Annual canvass reform proposals: consultation paper

Section 2 - The current annual canvass

2.1 The current process

Electoral Registration Officers ( EROs) are required to conduct an annual canvass of all residential properties in the area for which they have responsibility. There are 358 EROs in Great Britain: 319 in England, 22 in Wales and 15 in Scotland. In England and Wales, EROs sit at the Local Authority level. In Scotland, the majority of EROs are also Lands Valuation Assessors and employed by Local Authorities or where valuation areas are combined by a Valuation Joint Board ( VJB).

In 2014, Individual Electoral Registration ( IER) was introduced in Great Britain to replace the household registration system, where one person in every household was responsible for registering everyone who lived at that address. Under IER, each person in a household is required to apply individually to be registered to vote. They must also provide 'identifying information', such as their date of birth and national insurance number, which is used to verify their identity, as part of their application to register to vote.

Under Section 9A of the Representation of the People Act 1983 (RPA 1983) an ERO has a duty to maintain the electoral register for their area. Section 9D of the RPA 1983 requires an ERO to conduct an annual canvass of all residential properties in their area, usually between July and December each year, in order to identify everyone who should be on the electoral register. This means identifying citizens who should be registered but are currently not, as well as identifying electors who are no longer at a property and should therefore be removed from the register. A revised version of the electoral register must be published each year by 1 December ^[1] , following the conclusion of the annual canvass.

EROs must send every household an annual canvass form, also known as a Household Enquiry Form ( HEF). The HEF requires a response, regardless of whether there have been any changes in the household to report. Failure to respond is an offence. EROs must follow up any non-responses with up to two reminders and carry out a household visit if required. The household visit can be conducted at any stage; any of the initial, first reminder and second reminder HEF steps can be combined with the household visit or it can be conducted as a separate process. Each HEF must be issued in paper form and be accompanied by a postage paid return envelope.

The current canvass gathers information on potential additions, changes and deletions to the register. However, since the introduction of IER in 2014, further action is required to convert this information into actual changes on the electoral registers. The annual canvass is therefore no longer a registration process in itself. EROs must individually invite potential new electors to apply to register, and verify their identity, before they can be added to the register. This process sits separately to the annual canvass but can, and generally does occur concurrently.

2.2 Issues with the current canvass model

The current annual canvass model has numerous issues:

Highly prescriptive and paper based

As described above, the current canvass process is highly prescribed in legislation, allowing EROs little scope to innovate or adapt their canvass process to best fit the needs of their local residents. Whilst this means that all properties across the UK receive the same process, it does not take into account that different property types and individuals may require a more tailored approach. It does not allow EROs to explore more efficient ways of canvassing or introduce modern technology into the process. The success of the digital service and online registration shows that there is clear public acceptance of moving to more a digital approach which is largely prohibited by the current process.

Every property must respond whether or not they have change to report

One of the key issues identified with the current canvass is that a resident from every property must respond, whether or not there is a change to report. The large majority of households, some 88% across England and Wales, ^[2] and the position is similar in Scotland, remain stable from one year to the next; this means that these residents must respond simply to report that nothing has changed in the composition of their household. Many EROs have expressed frustration at this requirement. They argue that they should be able to target their canvass resources at properties where there is likely to have been a change of composition to report. This would also create a more sensible process for citizens.

Electoral Registration Officers now required to undertake a more resource intensive process

Prior to 2014, the annual canvass process registered citizens to vote as well as allowing the ERO to make amendments to existing entries and delete out of date entries directly from information provided on the canvass form. The accuracy of the electoral registers, and the security against potential fraudulent applications within the process, has benefitted from the introduction of IER. However, it has created a more resource intensive process to be completed by the ERO in their duty to maintain a complete and accurate register. The annual canvass is now an information gathering exercise only, with the ERO completing additional actions and processes for each change recorded on a HEF. For example, if someone new is added to the HEF, the ERO must now issue them an Invitation to Register ( ITR) and follow the prescribed chasing cycle. The additional registration costs - which come on top of the existing cost of the annual canvass (now estimated at £52m per annum across Great Britain) - have been covered by funding from the UK Government. In 2017-18, the net additional funding was approximately £18.5m across Great Britain.

Citizen confusion caused by a ‘two stage’ process

Feedback from EROs indicates there is continued confusion from citizens about the new ‘two-stage’ process. Some citizens believe that by completing and returning the HEF they are registering to vote (as was the case under the old household system), leading them to ignore the subsequent Invitation to Register ( ITR) and failing to register. Others, instead of completing and returning the HEF, are going online and registering to vote again. As there has been no reply to the HEF the ERO is obliged to continue the chasing cycle on the HEF, causing confusion for the citizen. Comments left on the online register to vote service demonstrate this confusion:

‘I'm confused as I thought I'd registered to vote already and not sure why there is a difference in the household enquiry and register to vote forms as they ask the same information (eg, I'd already said that I wanted a postal vote on the previous form but had to do it again today)’

‘I have completed a household enquiry form online which then took me to the Gov. UK register to vote page, where I re-submitted the same information but could not add information for other family members. This is not "joined-up" or "streamlined" government.’

‘A lot of people who fill in the Annual Canvass form will assume that they are then registered to vote when in fact they are not and will be disenfranchised as a result..’

This confusion leads to a multitude of issues, the first and foremost is a negative impact on citizens’ experience of electoral registration which could, in turn, impact their view on engaging with democracy. It also increases the cost of the annual canvass and registration with citizens failing to complete the legislated process, leading to costly reminders.

Changing nature of how citizens engage with registering to vote

Online registration was made available in Great Britain in 2014. It is quick and easy and fits with the way citizens increasingly live their lives. Online registration has been overwhelmingly successful, with over 25 million online applications to date. This has had an unexpected consequence: citizens are increasingly opting to register outside the canvass period. For example, in 2016 there were twice as many additions to the register outside the canvass period than during the canvass ^[3] , signalling that the canvass itself is becoming less important in registering eligible electors. Online registration has also generated more election-focused registration applications, with significant peaks in the lead up to the registration deadlines for elections. For example just under 2 million ^[4] applications were submitted in the two weeks leading up to the registration deadline for the UK Parliamentary Election in 2017. The canvass is now only one of numerous ways that the ERO is able to update their electoral registers.

To attempt to address these issues with the current canvass process, the Cabinet Office piloted schemes over the 2016 and 2017 canvass. Four models were designed by Electoral Administrators and piloted across 24 Local Authority areas in England, Scotland and Wales. Both the Cabinet Office and the Electoral Commission produced evaluations of the pilots ^[5] . A summary of the Cabinet Office evaluation can be found in Annex 2. These pilots have informed the proposed model for the annual canvass going forward.