Electoral boundaries - determination process: consultation analysis

Boundary Commission Structure and Resources

Rules about who should be among the members of Boundaries Scotland or how they are appointed

The consultation paper sought views on whether there should be any changes to the rules about who should be among the members of Boundaries Scotland or how they are appointed. A total of 26 responses were received to this question (18 from individuals, and 8 from organisations).

Overall there was a broadly even split of views, with 11 respondents suggesting there should be changes to the rules, and 9 respondents suggesting there should not. A further 6 respondents provided comments, but not an explicit yes or no to whether there should be rule changes.

Individuals were more likely not to think changes were required, with all 9 of the respondents who answered ‘no’ to this question being individual respondents. Conversely, none of the eight responding organisations thought that no changes were required.

Who should be among the members of Boundaries Scotland

In relation to the composition of Boundaries Scotland, the following views were expressed.

Several respondents made comments in relation to whether commission membership should include people with specific technical and/or public service expertise. One individual suggested: a senior geographer or cartographer (e.g. from Ordnance Survey); a representative from National Records of Scotland for population data and parity expertise; and a senior equality or access advocate to ensure inclusive boundary implications, and for these individuals to be appointed in a statutory advisory capacity, not by ministerial discretion, but via open competition or nomination by arms-length public bodies. A further individual respondent stated “People who understand not just maps but the dynamics of local geography should sit on the commission and have a formal role”.

The EMB commented that the “day-to-day work of the Commission in terms of developing boundaries needs appropriate expertise in mapping, geography, public consultation etc” but did not explicitly call for additional members, noting “It is the experience of the EMB that those working in Boundaries Scotland are currently effective and professional officers who deliver a professional and expert service”. This view was shared by an individual respondent who commented: “Whilst in the Westminster commissions and elsewhere, representatives of other organisations sit on commissions providing specific skills in relation to population statistics and mapping, they take no part in boundary deliberations and are there to facilitate data transfer. I am not aware of any issues in relation to the provision of population and mapping data in Scotland that would warrant the need for these organisations to be represented on Boundaries Scotland. Current arrangements between staff of the different organisations work well at a technical level”.

Boundaries Scotland also commented that “we already engage extensively with communities, stakeholders and external sources of advice to arrive at our collective decision. This diverse engagement is already key to our decision making and [we] do not feel that it would warrant changes to the membership of the Commission in the form of ex officio members”. They further noted that: “Aside from permanent Commission membership, the current rules do allow the Secretary of State to appoint any person having expert knowledge that is likely to be of value to the Commission. Boundaries Scotland considers there should continue to be the option for such appointments to be made on an ‘as needed’ basis, in the form of short term or interim appointments. We welcome the flexibility of this approach which is preferred to having a sitting senior public servant or ex officio member on the Commission”.

There were also suggestions from two individual respondents and both community council respondents for community / local representation on Boundaries Scotland. An individual respondent suggested “Introducing community-based representation (similar to Canada’s “two public members from affected areas”) would help capture the social and practical consequences of boundary changes from a lived-experience perspective”. Another individual respondent stated “A local element must be on offer. The community council structure gives this option validation and a consistent contact point”.

As noted above, Boundaries Scotland commented that they already extensively engage with communities (and others) and that “This diverse engagement is already key to our decision making and [we] do not feel that it would warrant changes to the membership of the Commission in the form of ex officio members”.

Two different views were expressed in relation to whether members of the judiciary should sit on the Commission. One individual respondent suggested that a current or retired senior judge should be included, ideally as Chair or Deputy Chair. They noted that this was the case in Australia, Canada, and New Zealand and would “mirror Scotland’s own model for the Boundary Commission for Scotland (Westminster), which includes a Court of Session judge as Deputy Chair”. Conversely, however, Boundaries Scotland noted that the examples provided of countries where members of the judiciary do sit on Commissions “do not relate to devolved administrations”. They further commented that “Democracy and Boundary Commission Cymru, which is the closest equivalent to Boundaries Scotland, does not have a member of the judiciary sitting on the Commission, nor was one added with the introduction of automaticity”. They noted that “including a sitting member of the judiciary has not guarded against political interference as demonstrated by two historic UK Parliament reviews (Sixth Review and 2018 Review, both cancelled, despite each of the four commissions being headed by a high court judge or equivalent)”.

An individual respondent suggested that “it would be appropriate to bar current members of political parties being a member of Boundaries Scotland”. This view was shared by the EMB and Boundaries Scotland who commented, respectively, that “The members of Boundaries Scotland would need to be able to provide robust governance and oversight of the activities of the Commission and should have no political affiliation” (EMB) and that “the continued neutrality of the Commission could be protected by legislation specifically prohibiting the appointment of Commissioners with a recent history of active political involvement, to safeguard the level of independence already seen in the makeup of the Commission at present” (Boundaries Scotland).

How should members of Boundaries Scotland be appointed

In relation to the appointment process for members of Boundaries Scotland, the following views were expressed.

Five respondents provided comments in relation to the appointment of members of Boundaries Scotland by Ministers.

The EMB suggested that members “need to be independently appointed perhaps by the Crown as is the case with the Scottish Information Commissioner”. Similarly, Aberdeenshire Council commented that “The current appointment process should be reviewed to ensure greater transparency and independence, while also promoting inclusivity and diversity amongst its membership”. The Scottish Liberal Democrats recorded that they “have a slight concern that as all the commissioners are appointed by the Government, they may have regard to the wishes of the Government on some matters”.

Two individual respondents made comments in relation to whether there should be cross-party approval / oversight of appointments, with one suggesting either “Approval by a cross-party parliamentary committee; or nomination by both government and opposition MSPs (as in New Zealand)”. Another individual respondent was more hesitant, commenting: “There may be a case for members of Boundaries Scotland being appointed by the Scottish Parliament rather than Ministers. However, this would need to be looked at in detail in relation to accountability of the chair and members because under the legislation Ministers have the right to (and have done so) to provide Directions to Boundaries Scotland”.

A couple of respondents called for great transparency in the appointments process, with one suggesting: “All appointments should be: open to public application; assessed through transparent, criteria-based scoring; subject to independent review or panel assessment (not solely Ministerial approval); limited to one renewal only to prevent entrenchment”.

Glasgow City Council suggested “consistency across the four nations of the UK is imperative. Aligning appointment processes and standards would support a more coherent and trusted approach to boundary setting across the UK”.

Boundaries Scotland did not call for a change to the process but noted that “A recognition of our independence in the legislation would be welcome”.

Further comments on boundary commission structure or resources

Respondents were asked whether they had any further comments on boundary commission structure or resources, including any other elements of the models used in other countries that they would like to see introduced in Scotland.

A total of 8 respondents (4 individuals and 4 organisations) provided further comments.

Two individual respondents and one organisation (Glasgow City Council) made comments in support of merging or better collaboration with the EMB. One individual respondent noted: “In principle I am supportive of a comprehensive democratic systems body on the model of the Democracy and Boundary Commission Cymru, or several of the Australian state-level electoral commissions. This would allow for resources and expertise to be concentrated on one body rather than dispersed between several, potentially allowing for more efficient operations”. A further individual respondent stated “A unified Scottish Electoral and Boundary Commission could enhance efficiency, data sharing, and long-term strategic planning—while maintaining firewalls between administrative and decision-making functions. If full merger is not desirable, stronger formal cooperation protocols should be introduced between the three bodies”.

Glasgow City Council called for closer collaboration between the Boundary Commission, the Electoral Commission, and the EMB, noting “If these bodies worked together more systematically—particularly during the planning and implementation phases of boundary changes—it would help ensure a more joined-up approach, reduce duplication of effort, and support clearer communication with stakeholders and the public”. They further noted “This model of integrated working could draw on best practices from other countries where electoral oversight bodies operate in a more unified or collaborative framework”.

Boundaries Scotland called for more resources to support “a shift towards a more multilateral, consensus-based approach to boundary setting within Scotland with a higher level of engagement with the public” noting that this would be “consistent with the enhanced budget for the equivalent Commission in Wales”. Aberdeenshire Council also commented that “Adequate resources should be allocated to Boundaries Scotland to ensure they can conduct thorough and timely reviews”.

There were two different views expressed by individual respondents in relation to the sharing of a secretariat with the Boundary Commission for Scotland. One respondent suggested that Boundaries Scotland needed “enhanced and dedicated resourcing” (in line with the comments above) stating that the shared secretariat: “may constrain independent operation, especially during overlapping reviews (e.g. local wards and UK Parliament boundaries)” and suggested “Scotland should establish a dedicated, permanent secretariat for Boundaries Scotland to ensure sufficient analytical, cartographic, legal, and public engagement capacity. The commission should also have access to its own data analysts, digital infrastructure, and communications team to support modern consultation formats”. Conversely, another individual respondent commented that the sharing of the secretariat between the UK commission for Scotland and Boundaries Scotland “works well in providing a critical mass of skilled staff and opportunities for continuity of staff roles between reviews of each commission […] It also allows the balancing of the peaks and troughs in each commissions work without the need to take on temporary staff to deal with peaks and the overhead and inefficiency this would bring in training individuals up for a short period of time”.

The EMB commented that “the recent change in legislation in the Scottish Elections (Representation and Reform) Act 2025 that recommendations for changes to boundaries must be made at least 18 months ahead of the election to which they will apply was welcomed. In addition, the EMB would note that there needs to be recognition of the broader electoral timetable so that changes recognise the pattern of work of electoral administrators for example with respect to UK elections”.

An individual respondent called for an improved approach to data collection and accessibility , noting they “would urge the Scottish Government to give consideration to how localised election data can be collated and published. The central electoral body of many other countries act as the central hub for real-time election result publication not simply at constituency (or ward or region) level, but right down to polling district level. This approach is not generally taken in the UK, despite the advantages to democratic understanding of collecting such data”.

A further individual respondent made additional suggestions, including that: Equality Impact Assessments should be a statutory requirement embedded in the structure and workflow of the Commission; that Boundaries Scotland should create a small team of regional public engagement officers, based in different areas of Scotland (e.g. Highlands & Islands, Central Belt, Borders) [to] facilitate local consultation events, engage with underrepresented communities, and liaise with councils and civic groups” noting “This model has parallels in Australia and Canada, where boundary commissions engage regionally and not solely from central offices”; and, that there should be digital modernisation and an open data mandate (with interactive online boundary maps, publicly accessible boundary review datasets, tools that allow the public to model or comment on proposed changes visually and an open-access digital repository of historic and current boundary data for public and academic use.

Another individual respondent noted that “Boundaries Scotland is thinking of moving to a system of rolling reviews of local authorities rather than undertaking all 32 reviews within a narrow window. Whilst the are advantages of this for example in allowing deeper consultation with the areas of local authorities being reviewed, the publicity generated and ability to encourage people to engage may be diluted”.