A big thank you to the Conservative party (or ‘4, Matthew Parker Street’)

The above leaflet (you can view it in full here) produced by or on behalf of the Conservative candidate for London mayor, Shaun Bailey, is a considerable help to us and to others. It provides the perfect example of why new rules must urgently be introduced to prevent this kind of shabby manipulation of the existing inadequate regulatory regime.


The leaflet makes a series of material claims related to TFL expenditure without providing any substance or attributing any source to the numbers. If this wasn’t ‘electoral material’ that would not be permitted. Additionally, while the leaflet is clearly (to those more initiated in the dark arts) election material, it doesn’t properly identify itself as such. The requirement in printed material from PPERA/ The Electoral Commission is (cynically) delivered by the promoter’s, and the ‘person on whose behalf the material is published’, statement of their joint address, without the helpful addition of the tenant’s name – Conservative Campaign HQ.


While this example is more grist to the mill for ourselves and the 87% of voters who want to see proper regulation of electoral advertising, it is also and more importantly continuing to reduce standards in the electoral process at voters’ and democracy’s expense. Despite rather more practice, London doesn’t seem to deliver to its voters any better than Washington.

Many thanks to @vauxhallwoman for sending the leaflet on to us.

The Coalition For Reform In Political Advertising

We are not for profit and are run by unpaid volunteers. We rely on donations to continue our work. Please donate to our campaign here.

The Government’s proposals for the introduction of digital imprints in electoral advertising are disappointing for three reasons, only two of which are obvious.

It’s clear that digital imprints, i.e. the means by which political parties and other campaigners can be identified in online advertising, should be introduced as soon as possible, if not earlier. This plan is simply an extension of the requirement applicable to printed material, one that the Electoral Commission have been recommending for more than fifteen years, and one that was in our original four-point plan several years ago.

That is the first disappointment: this consultation is terribly late; at least three General Elections or referenda have happened without benefit of the increased transparency this proposal would have provided if enacted. 

The above is the first of the obvious disappointments. Still, better late than never.

The second obvious disappointment is that the proposals fail to deliver what voters really want in electoral advertising: not just advertising where it’s clear who is behind it – that is, after all, a bare minimum in any other advertising and anyway required by law – but advertising that does not permit the kind of misleading statements that have so besmirched electoral advertising over at least the past twenty years.

That oversight, or deliberate omission, as the case may be, is an obvious disappointment because the regulation of the content of electoral advertising is an issue on which we have campaigned for some years and because it’s so blatantly the right thing to do – for voters, for politicians and for the whole electoral process and therefore for democracy.

While, as with the other disappointment above, that would appear to be an obvious case, we commissioned YouGov research specifically for this consultation that found that 64% of voters thought it very important that …’it is clear which political party is responsible for an advert’ but that 77% thought that…’political parties’ adverts do not make false or misleading claims.’

This finding, in case it suffers from the inevitable accusation of research findings suiting those who paid for them, is supported by two other pieces of evidence:

‘As with traditional campaign materials, identifying a trustworthy source was important in establishing the credibility of a message. However, although identifying a trusted source helped to reassure participants that campaign material was bona fide, this did not always mean that they believed the information contained in the message. This is because there is a distrust of campaign messages and statements made by politicians more generally.’

And

‘The core concern for participants throughout the research was the believability and trustworthiness of the content they consumed during election campaigns.’ (emphasis per the research document).

  • A study we commissioned in December 2019, which found that 87% of voters thought that ‘it should be a legal requirement that factual claims in political adverts must be accurate.’ We conducted a very similar study in December 2018, when the level was 83%. Both pieces of research from YouGov. 

The third disappointment is rather less obvious. This should be an entirely straightforward exercise: an extension of the identification regime that exists in electoral print advertising into the online space. Such an exercise should surely not tax, as it were, the Cabinet Office? 

We do not particularly recommend the reading of the consultation document itself, linked above. It’s not exactly a page-turner, but these processes are not intended to produce a rattling good yarn: just some solid evidence-based thinking, clearly articulated, on how the government plans to go about this workaday exercise. 

Where it deals with the matters specific to the online identification process that it sets out to deliver, the document fails on four counts: it fails properly to define two different aspects of scope, it practically guarantees inconsistency in application, it pays no attention to what voters want in execution of this process, and some aspects of its drafting should make the Cabinet Office blush if they were capable of displaying such humility. You can read our full response, should you wish, here.

But the deep and central flaw of the proposals in this consultation is that it is simply not possible to address the scope of the imprint extension proposals and the maelstrom of advertising in the digital world without recognizing that who advertisers are is inevitably and directly connected with what they say. Indeed, what they say often identifies who they are. It is only the combination of regulatory measures – identification and material content – that will deliver to voters and to democracy.  

At least the government might have got the Identification measure right, but on the evidence of this consultation, apparently not even that could be managed.

The Coalition For Reform In Political Advertising


We are not for profit and are run by unpaid volunteers. We rely on donations to continue our work. Please donate to our campaign here.

Our reaction to the Government’s response to the House of Lords report Digital Technology and the Resurrection of Trust

The Coalition for Reform in Political Advertising replies to the Government Response to the House of Lords Democracy and Digital Technologies Committee Report on Digital Technology and the Resurrection of Trust

1. Context and background

In June 2020, the House of Lords Democracy and Digital Technologies Committee, after more than 18 months of Covid-affected work, evidence from more than 200 sources and leadership from one of the UK’s (and the world’s) most significant media figures Lord Puttnam, published ‘Digital Technology and the Resurrection of Trust’

A primary recommendation from the Report (para 36) stated: ‘The relevant experts in the ASA, the Electoral Commission, Ofcom and the UK Statistics Authority should co-operate through a regulatory committee on political advertising. Political parties should work with these regulators to develop a code of practice for political advertising, along with appropriate sanctions, that restricts fundamentally inaccurate advertising during a parliamentary or mayoral election, or referendum. This regulatory committee should adjudicate breaches of this code.’

The Coalition for Reform in Political Advertising (CRIPA), authors of this note, provided evidence to the House of Lords Committee and strongly supported the recommendation outlined above.

2. The Government Response and CRIPA’s reaction

The Government’s Response to the Report has recently been published. This note addresses in particular the Government response to the recommendation set out above. Piecemeal below is the government’s verbatim (and in full) position on the recommendation; the italicised type re-states the government view, the regular type the Coalition’s response.

Democracy must work for the people and robust debate is fundamental, so reaching out to all of our citizens, and empowering them to engage, only makes our democracy stronger. As part of that, it is important that political parties and other campaigners are able to connect with voters. Having an active online presence is crucial to facilitating engagement with new audiences. However, we also recognise that there are legitimate concerns around the exploitation of online platforms, which is being addressed through our work to counter disinformation and online manipulation.

This government statement above is irrelevant to the House of Lords recommendation, as it fails entirely to address the issue highlighted in the report, which is actually and obviously to do with political advertising, not ‘an online presence.’ This distinction seemed clear enough in the recommendation itself, which refers to ‘advertising’ three times. The government reference above to ‘our work to counter disinformation and online manipulation’, while not explained, we take to mean the Online Harms White paper, already at least four years late and also devoid of any reference to political advertising. Additionally, in the context of the considerable endeavour from the House of Lords team and all those who provided evidence, the Government statement above seems platitudinous, trite and patronising in the extreme.

2.1. An answer to a different question

Transparency around who is promoting material online and how this is targeted is a key part of facilitating scrutiny of political messages and equipping people with the right tools to participate and make informed decisions. The government is committed to promoting transparency around political advertising and is bringing in new rules that will require election material promoted online by a party, candidate or campaigner to explicitly show who is behind it.

Whilst more relevant, this government response again fails to address the key issue, i.e. the inaccuracy of electoral advertising, not identification of its source, nor inaccuracy of such identification. It is entirely clear to the Coalition and no doubt most others that the Cabinet Office consultation ‘Transparency in digital campaigning’, to which the government response above presumably refers, appears to be, ironically, itself a smokescreen that fails to address voter concerns about the content rather than the source of electoral political advertising.

2.2. Another answer to a different question

However, policy or political arguments – both online and offline – which can be rebutted by rival campaigners as part of the normal course of political debate are not regulated and the government does not support such regulation.

The government is not being asked to support ‘such regulation’ when that is supposedly to do with ‘policy or political arguments both online and offline.’ The recommendation does not propose that such arguments are regulated. Indeed, we can be reasonably certain that the authors of the House of Lords report, politicians themselves, would be alarmed by the idea that political debate of the type outlined in the government response should be regulated. The recommendation relates to political advertising, not political debate, though of course we understand that the Government is being deliberately obtuse in its failure to distinguish between the two.

2.3. The abdication of responsibility

It is a matter for voters to decide whether they consider materials to be ‘accurate’ or not.

It is? So the government recommends that political parties should abdicate responsibility for accuracy in electoral political advertising statements? Does the government hold the same view, for example, for the government’s Coronavirus advertising? And voters should be able to know, for example, when an opinion poll published by a political party is pure invention? When a claim that departure from the EU would mean £350 million p.w. to the NHS? The idea that the voter should decide whether the government or political party statistics in advertising are accurate is either grossly irresponsible or ridiculous. There is no refuge between those positions.

2.4. A vested interest masquerading as a moral principle

It would have a chilling effect on freedom of speech to have political campaigning ‘pre-vetted’ or censored during an election or referendum campaign.

Again, the government description of ’pre-vetting’ or ‘censoring’ political campaigning does not reflect the House of Lords recommendation; nobody has made such proposals, albeit we understand that it is convenient for the government to suggest that they have. We suspect that the above government response might be more truthfully articulated as ‘a chilling effect on political parties’ ability to lie to the electorate in their advertising’.

The whole process would no doubt be subject to vexatious and politically motivated complaints; such contention is why political advertising has not been subject to codes of advertising practice since 1999.

The statement above does not bear much scrutiny, though it is again revealing. First, It is unclear why the process ‘would no doubt be subject to vexatious and politically motivated complaints’ whena process has yet to be established. Second, and leaving aside how a contention can provide a rationale, the demise of the ASA’s involvement in electoral advertising is rather more nuanced than the government appears to understand. The ASA remit at the time was related to the rules on denigration and offence. That role is not being proposed in the House of Lords recommendation, which is rather to ‘restrict fundamentally inaccurate advertising’. Further, the full history of this issue should include the Neill Committee on Standards in Public Life recommendation to parliament in 1999 ‘that political parties should establish a code of best practice in partnership with the advertising industry’. Nothing was done, and that is the reason why political advertising has not been subject to codes of advertising practice since 1999.

Finally, in this context, the government appears to be claiming that the lack of political advertising regulation for the past twenty years is some kind of evidence that it can’t be done. It is entirely clear from the wealth, if that is an appropriate description, of misleading electoral material that has been produced in the following years, that the absence of regulation has provided as a result evidence of why it must be re-established.

Political parties have come to understand that they can say what they like in political advertising and it won’t and can’t be challenged by any kind of independent authority, so they say it. That is a different circumstance to a) media or facilitator or audience challenge in live political debate online and offline, and b) the requirements placed on all other advertising. Does the government really believe that only political parties are capable of ‘vexatious and politically motivated complaint’ and that regulators have no experience of dealing with such matters?

2.5. A response to some final cynicism and patronisation from the government

This matter is best ‘regulated’ by an independent free press, alongside the laws on defamation and the long-standing electoral offence of false statements about a candidate.

By definition, an ‘independent free press’ should not and cannot ‘regulate’ electoral advertising, unless of course it is along the party political lines that the government might desire. Could it possibly be the case, for example, that The Guardian may take a different line on any political statement (in any channel) to The Sun? (Electoral Commission research in 2019 found that when people were asked to prioritise their concerns about the election from a list of issues, 67% of people said ‘media bias’ was a problem.) As for the ‘laws on defamation and the long-standing electoral offence of false statements about a candidate’, the government might like to cite when these were last deployed against party political advertising, famous for its false statements on just about everything.

We conclude by re-stating the case for the House of Lords recommendation:  absence of any kind of regulation of material statements in electoral advertising has led to gross abuse by all political parties; proof if proof were needed from our review here, and from countless other sources over the years.

The government response to the Recommendation from the House of Lords is defensive and evasive; it attempts to paint a clearly reasonable proposal as an attack on free political speech. It is no such thing: this is a simple and evidence-based proposal that in electoral advertising – the only channel that is not ‘regulated’ by formal or informal real time intervention, and political parties the only unregulated advertiser – that there should be some means to prevent the extreme and obvious (if not to the electorate) untruths from happening.

The Coalition For Reform in Political Advertising

Follow us on Twitter for regular campaign updates. 

We are not for profit and are run by unpaid volunteers. We’ve made great progress with our campaign to date but we still have a significant task now to engage with various stakeholders to ensure that political advertising is regulated as this post demonstrates.  We rely on donations to continue our work. Please donate here. We are very grateful for your support. 

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2019 Election advertising

Over the next few weeks, with the help of a number of volunteers, we will be identifying paid advertising that appears to be misleading and contacting the parties concerned asking them to justify the claims, or amend or withdraw them. As visitors to this website will be aware, political advertising is currently unregulated and it seems like it’s way beyond time at least to ask political parties to observe the same rules that all other advertisers are required to observe, i.e. to be Legal, Decent, Honest and Truthful.

Unless misleadingness is blatantly obvious, we will be referencing various fact-checking sources where those have ‘ruled’ on the issue. Examples of misleading advertising will be posted on the website: we hope that these pages will become a central reference source of misleading political advertising and, more importantly, encouragement to political parties to think harder about the claims they are making in advertising. Everyone else has to.