Representation of the People Bill — Further written evidence submitted by Open Britain (RPB52)
Parliament bill publication: Written evidence. Commons.
Representation of the People Bill (16th April 2026)
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Session 2021-22
Representation of the People Bill
Further written evidence submitted by Open Britain (RPB52)
1.
About Open Britain
1.1
Open Britain is a not-for-profit, non-partisan democratic reform organisation campaigning for a fairer, more accountable political system. We advocate for transparency in political funding, stronger rules on foreign interference in elections and meaningful electoral reform.
1.2
Our current work is anchored in the Bigger Than Politics campaign, which aims to give citizens a greater stake in the governance of our political system. Following the 2024 general election, we established the All-Party Parliamentary Group for Fair Elections, now the biggest APPG in Parliament.
2.
Background
2.1
In addition to our initial written evidence
[1]
, which we do not seek to repeat here, we submit this further evidence following publication of the Rycroft Review
[2]
and the Government’s subsequent response
[3]
.
2.2
Open Britain welcomes the Rycroft Review as a serious and largely constructive contribution to the debate on electoral integrity. The Review reinforces concerns we have consistently raised: that the United Kingdom’s democratic safeguards are insufficiently robust and require urgent strengthening. Its 17 recommendations, if implemented in full, would represent significant progress in enhancing transparency, accountability, and enforcement within the UK’s system of political finance.
2.3
We particularly welcome the Review’s recommendations to strengthen the independence, resources, and powers of the Electoral Commission; to tighten the rules governing corporate donations; and to introduce year-round transparency for campaign spending and donations. We also note the Review’s recognition of the growing threat posed by hostile state interference online
and
support
its call for Permanent Secretary-level accountability for the protection of democratic processes across government.
2.4
The Rycroft Review endorses the Representation of the People Bill
but concludes that the ‘proposed changes do not go far enough’
[4]
.
2.5
While the Government has indicated its intention to take forward two of the Review’s recommendations, namely, introducing a £100,000 annual cap on political donations from overseas electors and banning cryptocurrency donations
[5]
, this falls significantly short of the comprehensive reform proposed by the Review.
2.6
We therefore believe that the Government should adopt all 17 of the Rycroft Review’s recommendations. To the fullest extent possible, the Representation of the People Bill
[6]
should be amended to give effect to these measures and to deliver the strengthened democratic protections that the Review identifies as necessary.
3.
Political finance
3.1 The Committee’s consideration of political finance within the Representation of the People Bill comes against a backdrop of rising spending and declining public confidence. Corporate donations to political parties have increased significantly, from £13.6 million in 2017 to £30.6 million in 2024
[7]
, while only 18 per cent of the public believe that political funding is sufficiently transparent
[8]
. At the same time, the 2024 general election saw a record £94.5 million spent by political parties
[9]
. These trends point to a system in which financial influence is growing, but public trust is not keeping pace.
3.2 While the Rycroft Review makes a valuable contribution, its relatively narrow terms of reference prevented it from addressing the deeper, systemic weaknesses in the UK’s political finance framework. The risks associated with foreign money should be understood as a symptom of a wider problem: a system that lacks transparency, concentrates influence, and is not underpinned by sufficiently strong accountability mechanisms. Although the Review notes that questions such as donation caps and spending limits are matters "for the political class as a whole to consider"
[10]
and stops short of making substantive recommendations in these areas, beyond overseas voters. This Bill provides the Committee with a clear opportunity to take forward that responsibility.
3.3 Open Britain therefore urges the Committee to consider amendments to the Bill which would introduce a universal cap on political donations, rather than limiting such measures to overseas voters alone. As recommended by a broad coalition of Civil Society organisations,
[11]
including Fair Vote UK, Spotlight on Corruption and Transparency International UK, a comprehensive cap would represent a proportionate and necessary step to reduce the risk of undue influence and to rebuild public confidence in the system.
3.4 The Committee should also consider amendments to ensure that corporate political donations are based on post-tax profits rather than revenue, in line with the Rycroft Review’s recommendations. This would help ensure that such donations are made on a more responsible and transparent financial basis.
3.5 In addition, the Bill provides an opportunity to implement a number of further reforms identified by the Review. Strengthening "know your donor" requirements to align with anti-money laundering due diligence would significantly enhance transparency and help prevent illegitimate funding from entering the system.
3.6 Extending the Electoral Commission’s powers to enable it both to share information with, and require information from, other bodies would further strengthen oversight. These changes should be accompanied by measures to ensure that electoral offences can be more effectively investigated and, where appropriate, prosecuted. At present, the Electoral Commission operates with constrained powers and reduced independence, limiting its effectiveness as a regulator. Without a strong and properly empowered watchdog, even well-designed rules risk being inadequately enforced.
3.7 Taken together, these amendments would strengthen the provisions of the Bill and represent a meaningful step towards a more transparent, accountable, and resilient system of political finance.
4.
Foreign interference
4.1
The Government has committed to bringing forward amendments to the Bill
in light of
the findings of the Rycroft Review, including proposals to cap donations from overseas electors and introduce a moratorium on cryptocurrency donations. These measures are welcome and, if implemented, will strengthen the Bill’s provisions in relation to foreign financial influence.
4.2
However, even with these changes, the Bill as currently drafted falls short of addressing the full range of risks posed by foreign interference in UK democracy.
4.3
In relation to financial interference, the Rycroft Review reinforces longstanding concerns that the United Kingdom’s political finance framework is not sufficiently robust. Its recommendations would represent meaningful progress in improving transparency and enforcement. However, its relatively narrow terms of reference limited its ability to examine the deeper structural vulnerabilities that enable foreign financial influence to occur. As the Review itself acknowledges, the true scale of such influence is "by definition unknowable"
[12]
. This highlights a significant gap in the current evidence base and raises serious questions about whether existing safeguards and oversight mechanisms are adequate. The focus of reform remains largely on the source of donations, rather than the wider set of channels through which foreign money and influence may enter the political system.
4.4
Foreign interference, however, extends beyond financial flows. It must also be understood in the context of the wider information environment, including coordinated disinformation campaigns, digital political advertising and other forms of online influence.
4.5
While the Review recognises the growing importance of "information warfare"
[13]
, its conclusions in this area are limited.
In particular, it
places reliance on the Online Safety Act 2023 despite the absence, to date, of clear enforcement action by Ofcom specifically addressing foreign interference.
4.6
Similarly, while proposals to improve coordination within government and strengthen controls on foreign-funded advertising are welcome, they do not fully engage with the broader challenges posed by online disinformation ecosystems or the role of algorithmic amplification in shaping political debate.
4.7
A resilient democracy depends not only on the integrity of its electoral finance rules, but also on the availability of accurate, transparent and trustworthy information. Where the information environment is
distorted
public understanding is undermined, and democratic outcomes may be influenced in ways that are neither visible nor accountable.
4.8
Considering
these gaps
Open Britain urges the Committee to consider the case for establishing a full statutory public inquiry into foreign interference in UK democracy. Such an inquiry, with powers to compel evidence, would be able to determine the scale and methods of interference, trace the flow of influence and funding
and
establish what was known, when and by whom. Crucially, it would provide a comprehensive, evidence-based foundation for identifying systemic weaknesses and recommending the reforms necessary to safeguard future elections, political decision-making
and the wider information environment.
5.
National Commission on Electoral Reform
5.1
Open Britain’s previous evidence to the Committee
[14]
set out the case for establishing a National Commission on Electoral Reform
(NCER)
. Considering the findings of the Rycroft Review, there is now an even more pressing need to address not only the security of elections, but the underlying features of the electoral system itself. In particular, the UK’s current voting system creates
a disproportionate electoral weight placed on a relatively small number of marginal constituencies
, increasing the potential impact of targeted interference. This structural vulnerability remains unaddressed by the present Bill.
5.2
As such, the Bill represents a missed opportunity to take a more comprehensive approach to strengthening the resilience and legitimacy of the UK’s democratic system. Open Britain therefore urges Committee Members to consider amending the Bill to provide for the establishment of
the NCER.
5.3
Such a Commission would be an independent, time-limited body tasked with reviewing whether the UK’s current voting system remains fit for purpose. It would bring together representatives from across political parties, alongside independent experts and members of the public, ensuring that its work is balanced, credible
and grounded in real experience. Crucially, it would not presuppose any particular outcome
-
its role would be to assess the evidence objectively and build broad confidence in its conclusions.
5.4
The Commission would examine what a fair and effective voting system should look like in modern Britain, assess whether the current system meets that standard and consider whether alternative systems could better serve those principles. It would report within a defined timeframe, enabling its recommendations to be considered during the current Parliament.
5.5
In essence, establishing such a Commission would create a structured and impartial process for evaluating the UK’s electoral system, ensuring that any future decisions are informed by evidence, public input, and cross-party engagement.
5.6
Including provision for the NCER in the Bill would represent a proportionate and forward-looking step towards strengthening the integrity and resilience of UK democracy against threats highlighted by the Rycroft Review.
6.
Government Coordination
6.1 The final recommendation of the Rycroft Review calls for the Cabinet Secretary to assign Permanent Secretary-level responsibility for sustaining UK democracy. This reflects a remarkable gap in the current governance of democratic resilience. No senior official in Whitehall presently holds a dedicated brief to oversee and coordinate the protection of the UK’s democratic system. Establishing such a role would provide clear leadership, improve cross-departmental coordination and ensure that long-term strategies for safeguarding elections, political finance and public trust in democratic processes are consistently prioritised at the highest levels of government.
6.2 Open Britain strongly urges the Committee to consider amending the Bill to rectify this gap, ensuring that responsibility for protecting UK democracy is clearly assigned and accountable at the top of the civil service.
14 April 2026
[1]
https://publications.parliament.uk/pa/cm5901/cmpublic/RepresentationPeople/memo/RPB10.htm
[1]
[2]
https://www.gov.uk/government/publications/the-rycroft-review-report-of-the-independent-review-into-countering-foreign-financial-influence-and-interference-in-uk-politics/the-rycroft-review-report-of-the-independent-review-into-countering-foreign-financial-influence-and-interference-in-uk-politics
[2]
[3]
https://assets.publishing.service.gov.uk/media/69c40ce3471d520038d0f631/Rycroft_-_SoS_Letter_to_Political_Party_Reps.pdf
[4]
https://www.gov.uk/government/publications/the-rycroft-review-report-of-the-independent-review-into-countering-foreign-financial-influence-and-interference-in-uk-politics/the-rycroft-review-report-of-the-independent-review-into-countering-foreign-financial-influence-and-interference-in-uk-politics
[4]
[5]
https://assets.publishing.service.gov.uk/media/69c40ce3471d520038d0f631/Rycroft_-_SoS_Letter_to_Political_Party_Reps.pdf
[5]
[6]
https://publications.parliament.uk/pa/bills/cbill/59-01/0384/240384.pdf
[6]
[7]
https://www.transparency.org.uk/sites/default/files/2025-01/Cheques%20and%20Balances%20-%20Countering%20the%20Influence%20of%20Big%20Money%20in%20UK%20Politics.pdf
[7]
[8]
https://www.electoralcommission.org.uk/research-reports-and-data/public-attitudes/public-attitudes-2025
[8]
[9]
https://www.electoralcommission.org.uk/media-centre/general-election-spending-hits-record-high
[10]
https://www.gov.uk/government/publications/the-rycroft-review-report-of-the-independent-review-into-countering-foreign-financial-influence-and-interference-in-uk-politics/the-rycroft-review-report-of-the-independent-review-into-countering-foreign-financial-influence-and-interference-in-uk-politics
[10]
[11]
https://bills.parliament.uk/publications/65474/documents/8045
[11]
[12]
https://www.gov.uk/government/publications/the-rycroft-review-report-of-the-independent-review-into-countering-foreign-financial-influence-and-interference-in-uk-politics/the-rycroft-review-report-of-the-independent-review-into-countering-foreign-financial-influence-and-interference-in-uk-politics
[12]
[13]
https://www.gov.uk/government/publications/the-rycroft-review-report-of-the-independent-review-into-countering-foreign-financial-influence-and-interference-in-uk-politics/the-rycroft-review-report-of-the-independent-review-into-countering-foreign-financial-influence-and-interference-in-uk-politics
[13]
[14]
https://publications.parliament.uk/pa/cm5901/cmpublic/RepresentationPeople/memo/RPB10.htm
Prepared 16th April 2026
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