Written evidence from The Scottish Assessors’ Association Electoral Registration Committee[1] (TEC 20)


Public Administration and Constitutional Affairs Committee

The Work of the Electoral Commission


The Scottish Assessors Association (SAA) Electoral Registration Committee is made up of all 15 Scottish Electoral Registration Officers (EROs) and their senior staff. It therefore represents the independent statutory officials who have personal responsibility for delivering Electoral Registration services in Scotland.

The Scottish Assessors Association itself is a voluntary non-statutory body that represents the 14 lands valuation Assessors appointed in terms of section 27(2) of the Local Government etc. (Scotland) Act 1994. The SAA has been in existence in one form or another since 1855, and has as its purpose:

“to encourage amongst its members the exchange of ideas regarding their statutory duties; to record results of discussions on all subjects brought before its meetings; to promote consistency in the operation of the Valuation, Council Tax and Electoral Registration legislation;  to act as a consultative and advisory body;  engage in partnership work both internally and externally with organisations and public bodies; and to represent the collective interests of its members in carrying out their duties”

The Electoral Registration Committee (ERC) meets approximately every two months. Representatives from the Electoral Commission, Scottish Government, Boundary Commission and Cabinet Office attend the committee meetings although they are not committee members. The Committee facilitates dialogue between Scottish EROs and partner organisations. It also acts as the principle forum to share good practice, agree timetabling, and a common approach to registration amongst Scottish EROs which in turn provides a consistent registration experience for the elector. Examples include where the ERC has:


EROs in Scotland are independent statutory officials and, as such, this response is limited to administrative/registration issues surrounding the matters raised in this Call for Evidence.

  1. The effectiveness of the Electoral Commission in delivering its statutory obligations.


1.1              The Electoral Commission is highly effective in developing guidance and producing resources for use by Electoral Registration Officers in Scotland. The guidance is well presented and easily accessible. The Commission has adopted a collaborative approach in developing guidance and has an effective and well-structured approach to working with stakeholders. This has been key to ensuring that the guidance has met the needs of the stakeholders who use it.


1.2              The research work and reporting work carried out by the Electoral Commission is very helpful to Electoral Registration Officers as it provides a sound basis for developing engagement strategies or reviewing service delivery. The impartial and independent nature of the Commission is key to this, as its reports are perceived as being neutral and without bias. It is particularly important that reviews of electoral events are carried out by a body that is independent of the people responsible for delivering the electoral events or those who set the legislative framework for those events.


1.3              The Commission also provides a useful and vital role in providing information to citizens on how to take part in the democratic process in the United Kingdom. This complements and assists with the work of Electoral Registration Officers. The Commission also serves as a neutral organisation who the public can turn to for information and advice on the roles and duties of an Electoral Registration Officer. In Scotland, it has been very good at working in partnership with the SAA and the Electoral Management Board for Scotland to promote awareness and engagement with stakeholders such as education bodies and groups representing under registered sectors of the population.


1.4              As a regulator, the Electoral Commission has developed a supportive approach, providing guidance and materials which are designed to enable and assist statutory officers in carrying out their duties. This is a much welcomed approach and is in line with many other regulators. The Commission in Scotland maintains effective links with the statutory officers meaning that were any issues to arise they can be dealt with at an early stage.

  1. What roles and functions within the UK electoral system should the Commission perform?

2.1              The roles and functions currently carried out by the Electoral Commission sit well within the framework of the delivery of electoral events in the UK. For all but UK wide referendums the Electoral Commission is not directly involved in the delivery of elections. This means that they can act and, most importantly, be seen to act independently of those responsible for delivering or legislating for electoral events. This independence means they can carry out effective and unbiased reviews of electoral events and carry out their role as a regulator free from any accusations of bias.

2.2              The recent changes in legislation that mean that the Electoral Commission in Scotland reports to the Scottish Parliament for elections within the Scottish Parliaments control are a logical and welcomed development.

  1. Should the remit of the Electoral Commission be changed?

3.1              In terms of its roles highlighted in section 1 of this response, the SAA sees no need for the Commissions remit to be changed.

  1. What powers should the Electoral Commission have? Should the existing powers of the Electoral Commission be changed?


4.1              See our response in section 3.


  1. The Governance of the Electoral Commission.

5.1              As mentioned already, it is key to the success of the Electoral Commission that it is perceived as politically neutral and unbiased.

5.2              The current balanced structure of Commissioners and being financially accountable to both the Speakers Committee for the UK Parliament and the Scottish Parliamentary Corporate Body for the Scottish Parliament assists in maintaining political neutrality.

  1. Public and political confidence in the impartiality and ability of the Electoral Commission.

6.1              The SAA has always perceived the Electoral Commission as politically impartial.

  1. The international reputation of and comparators for the UK Electoral Commission,


7.1              Care should be taken when comparing the UK Commission to other Commissions as the roles carried out vary. It is important that the regulatory body should not be directly involved in the delivery of electoral events.


  1. What, if any, reforms of the Electoral Commission should be considered?

8.1              The SAA does not propose any major reforms of the Commission


November 2020


[1] Submitted by Pete Wildman – ERO for Central Scotland and Chair of the SAA Electoral Registration Committee