introduction of these policies will place an additional burden on local authorities (LAs) when delivering elections and electoral registration activities, and this is known as a New Burden. A New Burden is defined as ‘any policy or initiative which increases the cost of providing local authority services.’ The New Burden doctrine states that the leading department must ensure that the net cost of all additional new burdens placed on LAs is fully assessed and properly funded.

3. This paper sets out the modelling approach undertaken to allocate funding to LAs to support the delivery of elections and electoral registration activities.

B. Background

4. Engagement with the sector has been crucial over the last several years in shaping and developing the analysis on the Elections Act, particularly on Voter Identification where the largest costs will be. The chart below illustrates the engagement that the department (previously Cabinet Office) has had with the sector in developing the evidence base on the various policies.

Figure 1: Sector engagement

Figure 1: Sector engagement accessible text version

2018-19

• ​Voter ID Pilots – Three different models (Photo ID, Mixed ID & Poll Card) were tested across ten LAs in the 2018 and 2019 Pilots.​
• We also ran a Cost Survey in the Spring of 2019 to improve our evidence base and this was used in our published Impact Assessment analysis in 2021.​

2020-21​

• Overseas Electors Survey​
  • Survey launched in September 2020 to understand impact of Overseas Electors place on EROs. This survey received 196 responses.​
  • Questions assessed the time taken to process registration activities such as attestations and register checks.​

2022​

• Jan-Feb: Sought views from Expert Panel on modelling assumptions​
• Feb-March: Ran an ERO survey with 205 responses ​
• April-May: Gap Analysis for New Burdens Modelling​
• August: Tested funding mechanism with some Expert Panel members​
• September: Presented the funding strategy to all LAs at the AEA seminar​

5. The evidence gathered above has fed into the funding model, which is primarily broken down into two stages:

a. National cost estimates – The first stage of the analysis builds a nationwide cost model to estimate the impacts of the relevant policy at a national level. This is based on understanding the journey of the policy, and the associated impacts. The relevant impacts are evidenced through various data and research collated over the past few years, such as pilot studies, survey data and desk-based research. More recently, we have received commercial supplier estimates on equipment costs.

b. Local funding allocation - Once the national cost estimates have been calculated, these costs are allocated by a range of factors to ensure that they are distributed to LAs in a fair and transparent manner. Further information on this has been included in Section D.

6. The new burdens funding strategy considers all aspects of how the new burdens costs will be met including an evaluation of funding mechanisms against evaluation criteria and risks, when payments should be made, how they should be made, and to whom, taking account of the divergence in policy and delivery across the UK. Three funding approaches have been considered: up-front grants, retrospective funding via a justification led bid (JLB) and a combination of these approaches (hybrid). Further information on the mechanisms have been included in section D.

C. National cost estimates

7. All unit cost estimates outlined in this paper are for financial year 2022-23 only. They are subject to change for future years, depending on inflation and other supply-side factors.

8. Analysis to identify the cost of Voter Identification uses a mixture of government data, survey-based evidence, desk-based research, and equipment cost estimates provided by several commercial suppliers. It uses local electoral registration data from the Office for National Statistics (ONS) for 2021 for England, Wales, and Scotland, to estimate the total number of registered electors in Great Britain. It then applies ONS population projections to estimate the yearly change in the electorate over the forecast period. The relevant cost components are then applied to these forecasts to estimate the total impact.

9. Costs are scaled according to the percentage of the electorate voting each year, which depends on the number of LAs that hold elections within a given year. The number of LAs holding elections each year is calculated by using the GOV.UK election timetable from March 2022 . Where the election timetables have changed more recently for LAs, funding will be adjusted retrospectively to account for this. The electorate for each LA is based on ONS registration data. By-election costs are also covered by the analysis and are explained in Section C.4.

C.1.2 Impacts

10. There are eight cost lines for Voter Identification that will be funded. These are presented in Table 1 below, alongside their funding mechanism and timing. Further information on the split between returning officer (RO) and electoral registration officer (ERO) costs is explained in Section D.

Table 1. Voter identification costs

Cost lines	Funding timing
ERO costs
ERO admin staff time (Voter Authority Certificate)	Hybrid: Grants in November 2022 and April 2023, JLB in Autumn 2023*
Equipment (Cameras and printers)	JLB: Autumn 2023
Equipment storage	JLB: Autumn 2023
Training (electoral service teams)	Grant: November 2022
RO costs
Equipment (mirror + privacy screens)	JLB: Autumn 2023
Poll station staff	Grant: April 2023
Poll station staff training	Grant: April 2023
Poll cards	Grant: April 2023

*The JLB in Autumn 2023 relates to the deadline for when LAs will be able to submit their application for additional funding

Voter Authority Certificate (ERO staff admin time)

11. The Voter Authority Certificate has two components: processing of Voter Authority Certificate applications by EROs and the manufacturing of the Voter Authority Certificate by a 3rd party supplier. LAs will receive funding for the former but not the latter as the print and despatch contract is held and funded centrally by DLUHC.

12. The modelling uses 2022 survey-based data on the time it takes to process aspects of the application and considers each stage of processing that is required. This is the time for identification and registration checks, time for registration exceptions, time for identification exceptions and identification attestations. The time is calculated for online and paper applications and weighted by the percentage of online applications versus paper applications. Then this time is weighted by the percentage of applications required to go through each stage. On average, EROs are expected to spend 6 minutes processing each Voter Authority Certificate application. This is estimated to cost approximately £1.90.

Equipment

13. EROs will have funding to purchase a digital camera to enable them to take a photo of the elector for their Voter Authority Certificate, if necessary. This is estimated to cost around £120 from desk-based research.

14. Some EROs will also have funding for a printer and scanner. In exceptional circumstances, such as the loss of an elector’s Voter Authority Certificate in the post, the ERO can use this item to print off a temporary Voter Authority Certificate, ensuring the elector can vote. The unit cost of a printer and scanner is estimated at £130 from desk-based research.

15. On polling day, poll clerks and presiding officers will be responsible for checking electors’ photographic identification. Sensitivity will be expected for those with religious headwear. To facilitate identification checks, polling stations may purchase a privacy screen if they lack a private room or area for the identification check. Funding for a mirror is also provided for all polling stations to facilitate the readjustment of headwear. These equipment costs are based on a range of estimates provided by several commercial suppliers. The cost of the privacy screen is estimated to be £41 per unit and the cost of the mirror is estimated to be around £4 per unit.

Equipment storage

16. LAs can obtain funding for storage space to store the equipment. Feedback from the sector earlier this year highlighted concerns around how this equipment is expected to be stored, noting that some LAs could in principle have up to 100 privacy screens to store.

17. Funding for 75 square foot of storage space is provided for up to two thirds of LAs, on the basis that not all LAs will need this storage (i.e., some LAs may already have sufficient storage space). Costs are based on an industry report’s UK average11 and storage will be offered for ten years, with a unit cost of £27 per square foot. Funding will be provided to EROs via new burdens JLB. Additional storage funding will therefore not be provided to ROs as part of UKPGE or PCC elections.

Polling station staff

18. The introduction of mandatory photographic identification in polling stations requires extra staffing resource. During the pilot studies, some LAs raised the need for additional poll clerks to help administer the additional identification checks on polling day, though the number of additional poll clerks hired varied between LAs.

19. In the rollout year of the policy (financial year 23/24) and every year when a general election is expected, all polling stations will have funding for an extra poll clerk. This is intended to facilitate photographic identification checks. Poll clerks work for approximately 16 hours on polling day and the rate of pay has been calculated based on rates previously paid to ROs for this role and uplifted to reflect public sector wage growth. The number of polling stations is based on the 2019 General Election but will be updated each year to reflect new estimates.

Poll cards

20. Currently, poll cards are generally A5 in size and not posted in an envelope. Under the new proposals, poll cards will be re-designed to include information on the requirement for Voter Identification in polling stations and what types of identification will be accepted. The poll card will be increased from A5 to A4 to account for the additional information and will now likely be posted in envelopes as a result.

21. LAs will be funded for the additional cost of the new poll card specification compared to the previous. The cost of the card, printing, enveloping, and postage is expected to be £0.11 more expensive per poll card. The number of poll cards required varies annually, depending on the percentage of the GB electorate who is eligible to vote.

22. When an LA in England has a combined poll, such as a local and Police and Crime Commissioner (PCC) election, or a local and a mayoral election, electors will receive only one poll card. Consequently, LAs will receive funding for one poll card size change per elector. The modelling assumes that electors will receive a separate poll card for Parliamentary elections. This is because a Parliamentary election could occur at any time and may not co-occur with other polls.

23. In Scotland and Wales, the modelling assumes that a poll card size change is only required for reserved elections, and thus poll cards are not combined even when local or devolved parliament elections fall on the same day as a reserved election. Funding is therefore provided only for size changes in poll cards for reserved polls.

C.2 Accessibility

C.2.1 Methodology

24. ROs are required to take all reasonable steps to support electors with disabilities at polling stations. Analysis to identify the cost of the accessibility measures uses a mixture of government and Electoral Commission data, survey-based evidence, commercial estimates, and policy insight.

C.2.2 Impacts

25. There are five cost lines for accessibility that will be funded. These are presented in Table 2 below, alongside their funding mechanism and timing. Further information on the split between RO and ERO costs will be explained in Section D.

Table 2. Accessibility costs

Cost lines	Funding timing
ERO costs
Training (electoral services teams)	Grant: November 2022
RO costs
Equipment (visual impairment)	Hybrid: Grant in November 2022 and April 2023 and JLB in Autumn 2023
Equipment (general)	Grant: November 2022
Admin costs	Grant: April 2023
Training (poll station staff)	Grant: April 2023

Visual impairment equipment and set up costs

26. To make the voting process more accessible to blind and partially sighted people and support independent voting, an audio player may be provided. It is estimated that 20% of polling stations in the UK will require an accessible audio device, a headset and three USB sticks at a unit cost of £54.99, £14.40, and £3.58, respectively. The setup of the audio device is estimated to require 20 minutes of election staff time to record the ballot paper information and check the accuracy of the recording. Provision for costs incurred when a seat is contested is also included, which would require a re-recording.

27. Some LAs will be able to purchase a USB duplicator to enable the quick duplication of audio files across many different USB sticks to be used in polling stations, with an estimated unit cost of £641.80.

28. Each LA will be able to purchase a subscription to a text to voice software, which will be renewed regardless of election status within the LA, at an estimated unit cost of £3.04.

29. The administrative costs associated with setting up audio equipment have been modelled on a per polling station basis because the extra work will be absorbed into poll clerks working day and it is not significant enough to require additional staff.

General accessibility equipment

30. Other equipment that makes it easier for electors with disabilities to vote independently will be made available at all polling stations. This includes a pack of large pencils, at an estimated cost of £4.77, and a pack of pencil grips, at an estimated cost of £4.75. These will assist people with arthritis and other issues that make them less able to hold a pencil. ‘Here to help’ badges for staff will be provided so that electors, including those with disabilities, know that they can get assistance in the polling station. These are costed at £0.14 each. Magnifiers are intended to assist electors with sight loss at an estimated unit cost to £3.19. A chair is intended to aid electors with mobility issues and has an estimated unit cost of £20.46. These costs are based on the average of estimates provided to us by several commercial suppliers.

Storage, wear, and tear

31. It is assumed that LAs will already have secure space to store this equipment, which is commonly used already in many cases, or will use the storage provision for Voter Identification (see paragraphs 16 and 17), and that the new visual impairment equipment will be transported alongside other polling station equipment at no additional cost.

32. We have not included funding for future replacement equipment due to wear and tear. It is expected that this will be funded via LA budgets and the Consolidated Fund.

C.3 Training and contact centres

33. Training will be required for electoral administrators and polling station staff to deliver the new requirements relating to the Voter Identification and Accessibility policies. Based on feedback from the sector, an additional temporary contact centre staff member per LA will be funded for two months prior to scheduled polls in the first two years of Voter Identification policy roll out. Payment timings for training and contact centres are outlined in Table 3.

Table 3. Training and contact centre costs

Cost lines	22/23
ERO costs
Training for electoral services teams	Grant: November 2022
Contact centre additional staff	JLB: Autumn 2023
RO costs
Training for polling station staff	Grant: April 2023

C.3.1 Training for electoral services teams

34. Electoral administrators will require training on the legislative changes relating to the introduction of the requirement for electors to present photographic identification to vote. They will also require training on how to process Voter Authority Certificate applications within the new ERO portal. Electoral administrators will also be trained on the guidance relating to improving the accessibility of polling stations.

35. The format of the training delivery is at the discretion of the ERO though the funding assumes that in-person training will be provided by external suppliers, based on the assumptions summarised in Table 4.

Table 4. Assumptions underpinning training for electoral administrators

Assumption	Evidence
Duration of training	1 day Estimated within the programme based on the policy requirements
Cost of training course	Estimated on the basis of training provider costs
Number of electoral administrators attending training in each LA	Based on survey responses to a question on size of electoral services team in the 2022 LA survey.
LA electorate	2021 ONS electorate figures

C.3.2 Training for polling station staff

36. Polling station staff will require training prior to polls regarding the accepted forms of photographic identity documents, how to carry out identity checks, and how to set up the polling station to conduct identity checks. They will also require training on how to improve accessibility of polling stations.

37. It is anticipated that this new training requirement is rolled into existing training polling station staff receive ahead of polls, and that the EC will amend their polling station staff training materials to reflect the new requirements. The format of training delivery is at the discretion of ROs. Funding will be provided for an additional 45 minutes of training for polling station staff, delivered face-to-face in groups of 25 staff by one trainer.

38. Full training is also provided for the additional poll clerk per polling station covering both the existing EC training materials and the new training requirement. The assumptions underpinning the training for polling station staff are summarised in Table 5.

Table 5. Assumptions underpinning training for polling station staff

Assumption	Evidence
Duration of new training element	45 minutes Estimated on the basis of policy requirements and duration of existing training provision
Cost of training	Based on elections claims data
Number of poll clerks requiring new training	Based on EC guidance on number of poll clerks per polling station
Number of additional poll clerks requiring existing plus new training	1 per polling station, based on policy decision
Number of presiding officers requiring new training	1 per polling station, based on EC guidance
Number of polling station inspectors requiring new training	1 for every 8 polling stations
Trainer fees	Based on elections claims data
Number of polling station staff attending each training session	25, based on elections claims data
Number of polling stations per constituency	2019 EC data

C.3.3 Additional contact centre staffing

39. Feedback from the sector indicated that electoral administrators were concerned that the volume of queries from electors prior to elections would increase because of the introduction of the new policies. To meet the cost of delivering this support to electors the programme committed to funding for one temporary contact centre staff for the two months prior to polls in LAs that have polls in May 23 and May 24. The assumptions underpinning contact centre staff funding are set out in Table 6.

40. It is not anticipated that all LAs have contact centres, so the cost of addressing queries is anticipated to vary between LAs.

Table 6. Summary of assumptions underpinning contact centre staff funding

Assumption	Evidence
Number of temporary contact centre staff required	1 per LA that have polls in May elections
Hourly rate	Based on cost survey data
Number of additional hours required	2 months FTE, based on feedback from the sector

C.4 By-elections

41. By-elections are, by their nature, unpredictable in both timing and location. However, the running of by-elections that occur after May 2023 will incur costs to LAs associated with the Voter Identification and accessibility policies. As such, new burdens funding for by-elections that occur will be provided to meet any additional costs that have not previously been funded via the JLB process. Costs are estimated based on the predicted number of by-elections multiplied by the cost per elector of each of the policies.

D. Funding strategy

D.1.1 Funding mechanisms

42. Paragraph 6 outlined the different funding mechanisms that were considered for New Burdens Funding. A hybrid approach of up-front grant funding and JLBs has been selected as the best approach for new burdens funding as it will ensure funding is distributed in a consistent and transparent manner, whilst also providing upfront access to funding and minimising the workload on EROs.

43. Cost lines are split into RO and ERO activities. ERO activities relate to registration activities for which the ERO is responsible, for example processing of Voter Authority Certificate applications and electoral services teams training. RO activities include activities for which the RO is responsible and relate to elections activities. Examples of RO activities include equipment required at polling stations. staffing of polling stations and polling station staff training. These have been outlined in Section C.

44. Table 7 summarises the funding mechanism for each cost line.

Table 7: Funding mechanism for each cost line and rationale

Cost line	Funding Mechanism	Rationale
Voter identification
Equipment	Justification-Led Bid	Funding will be provided as a JLB as demand for equipment will vary across LAs as some may already have the relevant equipment.
Equipment storage	Justification-Led Bid	Like equipment, storage needs will vary by LA depending on how much equipment they purchase and what arrangements are already in place
Poll station staff	Grant	Funding will be provided up front as it will apply to all polling stations in LAs with scheduled polls.
Poll card costs	Grant	Funding will be provided up front to LAs with scheduled polls as poll cards are required for all electors and the additional costs of the poll card are set.
Poll station staff training	Grant	Funding will be provided up front to LAs with scheduled polls as training costs are based on indicative rates derived from the costs of previous elections, and the number of polling station staff requiring depends on EC guidance per polling station.
Electoral Service Teams Training	Grant	Funding will be provided up front as staff need to be trained ahead of legislative changes being introduced.
ERO administration time (Voter Authority Certificate processing)	Hybrid	Funding will be provided via a split of up-front grant and JLB as Voter Authority Certificate demand will vary between LAs and some funding is needed ahead of Voter Authority Certificate applications going live.
Accessibility
General accessibility equipment	Grant	Funding will be provided up front to LAs to purchase equipment such as chairs, large pencils, and pencil grips to support the accessibility needs of their electorate. However, they will have the flexibility to purchase the equipment they deem most appropriate.
Staff admin costs	Grant	Funding will be allocated across LAs with scheduled elections via an up-front grant as it is a small cost. This funding is provided to support staff to set up digital equipment.
Electoral Service Teams Training	Grant	The rationale is the same as Voter Identification
Poll station staff training	Grant	The rationale is the same as Voter Identification
Accessibility audio devices (for visual impairment)	Hybrid	Like the Voter Authority Certificate processing above, this will be a hybrid approach as the demand for audio equipment will vary depending on the LA and the accessibility needs of their electorate. All LAs will receive up-front grant funding which varies depending on the number of polling stations in each LA. All LAs will have the option to bid for further funding if required.
Other costs
By-elections	JLB	Funding will be made available via the JLB process as the location and timing of by-elections is currently unknown.
Contact centres	JLB	Funding will be made available via the JLB processes as demand for contact centre staff will vary between LAs.

D.1.2 Funding timing

45. Payment timings follow from the funding approach. Grants will typically be made earlier in the financial year (April), ahead of May elections. JLB payments will be made later in the financial year, giving enough time for LAs to gather evidence of spend and apply for JLBs following May elections. The exception to this is Financial Year 22/23, where the grant will be released in November 2022 so LAs can invest in equipment, training etc ahead of May 23 elections. It should be noted that payment timings and mechanisms may change and are subject to SRO and Ministerial approval.

D.1.3 Funding Sources

46. Reserved elections are funded by the Consolidated Fund. As such, costs resulting from the new policies that are incurred by ROs in relation to reserved polls will be met by funding from the Consolidated Fund and not new burdens funding. Where reserved polls are combined with other polls, the full cost will be split between the Consolidated Fund and new burdens funding, at the ratio of reserved to other polls, in the usual way.

47. Costs incurred by EROs (registration costs) that result from the Elections Act will be funded as new burdens only.

48. The production of the Voter Authority Certificate will be undertaken by a commercial supplier and no new burdens funding will be provided for this.

D.1.4 Divergence across the UK

49. The Voter Identification policy will affect all elections in England and reserved elections (Parliamentary elections and PCC elections) in Scotland and Wales. Photographic identification will not be required for Devolved Parliamentary and local elections in Wales and Scotland. The policy will not be introduced in Northern Ireland as the photographic identification is required to vote there already.

50. The Accessibility policy affects reserved elections across the UK, however, the equipment may also be used in devolved elections at the discretion of the RO.

51. For LAs in Scotland who are members of a Valuation Joint Board (VJB), funding to meet ERO costs will be paid to the VJB while funding to meet RO costs will be paid directly to the LA. LAs that are not members of a VJB will receive both ERO and RO portions of funding.

52. LAs in England and Wales will receive both ERO and RO portions of funding. Two-tier councils in England will receive all new burdens funding at the District Council level (including for County Council elections). Payments will be made by Section 31 grant.

D.2 Funding allocation formula

53. A funding allocation formula takes the national costs and outputs ERO and RO allocations by lower-tier authority. The breakdown of ERO and RO costs facilitates the determination of funding allocations for Scotland and enables estimation of the proportion of funds to be paid by the Consolidated Fund.

54. The funding formula is a series of functions which dictate how the allocations are derived from the total cost at the national level. These functions typically multiply the cost by a fraction. The numerator of this fraction is the value of a variable at LA level. The denominator is usually the sum of variable values across all LAs (GB or UK).

55. The three variables used are typically electorate, number of polling stations or estimated number of electoral administrators. Polling station staff costs scale with the number of polling stations, number of poll cards scales with the number of electors, and the number of electoral administrators requiring training scales with the number of electoral administrators in the LA.

56. It should be noted that all three variables are correlated since the size of the electorate drives the number for polling stations and the demand for electoral services, however, this correlation is not perfect as other factors affect these variables (e.g., population density affects the number of polling stations in each LA), and thus for each cost line the most appropriate variable is used.

57. Some costs are incurred only if the LA has polls (i.e., polling station staff, poll cards, polling station staff training). Poll card costs are modelled as combined in England for locals and PCCs when these polls co-occur. The modelled cost of poll cards for UK Parliamentary elections assumes that these poll cards will not be combined with poll cards for other elections. This approach is taken because Parliamentary elections could be called at any time and therefore may or may not coincide with other scheduled polls. Poll cards are not combined in Wales or Scotland as photographic identification will not be required at devolved parliament or local elections.