Cynulliad Cenedlaethol Cymru

National Assembly for Wales

Y Pwyllgor Materion Cyfansoddiadol a Deddfwriaethol

Constitutional and Legislative Affairs Committee

Bil Senedd ac Etholiadau (Cymru)


Senedd and Elections (Wales) Bill

CLA(5) SE12a

Tystiolaeth ychwanegol gan y Comisiwn Etholiadol

Additional evidence from the Electoral Commission

Thank-you once again for the opportunity to provide evidence to the Constitutional and Legislative Affairs Committee as part of its scrutiny of the Senedd and Elections (Wales) Bill on 29 April 2019.

At this session, a question was put to us on the registration process in Scotland, how this differed from Wales and any advantages or disadvantages to this process.

The Electoral Registration Officer (ERO) is an official appointed by the local authority to prepare and maintain the register of electors. Throughout Scotland (with the exception of the City of Dundee and Fife) councils have appointed the local Assessor as ERO.

In Scotland, assessors are responsible for the valuation of all heritable properties for local taxation purposes within their respective valuation areas. Each of the 32 local councils within Scotland is a valuation authority and responsible for appointing an Assessor. There are however only fourteen Assessors in Scotland, four are appointed directly by a single Council and the remaining ten are appointed by Valuation Joint Boards comprising elected members appointed by two or more Councils. 

The reason that many local Assessors also act as ERO in Scotland dates back to the 1856 when legislation was passed that made the Valuation Roll the basis for the Electoral Register and required them to be compiled by the same person. This legal requirement was dropped in 1975, but in practice most local authorities in Scotland have continued to appoint the Assessor as ERO. 

While the Commission does not have a view on which arrangement is most appropriate, the Scottish Assessors Association would argue that the main advantages of this system are that the electoral register requires an up-to-date and accurate property database as its basis and Assessors are the first to be notified of new properties. It also provides a measure of resilience at busy election periods as the ERO focuses solely on electoral registration and the compilation of absent voter lists while the Returning Officer focuses on the administration of the poll.

However, holding the separate functions in separate offices does require a significant level of trust and communication between officers of the local authority and the ERO to ensure that both functions integrate seamlessly at election periods when systems can be under pressure.

There is no evidence that this different arrangement has had a significant impact on registration rates in Scotland as compared to Wales.

Please do feel free to contact us if you require any further information.

Yours sincerely,




Rhydian Thomas

Head of Electoral Commission, Wales