Draft Financial Scheme - Version 1
This document is not yet ratified by core group members or accepted as part of an application for registration as a political party to My UK Manifesto. By core group, we mean our Members so far. It’s creation date was 31 August 2024.
Words in italics will be true at the time of registration but are not yet in effect or they are commentary for the public. If you’d like to feedback, please either drop us a message on X (formerly Twitter) or on our Facebook group (Action to Change the British and Northern Irish Political System).
The document below is adapted from the Template Financial Scheme that the Electoral Commission provides on their website, in turn, it attempts to address many legislative requirements within the PPERA.
1. Preamble
1.1. It is a requirement of the Electoral Commission, who manages the registration, de-registration and regulation of political parties in England, Northern Ireland, Scotland and Wales to adopt a financial scheme.
1.2. This scheme sets out the arrangements for regulating the financial affairs of My UK Manifesto for the purposes of the Political Parties, Elections and Referendums Act 2000, abbreviated to “PPERA”.
1.3. This scheme concerns the financial affairs of the party that is registered in Great Britain and Northern Ireland.
1.4. All Registered Volunteer Officers of the Party have read the scheme, and understand the obligations and responsibilities outlined.
1.5. The scheme has been adopted by the party and will be in practice at the point of registration with the Electoral Commission.
1.6. The Party will have processes in place to ensure compliance with its legal obligations.
1.7. The Volunteer Registered Party Treasurer will ensure that the Party Founder and Leader (one and the same), all Volunteer Registered Officers and Members of the Party have sufficient knowledge of financial obligations under PPERA to ensure that the party as a whole complies with these obligations.
1.8. The Party has a constitution that sets out its structure and how it operates in practice. The Party has provided a copy of this constitution to the Electoral Commission.
1.9. The arrangements outlined in this constitution are consistent with the obligations outlined by this scheme.
1.10. The party must notify the Electoral Commission of any updates made to the constitution no later than the Party’s annual renewal confirmation deadline.
2. Amendments to the Financial Scheme
2.1. The Financial Scheme, so far as the outcome of any confirmative motion is compliant with the Requirements of the PPERA and any other requirements of the Electoral Commission, can be updated by the majority of Members passing a motion at ballot for the change(s).
2.2. Any amendments that are passed through motion at a ballot by the majority of Members voting in favour shall, until confirmed by the Electoral Commission, be considered a proposed amendment owing to the legal requirement for the Electoral Commission to have the final say.
2.3. Where proposed changes to the Financial Scheme are refused by the Electoral Commission, reasons for this will be sought from the Electoral Commission and reported back to the membership, the Financial Scheme shall remain the same as it was before the proposed change and Members are welcome to raise a new motion, paying due regard to the feedback received from the Electoral Commission.
2.4. The Volunteer Registered Treasurer will be tasked with ensuring that any proposed amendments to this scheme are submitted to the Electoral Commission for approval. A revised scheme must be approved in writing by the Electoral Commission.
3. Separate Organisation and Administration of Financial Affairs in Northern Ireland
3.1. The Party shall be registered in Great Britain and Northern Ireland, subject to the agreement of the Electoral Commission.
3.2. The Party shall have, as it is legally required, measures to ensure the separate organisation and administration of financial affairs in Great Britain and separate organisation and administration of financial affairs in Northern Ireland.
3.3. The Volunteer Donations Team for Northern Ireland and Great Britain shall be separate teams, which may consist of more than one separate team for Great Britain and more than one separate team for Northern Ireland.
3.4. [There shall be a separate Volunteer Unit Treasurer for Northern Ireland??] that is overseen by the Volunteer Party Registered Treasurer. [OR] There shall be a separate Volunteer Registered Treasurer for Northern Ireland and a separate Volunteer Registered Treasurer for Great Britain???
3.5.The Volunteer Registered Party Treasurer for Great Britain shall not have a separate Volunteer Unit Treasurer. THIS COULD POSSIBLY BE IRRELEVANT BASED ON THE OUTCOME OF THE QUESTION OVER THE ABOVE.
3.6. Both the [Volunteer Unit Treasurer for Northern Ireland??], and the Volunteer Registered Party Treasurer shall be able to avail themselves of, in the case of the Volunteer Registered Party Treasurer, one or more Volunteer Deputy Party Treasurers and, in the case of the [Volunteer Unit Treasurer for Northern Ireland, one or more Volunteer Deputy Unit Treasurers??] where such appointment must be through ordinary Volunteer Recruitment process and the Registered Volunteer Party Treasurer shall be responsible for notification of the appointment of any Deputy Party Treasurer(s) to the Electoral Commission.
3.7. Where the [Volunteer Unit Treasurer for Northern Ireland??] or the Volunteer Registered Party Treasurer appoint Deputies, the ultimate responsibility for legally required reporting to the Electoral Commission shall remain the task of the Volunteer Registered Party Treasurer.
3.8. Membership subscriptions and all donations, from members or from anybody else where we are legally entitled to accept donations, shall only be received by Credit or Debit Card or Direct Debit, but not in cash for the purposes of maintaining the confidence of Members and the general public and for security and transparency purposes. Both membership subscriptions and donations shall be held in separate bank accounts in respect of Great Britain and Northern Ireland, accounted for separately but on the same accounting software.
3.9. Membership Direct Debits, where members opt to pay by Direct Debit, shall be processed through a separate Direct Debit Processor account. In respect of Northern Ireland, this Direct Debit Processor account shall make only payments into the My UK Manifesto Northern Ireland bank account. In respect of Great Britain, the separate Direct Debit Processor account shall only make payments into the My UK Manifesto Great Britain bank account.
3.10. Credit and Debit Card donations shall be processed through a separate credit and debit card merchant processor account with each separate merchant processor account only paying out into the My UK Manifesto Northern Ireland or the My UK Manifesto Great Britain account respective to where the Donor is registered on the Electoral Role, other official database or in the form of other acceptable evidence as provided for in the PPERA.
3.11. In terms of which bank account membership payments (but not donations) are entered into, this shall depend on the location that the Member provides at the time of registration and not necessarily the country that they are registered under on the Electoral Role (if they are registered on it at all). This may be based on whether they consider Great Britain or Northern Ireland to be their home (“their geographic affiliation”).
3.12. Members can only be a registered on the My UK Manifesto Debate Platform (The online forum) in one region in one country at a time and their membership payments must be paid into either the My UK Manifesto Great Britain or My UK Manifesto Northern Ireland bank account that coincides with the country that they are registered as a Member within based on their geographic affiliation.
3.13. Members may opt to change their geographic affiliation at their discretion. In such cases, membership payments, until the date that the geographic affiliation change is confirmed in writing by My UK Manifesto, shall be paid to the respective My UK Manifesto bank account attributed to the country that they were registered in and, following the change of geographic affiliation, such funds shall remain in and be accounted for within the My UK Manifesto Great Britain or My UK Manifesto Northern Ireland bank account where they were originally received.
3.14. In terms of which bank account Donations are paid into, the following directions shall apply:
3.14.1. An individual registered on a UK electoral register, including overseas electors and those leaving bequests shall have such donations processed as a Great Britain transaction and donations shall be paid into the My UK Manifesto Great Britain bank account.
3.14.2. An Irish citizen, including those leaving bequests, shall have such donations processed as a Northern Ireland transaction and donations shall be paid into the My UK Manifesto Northern Ireland bank account.
3.14.3. In the case of a registered company in the UK (but not in Ireland or Northern Ireland), that is to say a company that is incorporated in the UK and carries on business in the UK, shall have donations processed as a Great Britain transaction and donations shall be paid into the My UK Manifesto Great Britain bank account.
3.14.4. In the case of a registered company in Ireland or Northern Ireland, an Irish-registered company which is incorporated within the EU, and has an office in Ireland or Northern Ireland from which the carrying out of one or more of it’s principle activities is directed, shall have donations processed as a Northern Ireland transaction and donations shall be paid into the My UK Manifesto Northern Ireland bank account.
3.14.5. In the case of a Limited Liability Partnership in the UK (but not in Ireland or Northern Ireland), that is to say a Limited Liability Partnership which carries on business in the UK, shall have donations processed as a Great Britain transaction and donations shall be paid into the My UK Manifesto Great Britain bank account.
3.14.6. In the case of a Limited Liability Partnership in Ireland or Northern Ireland, that is to say a Limited Liability Partnership that has an office in Ireland or Northern Ireland from which the carrying out of one of more of its principle activities is directed shall have donations processed as a Northern Ireland transaction and donations shall be paid into the My UK Manifesto Northern Ireland bank account.
3.14.7. In the case of a political party registered in the UK, it shall have donations processed as a Great Britain transaction and these shall be paid into the My UK Manifesto Great Britain bank account. In the case of one registered in Ireland, the donation shall be processed as a Northern Ireland transaction and donations shall be paid into the My UK Manifesto Northern Ireland bank account.
3.14.8. In the case of a Trade Union registered as a Trade Union in UK, it shall have donations processed as a Great Britain transaction and these shall be paid into the My UK Manifesto Great Britain bank account. In the case of one registered in Ireland, the donation shall be considered a Northern Ireland Transaction and shall be paid into the My UK Manifesto Northern Ireland bank account.
3.14.9. In the case of a Building Society registered as a Building Society in the UK, it shall have donations processed as a Great Britain transaction and these shall be paid into the My UK Manifesto Great Britain bank account. In the case of one registered in Ireland, the donation shall be considered a Northern Ireland transaction and shall be paid into the My UK Manifesto Northern Ireland bank account.
3.14.10. In the case of a Friendly, Industrial or Provident Society, registered as a Friendly, Industrial or Provident Society in the UK, it shall have donations processed as a Great Britain transaction and these shall be paid into the My UK Manifesto Great Britain bank account. In the case of one registered in Ireland, the donation shall be considered a Northern Ireland transaction and shall be paid into the My UK Manifesto Northern Ireland bank account.
3.14.11. In the case of an unincorporated association, that carries on the majority of its business or other activities in the UK, it shall have donations processed as a Great Britain transaction and these shall be paid into the My UK Manifesto Great Britain bank account. In the case of one, that carries on the majority of its business or other activities in Ireland and has its main office in Ireland, the donation shall be considered a Northern Ireland transaction and shall be paid into the My UK Manifesto Northern Ireland bank account.
3.15. In the case of an anonymous donation or a donation where My UK Manifesto cannot be satisfied that the Donor is a permissible Donor, My UK Manifesto cannot and shall not accept such payments and shall, wherever possible, return such a donation to the Donor, regardless of whether the donation is processed by a human or where they have been received by automated means i.e. through websites. Where it is not possible to return such donations, My UK Manifesto shall make arrangements with the Electoral Commission to hand over such donations as per the legal requirement to do so.
3.16. Where it becomes apparent that a donation has been taken from a person registered to vote in Northern Ireland, but it has been received into the party’s Great Britain bank account, the Volunteer Registered Party Treasurer shall be responsible for transferring the money to the separate My UK Manifesto English bank account.
3.17. Where it becomes apparent that a donation has been taken from a person registered to vote in Great Britain, but it has been received into the My UK Manifesto Northern Ireland bank account, the [Volunteer Unit Treasurer for Northern Ireland??] shall be tasked with ensuring the transfer of the donation to the My UK Manifesto Great Britain bank account.
4. Donations Reporting Requirements
4.1. In order to comply with the requirements of the PPERA, the Volunteer Registered Party Treasurer is tasked with, for donations:
4.1.1. Recording information for all Donations of more than £500, including, but not always limited to:
4.1.1.1. The amount or value of the donation;
4.1.1.2. The full name of the Donor;
4.1.1.3. The registered address of the Donor;
4.1.1.4. The Company Registration Number (if applicable);
4.1.1.5. The date on which the donation was received;
4.1.1.6. The date on which the donation was accepted or returned;
4.1.1.7. Information about the trust (if applicable);
4.1.2. Checking the permissibility of any donations over £500 as immediately as possible.
4.1.3. Ensuring, within 30 calendar days of receipt, that impermissible or unidentifiable donations of more than £500 received by the party are recorded as outlined above and returned to the sender or financial institution that transferred the money, or, if that is not possible, that the donation is surrendered to the Electoral Commission.
4.1.4. Ensuring that a submission of a quarterly donation report is received by the Electoral Commission within the timescales outlined in section xxxx of this scheme.
4.1.5. Ensuring that report shall include details of donations exceeding £11,180 (including aggregates in the same calendar year of donations and regulated transactions from the same source, donations that exceed £2,230 that come from a source the Party has already accepted an over £11,180 benefit from, in that calendar year, and any impermissible or anonymous donations of more than £500; or submit a nil report if there are no reportable donations.
4.1.6. Providing weekly Great Britain donation reports to the Electoral Commission during UK Parliamentary General Election campaigns, if the Party is contesting an election, and with providing separate weekly donation reports to the Electoral Commission for any Northern Ireland donations.
4.2. In order to comply with the requirements of the PPERA, the Volunteer Registered Party Treasurer is tasked with, for transactions:
4.2.1. Recording information about all regulated transactions (loans, credit facilities, etc.) of more than £500, including but not always limited to:
4.2.1.1. Value of benefit of the transaction;
4.2.1.2. The Name of all authorised participants;
4.2.1.3. The Registered addresses of participants;
4.2.1.4. The Company Registration Number (if applicable);
4.2.1.5. The nature of the transaction;
4.2.1.6. The date the agreement was entered;
4.2.1.7. The terms of the transaction.
4.2.2. Ensuring that the Party does not enter into any regulated transactions over £500 with unauthorised participants.
4.2.3. Ensuring that a submission of a quarterly transaction report is made to the Electoral Commission by the timescale outlines in Section xxx of this scheme.
4.2.4. The report will need to include details of:
4.2.4.1. Transactions exceeding £11,180 (including aggregates in the same calendar year of donations and regulated transactions from the same source).
4.2.4.2. Transactions exceeding £2,230 that come from a source the Party has already accepted an over £11,180 benefit from in that calendar year,
4.2.4.3. Any void transactions
4.2.4.4. Transactions or more than £500 entered into with an unauthorised participant
4.2.4.5. A nil report if there are no reportable transactions.
4.2.5. Providing weekly transaction reports to the Electoral Commission during UK Parliamentary election campaigns for Great Britain Transactions, if the Party is contesting the election. Separate weekly transaction reports must be submitted for the Party in respect of Northern Ireland transactions.
5. My UK Manifesto Financial Year
5.1. The Party’s financial year shall run from 1 January – 31 December of each year.
6. Responsibility for Compliance with the Political Parties, Elections and Referendums Act 2000 (PPERA)
6.1. The Volunteer Registered Party Treasurer is legally responsible for the whole party’s compliance with the Political Parties, Elections and Referendums Act in law save for deliberate or non-deliberate breaches of other party volunteers, where:
6.1.1. Training was delivered and a receipt for such training was received by My UK Manifesto that agrees:
6.1.1.1. The policies covered in training;
6.1.1.2. That the Volunteer has fully understood the training provided;
6.1.2. Those policies were sent to the Electoral Commission to invite their consultation, at the time of creation or any update, and, where feedback was provided from the Electoral Commission, it was adopted before the policy was included within training and
6.1.3. Action shall be immediately taken in investigating whether the breach was accidental or deliberate, in consultation and full cooperation with the Electoral Commission.
6.1.4. In the event of non-deliberate error, training shall be provided without undue delay to the Volunteer or Volunteers involved.
6.1.5. Where a deliberate breach is found this shall amount to a serious breach of membership rules and expulsion of the Member (and therefore the Volunteer) shall apply, subject to appeal and per the party disciplinary process, that also contain rights of appeal, within the My UK Manifesto Party Constitution.
[Please note: Regarding the text in red, these are safeguards we shall be asking for from the Electoral Commission as there is an argument that the requirements to pass on legal obligations to Volunteers put us at odds with employment law in recruiting Volunteers by placing requirements upon them (that could be considered as an implied employment contract when we have no intention to form one with Volunteers) and the risk of legal ramifications posed, for a party without a pot to yet p**s in interferes with our collective Article 12 EcHR right to Freedom of Assembly and of Association.
The Party Leader would be quite happy to take all legal liability, relating solely to accidental breaches of the law, instead of any Volunteer, until there are other paid Party Officers, as they shall eventually be paid for their time, in compensation for the level of responsibility involved].
Please see Temporary Section 24 for references.
15. Annual Accounts
15.1. The Volunteer Registered Party Treasurer is tasked with preparing a statement of accounts in respect of each financial year of the party.
15.2. The Volunteer Registered Party Treasurer is tasked with ensuring that the party’s annual accounts are approved by the party’s Direction and Strategy Committee that includes the Leader of the party as the leader of the Direction and Strategy Committee.
15.3. The Volunteer Registered Treasurer will submit the annual statement of accounts to the Electoral Commission:
15.3.1. If both expenditure and income of the party are £250,000 or under, in that year, by 30 April of the year following the end of the financial year; or
15.3.2. If either expenditure or income exceeds £250,000 in that year, by 7 July of the year following the end of the financial year and
15.3.3. If income or expenditure of the party exceeds £250,000, the party’s accounts must be submitted with an Independent Auditor’s report.
15.4. In order to comply with this requirement, the Party’s Volunteer Registered Treasurer has:
15.4.1. Put in place arrangements for ensuring that annual statements of accounts for the party are prepared, approved, audited (where necessary) and submitted to the Electoral Commission by the prescribed deadline.
15.4.2. Put in place accounting processes capable of meeting the accounting record keeping requirements under PPERA and of any regulations made by the Commission about the format of statements of accounts.
15.4.3. Put in place processes to keep accounting records for 6 years. This continues to apply in the event that the party is deregistered.
16. Donations and Transactions (Loans, Credit Facilities and Securities)
16.1. The Volunteer Registered Party Treasurer is tasked with reporting the donations and transactions it receives each quarter to the Electoral Commission, for each of the registers My UK Manifesto is registered on, within the following timescales:
16.1.1. Quarter 1 (1 January – 31 March) by 30 April of that year.
16.1.2. Quarter 2 (1 April – 30 June) by 30 July of that year.
16.1.3. Quarter 3 (1 July – 30 September) by 30 October of that year.
16.1.4. Quarter 4 (1 October – 31 December by 30 January of the following year.
16.2. Separate quarterly reports shall be submitted for Great Britain and Separate quarterly reports shall be submitted for Northern Ireland.
16.3. If the Volunteer Registered Party Treasurer submits four consecutive quarterly nil donation reports, the Party will then be exempt from submitting further quarterly donation reports, until receipt of a reportable donation.
16.4. If the Volunteer Registered Party Treasurer submits four consecutive quarterly nil transaction reports, the Party will then be exempt from submitting further quarterly transaction reports, until receipt of a reportable transaction.
17. Campaign Expenditure
17.1. If the Party has candidates contesting a UK Parliamentary General Election, Scottish Parliamentary Election, Senedd Election or Northern Ireland Assembly election then the Volunteer Registered Party Treasurer is tasked with submitting a separate Great Britain and a separate Northern Ireland Campaign Expenditure Return to the Electoral Commission.
17.2. In the case of Northern Ireland and Great Britain, the Expenditure Returns will need to be submitted within three months of the date of the election if My UK Manifesto’s expenditure is £250,000 or less, or within six months of the date of the election if My UK Manifesto’s expenditure exceeds £250,000. If My UK Manifesto’s expenditure during the campaign exceeds £250,000, My UK Manifesto’s return must also be submitted with an Independent Auditor’s report.
17.3. In order to ensure compliance with the legislation, the party’s Volunteer Registered Treasurer will ensure that campaign expenditure and claims payments are duly authorised, received and paid on time, and that all relevant receipts and invoices are kept.
17.4. No campaign expenditure shall be incurred by, or on behalf of, My UK Manifesto unless it is incurred with the authority of The Volunteer Registered Party Treasurer or any Volunteer Deputy Treasurer(s) or a person authorised in writing by the Volunteer Registered Party Treasurer or any Volunteer Deputy Treasurer(s).
17.5. No payment may be made in respect of any campaign expenditure incurred or to be incurred by, or on behalf of, My UK Manifesto unless it is made by the Volunteer Registered Party Treasurer or any Volunteer Deputy Treasurer(s), or a person authorised in writing by the Volunteer Registered Party Treasurer or any Volunteer Deputy Treasurer(s).
17.6. The Volunteer Registered Party Treasurer is tasked with putting in place budgeting and monitoring arrangements to ensure that campaign expenditure is within the statutory limits.
17.7. The Volunteer Registered Party Treasurer is tasked with ensuring the compilation, auditing (if necessary) and timely submission to the Electoral Commission of a Campaign Expenditure return within the statutory deadlines.
18. Referendums
18.1. If the party participates in a referendum to which PPERA applies, the party will develop and put in place arrangements for complying with the controls on referendum expenditure.
19. Grants
19.1. The Party will ensure that any grants from the Electoral Commission to the party are spent in accordance with the conditions of grant imposed by the Electoral Commission. My UK Manifesto agrees to cooperate with any associated audit requirements specified by the Electoral Commission.
[Please note: We can’t get a grant until we have two representatives in the House of Commons).
20. Changes to Registered Details
20.1. The Volunteer Registered Party Treasurer is tasked with ensuring that My UK Manifesto’s details, that are registered with Companies House, the Electoral Commission and HMRC are kept up to date.
20.2. The Volunteer Registered Party Treasurer is tasked with ensuring that the Electoral Commission are notified of any changes to Registered Officers, due to death or due to the termination of their appointment, within 14 calendar days of the change and that any other changes are notified within 28 days.
21. Annual Renewal Confirmation Due to the Electoral Commission
21.1. The Volunteer Registered Party Treasurer is tasked with ensuring that the Party’s Annual Renewal Confirmation and £25 fee are delivered to the Electoral Commission by 31 October of each year (if the party’s expenditure and income are each £250,000 or less) or by 7 January of the following year (if the party’s expenditure or income exceeds £250,000).
21.2. If the Party’s Annual Renewal Confirmation is not submitted within the prescribed timescale, the Party will, by law, be removed from the register of political parties.
22. Offences and Contraventions
22.1. The Party understands that failure to comply with certain legal requirements of being a registered political party may be a criminal offence or contravention of the law [but considers that the PPERA is in contravention of Article 12 of the EcHR (Right to Freedom of Assembly and of Association) in relation to Volunteer run political parties and that the legislation is unduly oppressive].
22.2. The party also understands that the commission may impose civil penalties, including fines, on any parties and/or responsible officers that fail to comply with their legal obligations, including failures to submit statutory reports or returns on time.
23. Declarations
23.1. We, the Volunteer Registered Officers named below, therefore understand the following:
23.2. All Volunteer Registered Officers, including new Volunteer Registered Officers, must read the scheme, and understand the obligations and responsibilities outlined.
24. Temporary Section - References Supporting Issues
1. Electoral Commission Financial Scheme Template – Click/tap here to open in a new tab.
2. Electoral Commission – How to Register Your Political Party – Click/tap here to open in a new tab.
3. National Council for Voluntary Organisations guidance: “Making Sure You Don’t Create an Employment Contract” – Click/tap here to open in a new tab.
4. Political Parties, Elections and Referendums Act 2000 (PPERA) – Click/tap here to open in a new tab.
5. Murray v Newham Citizens Advice Bureau [2000] UKEAT 1096_99_0607 – Click/tap here to open the case in Bailii in a new tab.
6. Article 11 of the EcHR – courtesy of the Equality and Human Rights Commission – Click/tap here to open in a new tab.