Representation of the People Bill — Supplementary written evidence submitted by Liberal Democrats Abroad (RPB47)

Written evidence submitted by Liberal Democrats Abroad to the
Representation of the People Public Bill Committee (RPB47)
Prepared by Liberal Democrats Abroad Representation of the People Working Group on behalf of
Liberal Democrats Abroad.
Contents
Executive Summary ................................ ................................ ................................ ................... 1
Introduction ................................ ................................ ................................ ............................. 2
Summary of suggested amendments to the Bill ................................ ................................ .......... 2
Key issues, facts, and proposed solutions ................................ ................................ ................... 3
Failures in Voting Logistics from Abroad................................ ................................ .............. 3
Exclusion of Overseas Voters from Automatic Voter Registration ................................ ......... 5
Removing Obstacles to Proxy Voting ................................ ................................ ................... 5
Lack of campaigning material sent to overseas voters ................................ .......................... 6
Dedicated representation through overseas constituencies ................................ ................. 6
Conclusion ................................ ................................ ................................ ................................ 8

Executive Summary
● The Representation of the People Bill (2026) as drafted represents a major missed
opportunity to address the systemic disenfranchisement of approximately 3.5 million British
citizens living abroad who are eligible to vote.
● Only 5% of the estimated eligible British voters living abroad (191,338) registered to vote at
the 2024 General Election, compared to the 16% (234,000) who did so at the 2019 General
Election. This compares to France, which saw some 600,000 (37%) of its registered overseas
citizens vote at its 2024 legislative election.
● The decline in registrations was in spite of the Elections Act 2022 extending the right to vote
to an additional 2.1 million British citizens abroad. Given that increase, we could have
expected a proportionate rise in registrations by overseas voters to approximately 590,000.

● The Elections Act 2022 failed to address critical flaws in the system for voting from abroad,
demonstrated by the fact that only 48%1 of postal ballots issued were returned in time to be
counted by citizens abroad at the 2024 General Election.
● Liberal Democrats Abroad asks the Committee to support amendments regarding AVR
inclusion, electronic or blank ballot distribution, embassy voting, education initiatives,
dedicated overseas constituencies, proxy voting improvements, and parity on donation
rules between domestic and overseas voters. This package of measures, taken together,
would increase both turnout and the likelihood of successful participation for overseas
electors.

Introduction
1. Liberal Democrats Abroad (LDA) represents the members and supporters of the Liberal
Democrats who live outside the United Kingdom.
2. This submission outlines the on-going barriers British citizens abroad face when voting, and
offers some solutions. While the Government rightly recognises overseas electors as
legitimate voters, current infrastructure remains outdated compared to international
standards.
3. Our proposals draw on the results of our survey conducted during and immediately after the
2024 General Election, research into other countries’ voting systems, and the Electoral
Commission’s Review of the 2024 General Election.
Summary of suggested amendments to the Bill
4. Modernise Ballot Logistics: Support feasibility studies for electronic and blank ballot
distribution, the use of embassies, and amendment of the electoral timetable.
5. Inclusive AVR: Remove the exclusion of overseas voters from Automatic Voter Registration.
6. Proxy Flexibility: Allow postal voters to switch to a proxy vote, improve information shared
with voters, and clarify party assistance rules.
7. Campaign Material Parity: Study 'Freepost' or electronic communication for candidate
leaflets to overseas voters.
8. Overseas Constituencies: Conduct a feasibility study on Overseas Constituencies.
9. Education Funding: Fund the Electoral Commission for collaborative awareness campaigns.
10. Donation Caps: Implement a universal cap on all political donations to maintain democratic
equivalence for overseas voters.

1 See 2024 United Kingdom Parliamentary General Election administrative data,
ConstituencyData tab, column AX

11. For any consultation periods or implementations, we ask that a timetable is prescribed, so
that another electoral cycle does not commence with these barriers still in place.

Key issues, facts, and proposed solutions
Failures in Voting Logistics from Abroad
12. Postal voting is the preferred or only practical method for nearly half of overseas electors2.
The Electoral Commission has been highlighting anecdotal evidence of problems with the
postal vote system since 2015 although it was only at the 2024 General Election that
quantitative data was published.
13. This data revealed that only 48%3 of the overseas postal ballots issued arrived back in time
to be counted. The democratic wishes of around 45,000 overseas electors – two-thirds of a
constituency – were ignored.
14. Notably, the Electoral Commission reported that this was not just a problem for the largest
contingent of British citizens living abroad in Australia, where only 6% of ballots were
returned in time, but also for parts of Europe, showing that distance was not the only factor.
15. Our survey results demonstrated a pattern of systemic delays. 52% of respondents reported
receiving their ballot papers less than 11 days before the poll or not receiving them at all.
Specific narrative evidence includes a voter as close as France receiving their ballot the day
after the election and a voter in the United States receiving a pack just 11 days before the
poll, which made a successful return via international mail nearly impossible. Several survey
respondents reported paying for private express courier services in an attempt to have their
vote counted.
16. All of this supports the conclusion in the Electoral Commission’s report on the General
Election stating that ‘The options for voting by British and eligible Irish citizens overseas do
not work well enough.’ 4

2 See Data from Electoral Commission Review of 2024 General Election, column AW.
3 See 2024 United Kingdom Parliamentary General Election administrative data,
ConstituencyData tab, column AX
4 See pp 22-26

17. RECOMMENDATION
We support the call in amendment NC8 to examine additional methods of ‘facilitating
overseas electors to vote’ and are particularly in favour of
○ The digital transmission and at-home printing of ballot papers to halve the round-
trip post time, as has been done for many years elsewhere, including in the US since
the 2012 Presidential Election.
○ Ballot distribution by UK embassies and consulates with the option of returning
through them.
○ Amending the electoral timetable to increase the time allowed for the registration of
overseas voters and allow a longer period for the issue and return of their ballots.
18. RECOMMENDATION
We suggest consideration of the Canadian approach of distributing ballot papers without
candidate names on them, which can be distributed in advance of the close of nominations,
allowing the voter to write the name of their preferred candidate once candidate lists are
published.
19. RECOMMENDATION
Whilst we support electronic distribution of ballots, most election security experts are
against online voting5. We therefore suggest that the consultation proposed in NC8 include
risk-benefit analysis evidence from such experts.
20. RECOMMENDATION
Create a centralised electoral register for overseas electors to address the lack of
information about problems faced by overseas electors and systematically assess the
performance of the electoral system for them, as recommended in the PACAC review of the
2024 General Election6 . This should encompass the collection of a wider range of metrics
including
○ Overseas registration patterns by new and existing voters, including applications
made, their outcomes and the reasons for their acceptance or failure.
○ The number of electors using the different methods of voting and the number of
successes or failures of each in leading to a vote being counted.

5 Example paper: Park, S., Specter, M., Narula, N., & Rivest, R. L. (2021). Going from bad to worse:
From Internet voting to blockchain voting. Journal of Cybersecurity, 7(1), tyaa025.
6 page 45, paragraph 122

Exclusion of Overseas Voters from Automatic Voter Registration
21. We welcome the introduction of Automatic Voter Registration (AVR) in Part 2 of the Bill, but
are disappointed to see that it specifically excludes overseas electors.
22. The annual canvass in the UK not only refreshes the data on the electoral roll, but also
serves to publicise the democratic rights of those living there. Given the low level of
awareness and participation amongst overseas voters, AVR is particularly important for this
group.

23. RECOMMENDATION
We welcome using passport application and renewal as opportunities to inform citizens of
their voting rights, as proposed in Amendment NC7, but recommend that these
opportunities be used as a gateway to automatic voter registration, rather than merely
providing the applicant with registration information. We would also include other
governmental contact with individuals, including immigration services, Department for Work
and Pensions, and HMRC as opportunities to make progress towards voter registration for
eligible citizens.
Removing Obstacles to Proxy Voting
24. Local councils have been recommending proxy voting as an alternative for overseas electors
for at least the last two elections.
25. We received regular enquiries and requests for help from potential electors abroad who
were unable to find a proxy in the constituency where they voted, unaware that they could
appoint someone living elsewhere who could then cast the vote on their behalf by post.
26. We received considerable correspondence at the 2024 General Election from concerned
citizens abroad when it became clear that their postal vote would arrive too late to be
returned in time to be counted. Since they had registered to vote by post, there was no
mechanism to switch to a proxy vote as a fallback. Whilst the provision in the Bill to allow a
postal voter to change their voting method at the last minute to an in-person ballot is
helpful for a UK resident, it is not fit for purpose for someone living abroad, who would likely
not be able to travel to the UK to vote in person at short notice.
27. We received a number of reports of proxies being refused at polling stations. In one
instance, a presiding officer did not understand how to locate an elector in the "overseas
category" on the register and had already turned away several other voters for the same
reason.

28. RECOMMENDATION
We recommend that clearer information needs to be provided to voters about who is able
to be appointed as their proxy, especially at the time of their registration or its renewal. We
further recommend that polling station staff receive clearer guidance on the use of overseas
registers.
29. RECOMMENDATION
We also request further clarification as to the circumstances under which political parties
are permitted to assist voters in finding a proxy to vote on their behalf.
30. RECOMMENDATION
The provision in the Bill to allow a postal voter to switch to an in-person vote should be
extended to allow them to nominate a proxy.
Lack of campaigning material sent to overseas voters
31. Overseas voters deserve to be able to make informed decisions about which candidate to
support, yet they are often forgotten in campaigning. Unlike in the UK, they are not entitled
to receive a ‘Freepost’ leaflet from candidates.
32. We believe overseas voters should have the same opportunity to receive material from
candidates as domestic voters, but understand that the cost and potential delays of using
the ‘Freepost’ system may be problematic.
33. RECOMMENDATION
We recommend that a feasibility study is conducted to examine the options for the
‘Freepost’ distribution of leaflets to overseas electors, including electronic communication
using email addresses held by Electoral Registration Offices.
Dedicated representation through overseas constituencies
34. The UK’s constituency system is built on the principle that representatives should have a
direct, working knowledge of where their constituents live. This fundamental link is broken
by overseas voters being tied to the constituency in which they lived immediately before
they left the UK. There are many drawbacks for both the Member of Parliament and their
overseas constituents including:
○ MPs being expected to deal with overseas constituents living across the globe
○ Constituents routinely being told in MPs’ communications that they cannot be
helped unless they are resident in the constituency.

35. We affirm our long-standing support for the creation of Overseas Constituencies, a system
used in many countries ranging across Europe, Asia, and the Americas, which has the
potential to:
○ Ensure a better understanding for their MP of the concerns and issues affecting
overseas constituents and therefore an improved ability to represent them in
Parliament.
○ Provide improved links to the legislative system whose decisions have an important
effect on Britons abroad.
36. RECOMMENDATION
We call for this Bill to include a feasibility study to make proposals for the creation of
Overseas Constituencies.
Education and awareness
37. Only 26% of British citizens abroad are aware of their right to vote7. It is therefore not
surprising that turnout was so low at the last General Election, despite the 2.5-fold increase
in eligible voters.
38. The Electoral Commission created material for use in publicity and education programmes to
inform voters of the changes in eligibility. This material was appropriate, but the method of
delivery was extremely limited. For example, our connections in overseas digital media
reported that there was no budget for advertising, and several councils told us they
expected the publicity to be carried out by others, despite their contact with potentially
eligible citizens.
39. LDA, like representatives of UK political parties abroad, ran an awareness campaign.
However, as representatives of a single political party, we found that many organisations
were unwilling to work with us.
40. RECOMMENDATION
We ask that the Electoral Commission is funded to conduct a voting rights awareness
campaign to eligible voters abroad, in collaboration with Government departments,
embassies, high commissions, and non-governmental organisations.
Donations
41. We welcome the tightening of rules on donations to UK political parties, and support
amendment NC2 to exclude individuals serving a foreign administration from being
permissible donors. It is important, however, that eligible British citizens abroad continue to
be able to donate to UK political parties. As legitimate voters, the diaspora should have the
same level of democratic service and effective participation as domestic electors.
42. Whilst supporting our Party’s commitment for tackling foreign influence in our politics, we
do not accept that the Government's recent proposed amendment to the Bill to restrict
donations from British citizens abroad to £100,000 per annum is a fair or consistent

7 YouGov poll commissioned by the Electoral Commission after the 2024 General Election

response to their stated aim of enabling the full democratic participation of those legitimate
voters.

43. RECOMMENDATION
We urge the Government to use this Bill to implement a cap on all donations to political
parties and so maintain the democratic equivalence between all British voters, wherever
they live.

Conclusion
44. The Government stated in their response to the Electoral Commission’s General Election
report that "Overseas electors are legitimate voters who should be able to exercise their
vote without unnecessary barriers and we will consider options to support voting by
overseas electors in general".
45. However, this Bill as drafted fails to tackle those very barriers, and so does nothing to reduce
the democratic deficit endured by voters abroad.
46. We urge the Committee to adopt amendments in the areas mentioned to ensure that the
"Representation of the People" Bill truly includes all of the people, regardless of where they
live.
March 2026