Policy paper

Protecting the integrity of our elections: Voter identification at polling stations and the new Voter Card

Published 6 January 2022

This was published under the 2019 to 2022 Johnson Conservative government

Ministerial foreword

Our democracy is underpinned by free and fair elections and this government has committed to securing the integrity of those elections for the future. At the heart of an election is the simple action of a voter casting their ballot. Leading international election observers, the Electoral Commission, and the author of the 2016 report on electoral fraud, Sir (now Lord) Eric Pickles, all agree that there are potential vulnerabilities in our current system. That is why this government has committed to updating outdated security protections around identity at the polls and is introducing a requirement for voters to prove their identity at the polling station.

Showing photographic identification is a reasonable and proportionate way to confirm that someone is who they say they are when voting, thus stamping out the potential for voter fraud to take place and giving electors the confidence that their vote is theirs and theirs alone.

As we take decisive action against the potential fraud within the system, we will make sure that the efficiency and accessibility of the process is not compromised. This important work has already benefited from a range of input and expertise from a wide variety of stakeholders and I am committed to continuing the development of the policy in an open and transparent way. I am pleased to be able to set out in this publication more information about how the new requirements will work, and on the application and rollout process that we envisage for the Voter Card.

In publishing this paper, I want to make it absolutely clear that everyone eligible to vote will continue to have the opportunity to do so. These measures have been informed by comprehensive research and pilots, and I wish to reassure all that they will be implemented in a careful and considerate way. We will continue to work closely with the Electoral Commission, civil society organisations and administrators as the legislation progresses through Parliament to ensure that these changes work for all voters.

Kemi Badenoch MP
Minister of State at the Department for Levelling Up, Housing and Communities

1. Introduction

In its 2019 Manifesto, the government committed to “protect the integrity of our democracy, by introducing identification to vote at polling stations”. The Elections Bill, currently being considered by Parliament, aims to deliver on that promise by introducing a requirement to show photographic identification when voting in person at polling stations.

This requirement will apply to UK Parliamentary elections across Great Britain following passage of the legislation, and will be rolled out through secondary legislation to mayoral and council elections and local referendums in England, and Police and Crime Commissioner elections in England and Wales.

Similar requirements for voter identification have been in place in Northern Ireland since 2003.

To assist with scrutiny of the government’s proposals for voter identification, this paper will set out further information on the government’s plans, including:

• The reasoning behind the list of photographic identity documents that will be accepted at polling stations, and those that will not be accepted.

• Detail of plans for secondary legislation, which will set out how the Voter Card will work – the document that will be available free of charge for those electors who do not possess one of the required forms of identification.

2. Current system

The current process for voter identification and tackling personation that is set out in legislation for use at polling stations in Great Britain is twofold. Firstly the elector’s name and voter number is called out, so that any people present have the opportunity to object if that person is not the elector they purport to be. The second is that there is specific provision to allow candidates to appoint polling agents to be present at polling stations for the express purpose of ‘detecting personation’.

This is a security system that has seen no significant changes since the Secret Ballot Act 1872, and it is outdated to the point of being almost completely ineffective.

An elector’s name and address can easily be obtained by a potential fraudster and used with minimal risk of being caught. Poll cards in particular, though vital for providing information to electors, provide a significant vulnerability - if intercepted, not only do they provide a fraudster with the elector’s name and address, but they also confirm that that person is registered to vote and provide legitimacy to the fraudster. In a context of significantly more people being enfranchised and voting since the Secret Ballot Act 1872, increasing populations and fewer people knowing many of their neighbours, the first measure is now insufficient as a means of catching anyone seeking to commit personation – it is very unlikely there will be anyone in the polling station at the same time who knows the elector being personated. In addition, there are more recent concerns about publicly naming people if that information could be abused in some way.

The second measure – provision to allow polling agents to counter personation – suffers from the same issues with lack of knowledge of people in the local area and also because fielding such agents is often not possible for candidates and parties. Scarce resources will not allow them to have people present in every polling station.

This lack of an effective identity check has been found by the Electoral Commission to leave the system vulnerable to fraud and this is reflected in their reports. This risk has also been identified by leading international observers such as the Organisation for Economic Co-operation and Development (OECD).

In response to concerns around electoral fraud, voters in Northern Ireland have been required to show identification when voting at polling stations since 1985, and photographic identification since 2003. Since its introduction, this requirement has successfully helped to tackle electoral fraud and has been operating with ease.^{[footnote 1]}

3. Voter identification

Requirements to produce photographic identification are common in democracies across the world, including most European countries. They are widely acknowledged as an effective system for preventing electoral fraud by ensuring that someone is who they say they are when voting, and therefore represent the most straightforward and proportionate solution to the vulnerabilities in our elections.

The Elections Bill policy proposals have been informed by a significant amount of research, including the findings of voter identification pilots held at local elections across 2018 and 2019, as well as photographic identification research carried out by the Cabinet Office, and a significant amount of work with civil society organisations and other key stakeholders.

Under the Bill’s proposals, a ballot paper will only be delivered to a voter at a polling station if they are able to produce suitable photographic identification included in the wide range of documents set out in the Bill (and below).

Polling station staff will be given appropriate training and there will be a requirement for there to be a private area in polling stations, which will allow voters wishing to have their identification viewed in private to be accommodated.

Accepted forms of identification

The Bill sets out in Schedule 1 the wide range of photographic identification that will be accepted. The full list of documents that will be accepted is reproduced in Annex A to this paper, and this information will be provided to the electorate on poll cards.

In developing the list, specific consideration was given to the following:

• the robustness of the verification measures carried out before issuing of the identification document – in line with the government’s good practice guide on identity verification;
• the demographic(s) of those who the identification document is most likely to be held by, and if the identification is commonly used by those with protected characteristics; and
• the percentage of electors that presented each form of specified identification document in pilots.

The primary criteria for accepted forms of identification focused on ensuring that they must be suitably secure (i.e. not easy to falsify or acquire with false information) and must contain a photograph of the elector in order to enable personal recognition.

Of equal importance to this criteria is the need to ensure that the forms of identification accepted are held across the vast majority of the population. We have always been clear that only permitting the use of passports and driving licences would neither be appropriate nor desirable - though highly secure, we appreciate that not all of the electorate possess them. The initial entries on the list of accepted identification documents are therefore those that are commonly held and have higher levels of security on the good practice guide’s confidence score scale – driving licences, passports, European Economic Area (EEA) issued national identity cards, biometric immigration documents, Proof of Age Standards Scheme (PASS) cards, defence identity cards.

This is supplemented by allowing forms of identification that cater to those demographics who are slightly less likely to have these major forms of identification. In some cases these have a confidence score of 2 (representing the third-highest level, but not the top level of security), but this has been accepted in order to support accessibility. This includes:

• 60+ Oyster card and Freedom Pass
• The Blue Badge, to support disabled voters

The Bill also makes provision for the list to be amended so that additional forms of identification can be added, or some removed, as necessary. This will ensure that, where appropriate, future forms of identification can be added without the need for further primary legislation.

• This could include forms of identification that are currently in the process of being rolled out, such as Veterans Cards. Defence Identity cards (MOD Form 90) are already included – and Armed Forces personnel are able to keep these cards when they leave the service.

• This could also allow for digital forms of identification to be included in the list in the future if appropriate.

A recommendation from the Electoral Commission will be required before anything can be removed from the list – in addition to the relevant Parliamentary procedures.

Forms of identification that will not be accepted

Some forms of photographic identification not included on the list were considered but were ultimately ruled out as they did not satisfy the criteria, and thus will not be accepted if an elector presents them as identification to vote.

These include:

• Work/Student Passes – given the wide array of professional and educational organisations that provide photographic identification, it would not be difficult to create a form of identification for a non-existent organisation meaning these would be susceptible to fraud. It is important to note, however, that some student cards are PASS accredited, and so would be accepted (e.g. the National Union of Students ‘TOTUM’ student card). All accredited PASS cards bear a hologram bearing the Proof of Age Standards Scheme (see Annex A for more information).

• Railcards – while a Railcard is considered a concessionary travel pass, the government does not believe this would be an appropriate form of identification, as it is insufficiently secure. Similarly, the 18+ Oyster card does not have a suitably secure application process for it to be used as photographic identification at polling stations (unlike the 60+ Oyster card, which has more rigorous processes).

Photocopies of identification documents, or pictures of identification saved on mobile phones will also not be accepted as photo-editing software could be used to edit them, thus making them susceptible to fraudulent alteration. The government has been consulting on a future digital identity system and will consider how such solutions may support voter identification in the future.

Ensuring that all eligible voters are able to vote

The government has always been clear that all eligible voters will continue to be able to vote following the introduction of photographic voter identification.

We note the concerns that have been expressed about potential impacts of the introduction of mandatory voter identification on certain societal groups. However, as highlighted in the Equality Impact Assessment published alongside the Elections Bill, extensive research and engagement has shaped these proposals and will continue to shape them as we move towards their implementation.

In addition to the breadth of the range of documents that will be accepted, documents will still be accepted even where they have expired, provided that the photograph remains a good likeness of the elector. This will ensure that the vast majority of electors will have access to identification, and that electors will not need to worry about renewing any documents that expire shortly before a poll.

Extensive research commissioned by the Cabinet Office on the ownership of the proposed list of documents estimated that 98% of the electorate holds an appropriate form of identification. Voter Cards will be available free of charge for any eligible electors who may not have a suitable form of identification.

We are determined to ensure that electors are clear about the new requirements for voting in polling stations. Comprehensive, targeted communications and guidance by the Electoral Commission will raise awareness of voter identification requirements throughout the electorate, and will provide a call to action for electors to ensure they have appropriate identification or have applied for a Voter Card ahead of electoral events.

We have and will continue to work with charities and civil society organisations across the UK to ensure that voter identification works for all voters, and all groups are aware of the new requirements.

Engagement to date has included a wide range of groups, including organisations representing individuals and communities with protected characteristics – age, disability, gender reassignment, race, and religion or belief – as well as organisations representing other groups that the policy may impact, such as the homeless and survivors of domestic abuse. We will continue to work with these organisations to ensure that the new requirements work for all voters, and their input will inform our detailed planning for the Voter Card application process and the practicalities of showing identification in the polling station.

If any additional concerns or potential adversities come to light during the rollout of the new system, we will ensure relevant impacts are identified and mitigated appropriately.

The Elections Bill also makes provision for an evaluation of the impact of the implementation of voter identification to be completed following the first three sets of elections where the requirements apply.

4. The Voter Card

The Elections Bill makes provision for an “Electoral Identity Document” to be provided free of charge, to ensure that all electors have access to an accepted form of identification – this will be a free Voter Card, issued by local authorities.

Detailed information on how the Voter Card policy will be implemented will be set out in secondary legislation in due course. The government’s current intentions are set out below.

Information on the card

The information on the Voter Card will be kept to a minimum – it will show the elector’s name and photograph, the local authority that issued the card, and a card number. This is the essential information required for the voting process, and in taking this approach we have deliberately sought to ensure inclusivity (though more information, such as the elector’s address and date of birth, will necessarily be required to apply for and receive a card).

The elector’s date of birth has been intentionally excluded for Great Britain. The government does not intend for this card to be used for demonstrating proof of age. This is consistent with the fact we have always been clear that this policy will not introduce a national identity card by the back door; the Voter Card is solely for the purpose of supporting the democratic process.

Application process

The government is determined to ensure that the application process is as accessible as possible.

For this reason, electors will have a range of options to choose from when applying for a Voter Card – online, by post or in person.

Regardless of the way a person applies, there will be a check as to the person’s electoral registration status and their identity will need to be confirmed. Electoral Registration Officers (EROs) will be able to check the data provided against local data, such as Council Tax Records, or request further information from the applicant before making their decision, should that be necessary. This is a similar approach as is used to verify applications to register to vote. A list of document types that EROs may request will be set out in secondary legislation, and will be similar to those that can be requested when registering to vote.

Electors will be able to submit an application for a Voter Card at the same time as they submit an application to register to vote – they will not need to wait to have their registration confirmed first.

An appeals process will be put in place, should an elector’s application for a Voter Card be unsuccessful, and the elector wishes to appeal the outcome.

Online applications

Electors will be able to apply for the Voter Card online through a dedicated online system provided by the government, similar to the Register to Vote service. This will allow an elector to upload their details and a photograph.

We intend to ensure that online applications are as accessible as possible for voters. As such we will be consulting with a wide range of stakeholders when testing the application process, including the government chaired Accessibility of Elections Working Group, which includes representation from a number of disability charities and civil society organisations. The service will be designed in line with Web Content Accessibility Standards.

The government intends to implement automatic checks where possible in order to assist the ERO in validating the applicant’s identity and speed up the application process for electors. This again will operate in a similar way to the Register to Vote service.

Applying by post

Electors will be able to make their application by post. Application forms will be available online to download and print (including on GOV.UK), but electors will also be able to request that EROs post an application form to them.

The application form will set out the information required and electors will need to return this along with a photograph to be included on their Voter Card.

Applying in person

Electors will be able to apply for a Voter Card in person, though local authorities will be allowed to determine their own approach to this locally. For example, they may choose to use local government offices.

Individual EROs are best placed to identify how demand in their local authority is best met (such as locations, opening times etc.) as these logistical matters will be heavily dependent on population and geography – e.g. an ERO with electors in a rural area will need to take a different approach an ERO located in a large city.

Deadline for applications and Temporary Cards

We are continuing to work with stakeholders and the electoral sector to identify the most appropriate deadline for when electors can apply for Voter Cards. However, we are determined to make sure that all eligible voters will be able to vote following the changes and are mindful of emergencies and other pressures that could apply to deadlines, as well as impacts on administrators.

As a result, the government intends to work with local authorities to realise our ambition that the last possible point electors can apply for a Voter Card will be the day ahead of a poll. We wish to ensure that electors’ needs and burdens on administrators are proportionately considered, and will explore further options to ensure that this is achieved in a balanced fashion.

The elector will be able to request their Voter Card be posted to them at their registered address, or may collect it in person.

If it is not possible to produce a ‘permanent’ Voter Card in time for a poll, EROs will be able to print Temporary Voter Cards as an interim measure. These will be used in the same way as a ‘permanent’ Voter Card, except that a Temporary Voter Card will only be valid for the day of the poll (this will be an exception to the general position that identity documents will remain valid for voting if the likeness of the photograph remains good).

Where an ERO provides a Temporary Voter Card, then they will also still produce a ‘permanent’ Voter Card and send that to the elector in due course – the elector will not need to make a further application.

Validity

Voter Cards will be usable across all of Great Britain in polls where identification is required – not just in the area of the local authority that issues them.

We envision that Voter Cards will have a ‘life’ of around 10 years – this is the same as passports and driving licences. An elector may apply for a new Voter Card earlier (e.g. if they change their name, they lose their card, the photograph is no longer a good likeness).

As with the other accepted forms of identification, the Voter Card will continue to be usable so long as the photograph remains a good likeness of the elector.

Any date included on the card would therefore primarily serve as a reminder for the elector to apply for a new card to ensure their photograph remains up to date.

Anonymous electors

The government recognises that there are electors who need to register and vote anonymously for a variety of reasons. As now, to maintain anonymity but also ensure that the voter’s identity can still be checked, this will need a system that varies from that for other electors who vote at polling stations.

Anonymous electors who wish to vote in person at a polling station will be able to apply for an Anonymous Elector’s Document. The application process for this will be broadly similar to the Voter Card, but in order to protect the anonymity of the electors the Card will be linked to their registration number as opposed to their name. We are currently working to understand the implications that this may have for the use of Anonymous Elector’s Documents, but bespoke requirements may apply to such cards in order to enable effective verification of identity whilst also protecting the voter’s anonymity.

Anonymous electors voting in person will still need to bring their poll card when voting, as they currently do.

5. Costs

An Impact Assessment (PDF, 904KB) has been conducted to estimate the costs of the Elections Bill, including the voter identification policy. The costs estimated include the costs of the Voter Card as well as additional equipment and staffing requirements at polling stations, and awareness raising.

Voter Cards will be available to all electors who need them, free of charge. The new requirement for photographic identification will cost approximately 25p a year per elector. This includes the production of Voter Cards and raising awareness of voter identification across all the polls happening within the first 10 years.

This is not expected to be a fixed cost, and is likely to reduce over time as electors become familiar with the arrangements.

The government is committed to ensuring local authorities have the necessary resources to continue to deliver our elections robustly and securely as they implement these new measures. As is usual for programmes of this kind, any additional funding required will be delivered to local authorities via new burdens funding in line with longstanding government practice.

Annex A: List of identity documents that will be accepted

Identity Document	Notes
A United Kingdom passport	n/a
A passport issued by an EEA state or a Commonwealth country	n/a
A licence to drive a motor vehicle granted under (i) Part 3 of the Road Traffic Act 1988, or (ii) the Road Traffic (Northern Ireland) Order 1981 (SI 1981/154 (N.I. 1))	This includes provisional driving licences
A driving licence issued by any of the Channel Islands, the Isle of Man or an EEA state	n/a
A biometric immigration document issued in accordance with regulations under section 5 of the UK Borders Act 2007	n/a
An identity card bearing the Proof of Age Standards Scheme hologram (a PASS card)	A wide range of identity documents are PASS accredited including: - CitizenCard - Bracknell Forest Council e-card - My ID Card - Milton Keynes all in 1 MK Card - NUS Totum ID Card - Validate UK Card - Young Scot Card - Southwark Proof of Age London Card - One ID 4 U Card
A Ministry of Defence Form 90 (Defence Identity Card)	Commonly known as a MOD90
Any of the following concessionary travel passes: Funded by the UK Government: - Older Person’s Bus Pass - Disabled Person’s Bus Pass - Oyster 60+ Card - Freedom Pass Funded by the Scottish Government: - National Entitlement Card Funded by the Welsh Government: - 60 and over Welsh Concessionary Travel Card - Disabled Person’s Welsh Concessionary Travel Card Issued under the Northern Ireland Concessionary Fares Scheme: - A Senior SmartPass - A Registered Blind SmartPass or Blind Person’s SmartPass - A War Disablement SmartPass or War Disabled SmartPass - A 60+ SmartPass - A Half Fare SmartPass	This list exhaustively sets out all concessionary travel cards that will be accepted, to avoid any confusion amongst electors.
A badge of a form prescribed under section 21 of the Chronically Sick and Disabled Persons Act 1970 or section 14 of the Chronically Sick and Disabled Persons (Northern Ireland) Act 1978 (blue badge scheme)	n/a
An electoral identity document issued under section 13BD (electoral identity document: Great Britain)	Referred to as the Voter Card
An anonymous elector’s document issued under section 13BE (anonymous elector’s document: Great Britain) the holder of which has an anonymous entry at the time of the application for a ballot paper	n/a
An electoral identity card issued under section 13C (electoral identity card: Northern Ireland)	n/a
A national identity card issued by an EEA state	n/a

1. The 2019 Electoral Commission post-election questionnaire (Excel, 676KB) reported that 83% of voters in Northern Ireland found it ‘very easy to participate in the elections’ as opposed to 78% in Great Britain elections. ↩