Electoral Reviews: Policy and Practice 2025
Foreword
The Democracy and Boundary Commission Cymru etc. Act 2013 (“the 2013 Act”) requires the Democracy and Boundary Commission Cymru (“the Commission”) to review the electoral arrangements for each principal area in Wales at least once every 12 years.
Before carrying out a review of the electoral arrangements for a principal area (which the Commission describes as an “electoral review”), the Commission is required to consult certain specified bodies (known as “mandatory consultees”) on its intended procedure and methodology for the review, and in particular on how it proposes to determine the appropriate number of members for any principal council in the principal area or areas under review. The Commission consulted on its Policy and Practice document from February 11 2025 to March 24 2025 and received responses from principal councils across Wales. After considering the responses the Commission has updated its document and has produced this final version.
This document sets out the Commission’s procedure and methodology and council size policy for the programme of electoral reviews which must be carried out during the 12-year period which started on 30 September 2023. The reviews will start in May 2025, and thus the Commission refers to this cycle of reviews as the “2025 programme”.
Beverley Smith
Chair
The Commission welcomes correspondence and telephone calls in Welsh or English.
This document is available in Welsh.
Background
The Commission is required to carry out periodic reviews of the electoral arrangements of principal areas in Wales. These reviews are described in this document as “electoral reviews”. The way the Commission conducts an electoral review is defined by legislation and may be guided by directions issued by Welsh Ministers.
This document sets out the Commission’s procedure and methodology and council size policy for the programme of electoral reviews which must be carried out during the 12-year period which started on 30 September 2023 (and which is known as the “2025 programme”).
Statutory Requirements
The Democracy and Boundary Commission Cymru etc. Act 2013
The 2013 Act requires the Commission to review the electoral arrangements of principal councils in Wales. The 2013 Act has recently been amended (and given its new name) by the Elections and Elected Bodies (Wales) Act 2024 .
Section 21(3) of the 2013 Act provides that the Commission in carrying out its duties must seek to ensure effective and convenient local government. This is the paramount and primary function of the Commission.
Section 29 of the 2013 Act lays upon the Commission the duty to review the electoral arrangements for each principal area at least once in every 12-year review period.
The purpose of an electoral review is to consider whether changes should be made to the electoral arrangements of the principal area. At the outcome of the review, the Commission will recommend changes which it considers appropriate to those electoral arrangements (or will recommend that no changes are made). The Commission’s recommendations are made to the Welsh Ministers, who then decide whether to implement changes recommended by the Commission (with or without modifications).
In this context, the “electoral arrangements” of a principal area are defined in Section 29 (9) of the 2013 Act as:
the number of members of the council for the principal area;
the number, type and boundaries of the electoral wards into which the principal area is for the time being divided for the purpose for the election of members;
the number of members to be elected for any electoral ward in the principal area; and
the name of any electoral ward.
When the Commission recommends changes to electoral arrangements at the outcome of an electoral review, it may also recommend consequential changes to the boundaries, council and/or electoral arrangements of a community within the area under review, as well as consequential changes to the area of a preserved county (Wales is split into eight preserved counties. They are areas used for the ceremonial purposes of lieutenancy and shrievalty).
Considerations for a Review of Principal Area Electoral Arrangements
When carrying out an electoral review, the Commission is required by Section 30 of the 2013 Act to have regard to the following factors-
the desirability of having a ratio of local government electors to the number of members of the council to be elected that is the same, or nearly the same, in every electoral ward of the principal area (which the Commission refers to as “electoral parity”);
special geographical considerations, including in particular the size, shape and accessibility of an electoral ward; and
any local ties (including local ties connected to the use of the Welsh language) that would be broken by changes to the electoral arrangements in the area.
When the Commission takes into account considerations of electoral parity (within the meaning of point (a) above), the Commission is also required to take into account:
any discrepancy between the number of local government electors and the number of persons that are eligible to be local government electors (as indicated by relevant official statistics); and
any change to the number or distribution of local government electors in the principal area which is likely to take place in the period of five years immediately following the outcome of the Commission’s electoral review.
Balance
The Commission’s task is to exercise a balanced judgement taking into account all relevant considerations, with a view to making recommendations for electoral arrangements that will achieve effective and convenient local government.
In an ideal situation, it would be possible to devise a pattern of electoral ward boundaries in which all electoral wards in a principal area had an equal ratio of electors to councillors, which brought together people in clearly identifiable communities, demonstrated clearly how local government would be both effective and convenient, and resulted in the appropriate number of councillors.
The geographical, social, economic and administrative make-up of Wales is however not so straightforward as to facilitate the drawing up of ideal electoral patterns. This means that the Commission must consider all relevant factors and exercise a judgement with a view to achieving a pattern of electoral wards which is as close as possible to the ideal described above. Achieving a structure that ensures effective and convenient local government is paramount.
Timetable
The Commission’s timetable for the 2025 programme of electoral reviews can be found at Appendix 1.
Section 36B(2) of the 2013 Act requires the Commission to use its best endeavours to publish its final report in an electoral review within 12 months of starting the review.
Council Size Policy
For the 2025 programme the Commission has allocated each principal council a range within which the total number of councillors for a council should fall. Details of the methodology followed by the Commission and the appropriate range of councillor numbers for each principal council are set out in Appendix 2.
Should a principal council not agree with the range allocated by the Commission then the Commission will require a well evidenced argument to be submitted prior to the start of the review. The Commission has developed a template document which can be used to help shape this and the document is available on the website. The Commission will consider any submissions on a case by case basis.
Procedure
The procedure for conducting electoral reviews is set out in Chapter 4 of the 2013 Act and is summarised in the following sections.
Pre-review Procedure
The Commission will designate a Lead Commissioner for each electoral review, whose role will be to lead the Commission’s staff through the review and who will present proposals and recommendations internally for the Commission’s collective consideration and approval.
Before conducting an electoral review, the Commission will require that the principal council for the area under review provides electorate data and five-year forecasted electorate figures, in each case broken down to community ward level. The technical advice note in Appendix 3 to this document provides guidance for principal councils on the Commission’s requirements and on how forecasted electorate figures can be produced.
The Commission is also required at the start of the review to take such steps as it considers appropriate to bring the review to the attention of members of the public affected by the review, the mandatory consultees and any other person it considers likely to be interested in the review. If any directions have been given by the Welsh Ministers which are relevant to the review, then the Commission is also required to make the mandatory consultees and such other interested persons aware of these.
For these purposes, the “mandatory consultees” are defined in Section 34(3) of the Act as:
any local authority affected by the review;
the police and crime commissioner for any police area which may be affected by the review;
any fire and rescue authority constituted pursuant to the Fire and Rescue Services Act 2004 for an area in Wales which may be affected by the review;
the National Park authority for a National Park in an area affected by the review,
the Port Health authority constituted under section 2 of the Public Health (Control of Disease) Act 1984 (c. 22) for a port health district in an area affected by the review,
the Welsh Language Commissioner
any organisation representing the staff employed by local authorities which has asked to be consulted; and
such other persons as may be specified by order made by the Welsh Ministers.
Prior to the planned start of the review programme the Commission will provide online briefing sessions about the review process that can be attended by any interested parties. These briefings will describe the Commission’s practice and procedures when carrying out electoral reviews.
Initial consultation and investigation
At the official start of an electoral review the Commission will publish a statement specifying the date on which the review begins, as required by section 36B(1) of the 2013 Act.
The Commission will also communicate with the principal council under review, all the town or community councils in the area, the Members of Parliament and Members of the Senedd for the local constituencies and other interested parties as well as the mandatory consultees listed above to inform them of the review and to request preliminary views on the issues to be considered in the review.
The Commission will issue press releases about the review to publicise the review to the media.
The initial consultation period, during which anyone with an interest in the review can submit initial views to the Commission, will last for 6 weeks.
Draft Proposals
Following the end of the initial consultation period, the Commission will consider the representations it has received and will publish draft proposals for consultation. The Commission will write to the principal council under review, all the community councils in the area, the Members of Parliament and Members of the Senedd for the local constituencies and other interested parties as well as the mandatory consultees to inform them of the draft proposals and to request their views. The Commission will also issue press releases about the proposals and provide publicity material that it will request both the principal council and town and community councils distribute in appropriate places, such as public libraries, town and community notice boards, websites and council newsletters etc in order to raise the profile of the review and to encourage public engagement.
Following the publication of the Draft Proposals Report there will be a consultation period, lasting 6 weeks, during which representations in relation to the draft proposals can be submitted to the Commission.
During this consultation period the Commission will offer an online briefing to the officials of the principal council under review to discuss the draft proposals and the next stages of the review.
Further Consultation
Following the period of consultation on the Commission’s draft proposals, the Commission will consider the representations it has received and prepare its final recommendations. The Commission’s final recommendations may be the same as the proposals in the Commission’s Draft Proposals Report, or the Commission may change its proposals in the light of the representations it has received and make recommendations in its final report reflecting those changed proposals.
However on occasion, after it has received representations, the Commission may wish to bring forward changes to the electoral arrangements of the area under review which are so different from the proposals in the Commission’s Draft Proposals Report that the proposed changes amount to new proposals. Where this is the case, the Commission may engage in supplementary consultation in relation to its new proposals.
Any supplementary consultation period will usually last 4 weeks. The Commission will write to the principal council under review, all the community councils in the area, the Members of Parliament and Members of the Senedd for the local constituencies and other interested parties as well as the mandatory consultees to inform them of the further draft proposals, to request their views. The Commission will also issue press releases about the further proposals and provide publicity material that it will request both the principal council and town and community councils distribute in appropriate places, such as public libraries, town and community notice boards, websites and council newsletters etc in order to raise the profile of the review and to encourage public engagement.
Final Recommendations
When the Commission is ready, it will publish its final recommendations in the review (in a report known as a Final Recommendations Report) and submit them to Welsh Government. The Commission will write to the principal council under review, all the community councils in the area, the Members of Parliament and Members of the Senedd for the local constituencies and other interested parties as well as the mandatory consultees to inform them of its submission of recommendations to Welsh Government. The Commission will also issue press releases about the recommendations and provide publicity material that it will request both the principal council and town and community councils distribute in appropriate places, such as public libraries, town and community notice boards, websites and council newsletters etc.
Once the Commission has published its Final Recommendations Report, there is no further opportunity to provide representations to the Commission.
It is then for the Welsh Ministers to decide how they wish to proceed in relation to the Commission’s recommendations. If the Welsh Ministers choose to implement the Commission’s recommendations (with or without modifications) they will do so by making an Order, after waiting for a period of six weeks as required by section 37(3A) of the 2013 Act. During that six week period, anyone with an interest will have the opportunity to submit representations to the Welsh Ministers in relation to the representations.
Matters which the Commission will consider during an electoral review
Typically, electoral reviews present a range of issues and challenges which require a judgement on balance, taking into account matters, in addition to statutory requirements, that include the following:
effective and convenient local government;
electoral parity (number of electors per councillor);
considerations that might justify atypical levels of electoral parity, such as particular community ties;
topography of the land, hills and rivers creating natural boundaries and motorways/railways forming man-made boundaries;
variable factors (such as deprivation, student populations and tourism);
differences between rural and urban areas; and,
community area boundaries and any community ward boundaries – since the Commission will use communities and community wards as the “building blocks” for principal area electoral wards.
The Commission will take into account all of these factors when designing proposals and making recommendations, and invites respondents to consider each of these when submitting representations to the Commission during electoral reviews.
Effective and convenient local government
It is a duty of the Commission to recommend to Welsh Ministers electoral arrangements that are designed to achieve effective and convenient local government for principal councils.
In seeking to ensure effective and convenient local government, the Commission, when considering potential electoral arrangements, seeks to ensure that electoral wards are internally coherent. In the Commission’s view, this means that there are reasonable road links across the electoral ward so that it can be easily traversed, and that all electors in the ward can engage in the affairs and activities of all parts of it without having to travel through an adjoining ward. This may not be the case, for example, if a potential electoral ward boundary amalgamates two communities where a feature such as a mountain or river divides them.
Factors including convenient access to elected members by the electors and people they represent, patterns of settlements and ease of communications within electoral areas will be taken into account.
Electoral parity and Numbers of Councillors
As described above, the Commission is required to take into account the desirability of electoral parity when it carries out electoral reviews. Electoral parity refers to a situation in which the ratio of electors to elected members is the same, or nearly the same, in every electoral ward in the principal area.
The information which the Commission receives about the number of electors in an area will enable it to determine ward boundaries, and numbers of elected councillors for each ward, with a view to achieving electoral parity. The Commission will seek to achieve electoral ratios for electoral wards which are close to the council average, but the Commission nonetheless acknowledges that some degree of variance is inevitable in practice.
The Commission’s policy will be to attempt to achieve a level of variance that is not greater than 20% from the council average for any electoral ward. However, the Commission takes the view that each council is different and that some councils and electoral wards will be able to provide for a better level of electoral parity than others. The Commission will seek to provide the best level of electoral parity for each area under review and will take each case on its merit. The Commission takes the view that departing from the average ratio for the council can only be justified by clear evidence of other balancing factors, such as local ties or other relevant considerations.
Many principal councils have both urban and rural electoral wards. On occasion the Commission has received comments to the effect that urban areas should have proportionately more councillors than rural areas because urban areas present more complex issues. Others have argued that rural areas should have proportionately more councillors because rural populations are more dispersed, and therefore harder to contact. There is no provision in legislation for such an approach. Increasing use of electronic communication methods generally makes no distinction between urban and rural areas. However, there may be exceptions where local characteristics, including topography and the availability of high-speed broadband, lead to an acceptance of a particular variance in electoral ratio for one or more electoral wards.
The Commission has commissioned independent research regarding the workload of County Councillors in Wales. The research shows that the biggest impact on the workload of a councillor is the various cabinet and committee responsibilities, however deprivation also has a large impact on the workload of a councillor. The report can be found on the Commission’s website, and the Commission has taken it into account in determining the approach to its council size policy which is set out above.
As noted above, the 2013 Act places a further requirement on the Commission to take into account “…any discrepancy between the number of local government electors and the number of persons eligible to be local government electors (as indicated by relevant official statistics)”. The Commission relies on the Office for National Statistics (ONS) to provide population figures, on the basis of which the discrepancy between the number of registered electors and the local population can be assessed. However it is often the case that population figures and elector numbers are recorded across slightly different local areas, so the discrepancy can only be the subject of a rough estimate. The Commission will utilise the available statistics as best it can and where it is appropriate to do so.
The Commission’s general aim is that electoral parity in a principal area should improve as a result of an electoral review. This will be informed by the data provided by councils as to current electors as well as five-year electoral forecasts. The Commission will consider and respond to the implications of changes in the number and distribution of electors which are forecast. The Commission looks to councils to provide estimates of electorate changes supported by appropriate evidence. However, in the experience of the Commission the projected figures are often at significant variance with actual changes in the number of electors which occur subsequently, and the Commission will also take this into account in its decision-making (see further below).
Multi-member electoral wards
The Commission considers that multi-member electoral wards are more likely to be effective and convenient in urban areas than in rural areas. In areas of denser population, such as is found in urban areas, it is possible that many of the issues which a councillor may be called upon to address may be broadly similar in nature and may therefore allow multiple councillors to deal with similar issues. The Commission considers that multi-member wards in rural areas would lead to very large geographical areas which will create additional issues to the electors and the elected members such as travel time.
Five-year forecasted figures
The Commission must have regard to five-year projected electorate figures as part of its deliberations when creating proposals and recommendations. As noted above, the Commission requests these projections from the principal council under review. The Commission is aware that projections are not an exact science and therefore while the Commission will have regard to the principal council’s projected figures, the Commission will give greater weight to current electorate figures provided by the council.
Population figures
The Commission will have regard to the population figures that are provided to it by the Office for National Statistics (ONS), as described above. The Commission uses the mid-year estimates of populations for national and local areas. These are based on Census data, updated with information from a variety of sources which are published annually. The Commission will refer in its deliberations to the most recently published mid-year estimate at the time when the electoral review started.
Communities
There can be some confusion over what is meant by the word community. Some may consider it to refer to the street in which they live, others a more broad village area, others much larger areas. All of these are entirely accurate and reflect the lives of people and the differences and similarities of places where we live, work and interact. However, in Wales there is an additional and more technical meaning to the word as the whole of Wales is divided into community areas.
Many community areas have community or town councils. Where a community area has a community or town council then these areas may be divided into wards for electoral purposes. Over two-thirds of Wales’ population is covered by town and community councils.
The Commission will use communities and community wards as its primary “building blocks” making up electoral wards.
The 2013 Act also enables the Commission to recommend changes to community and community ward boundaries as a consequence of changes to the electoral ward boundaries.
Accordingly, the Commission has flexibility as to how it uses the existing communities and community wards as building blocks to create electoral wards. However in creating electoral wards the Commission must have regard to the desirability of fixing boundaries which are and will remain easily identifiable, and the desirability of not breaking local ties (these requirements are considered in more detail below). The Commission will ensure that proposals for significant changes to electoral ward boundaries and for consequential changes to community and community ward boundaries are subject to consultation (either in a draft proposals report or in a supplementary consultation) before being included in a Final Recommendations Report. The Commission will especially welcome representations relating to proposals for changes to boundaries that are supported by clear and relevant evidence.
Easily identifiable boundaries
The Commission will generally use community areas and, where they exist, community wards as the primary building blocks for electoral wards. This in effect means that the boundaries of any proposed electoral wards are usually formed from the boundaries of existing local government areas and as such should be easily identifiable. This does however depend on community boundaries and community ward boundaries being regularly reviewed by the principal council to take account of new developments that cross existing boundaries.
On occasion during an electoral review the Commission may identify changes that have occurred in a local area that might suggest that electoral ward boundaries should be changed, in circumstances where those changes in the area have not yet been reflected in changes to communities or community wards. For example, it may be the case that a large new housing development has been created across existing electoral ward and community boundaries. In these situations, the Commission may consider in the course of an electoral review whether the electoral ward boundaries should be changed so as to be more easily identifiable in light of the changes to the area. If the Commission considers that electoral ward boundaries should be changed in this way, it may also consider whether consequential changes to community or community ward boundaries should be made for the same or related reasons.
Where changes to community or community ward boundaries are considered as a consequence of changes proposed to electoral ward boundaries, the Commission will seek to ensure that these new boundaries are easily identifiable in the same way.
More generally, roads can influence the boundaries between electoral wards or communities, for example if they are the location of shops or community facilities which people visit regularly and where they interact, or if they are the source of community interactions for example in relation to safety, environmental or economic considerations. Alternatively, major highways, rivers or railway lines are often physical barriers marking the boundary between different communities. The Commission will take into account geographic elements such as these in seeking to arrive at identifiable boundaries between electoral units.
Local ties
The legislation requires the Commission to have regard to any local ties which would be broken by changes to electoral arrangements. This may be particularly relevant when proposals are made for new arrangements that divide existing electoral wards. However, such is the complexity of the term “local ties” that people may consider that their area has ties to a number of other areas. It can also be the case that those sharing an interest in the physical maintenance and management of their immediate living environment may consider that their local ties are within quite confined boundaries.
However, the Commission may also receive representations from those who may have an interest in the way their general hospital or secondary school provides services or in the continuation of a large-scale employer and thus identify themselves as also part of a community much wider in extent. This often leads to suggestion of local ties between multiple community areas (whether they have a community or town council or not) and can often bring deep opposition to dividing those areas into 2 (or more) electoral wards where they were previously contained within 1.
Another example of local ties could be that an area identifies itself as a Welsh- speaking area. The Commission takes into account the Welsh language characteristics of an area when conducting an electoral review, and has a general duty to promote the use of the Welsh language. The Commission will utilise census data to attempt to ensure that it does not put forward proposals which would undermine the use of the Welsh language.
The Commission often only hears from respondents who oppose its proposals on the basis that they would break local ties. The Commission also asks that respondents tell it when its proposals do reflect local ties, so that any support for the Commission’s proposals can be taken into account when the Commission decides whether to reflect its proposals in its final recommendations.
In many areas electoral wards will need to be greater in physical extent than individual communities due to considerations of electoral parity. In these instances the Commission will combine 2 or more communities within individual electoral wards.
Electoral ward names
As part of an electoral review, the Commission considers the names of electoral wards in the area under review. The Commission’s general practice will be to recommend changes to the name of an electoral ward if it considers that the name can be improved, whether or not the Commission is also recommending changes to other electoral arrangements affecting that ward.
In the light of the Commission’s duty to promote the use of the Welsh language, the Commission’s general preference will be for electoral wards to bear a single name in the Welsh language which is acceptable for use in English.
The Commission will regard a Welsh-language name as acceptable for use in English if it considers that the name is likely to be recognisable to residents of the same broad area of Wales whose primary language is not Welsh. This may be because (for example) the name is composed of a place name which is the same or similar in Welsh and English or because the place name in Welsh is particularly well-known in the area.
If the Welsh-language name is composed of more than 1 word, the Commission will regard that name as acceptable for use in English only if every word of the name is likely to be recognisable in this way. Accordingly:
if the Welsh-language name incorporates 1 or more place names which are likely to be recognisable in this way as well as a place name which is not, the Commission will not regard that name as acceptable for use in English;
if the Welsh-language name incorporates words which are not place names (for example a geographic designation such as “north”, “south” or “central”) the Commission will usually not regard that name as acceptable for use in English;
however if the Welsh-language name is composed solely of place names which are likely to be recognisable in this way together with a Welsh-language word meaning “and”, the Commission will regard that name as acceptable for use in English.
The Commission will also propose names that aim to avoid the need for mutations in Welsh in order to make names more recognisable.
If the Commission is unable to identify a suitable single name in the Welsh language which is acceptable for use in English in relation to an electoral ward, the Commission will propose alternative names for that ward in Welsh and English.
The Commission will consult with the Welsh Language Commissioner (WLC) in relation to the names of electoral wards in the area which is subject to an electoral review. The WLC is responsible for advising on the standard forms of Welsh place-names. The WLC has convened a Place-names Standardisation Panel to provide recommendations and expert advice in this field. In forming its recommendations, the Panel follows national standardisation guidelines and also gives consideration to the meaning, history and etymology of the place-names, as well as their usage. The WLC has agreed to provide specialist advice to the Commission regarding how electoral ward names should be spelt in official contexts.
The Commission welcomes suggestions as to electoral ward names at all stages of an electoral review.
Representations
The Commission encourages principal councils, town and community councils, elected representatives, interested parties and the general public to make representations and suggestions as part of the process of electoral reviews. The Commission welcomes representations that are based on evidence and facts which are relevant to the electoral arrangements under consideration. The Commission will consider and acknowledge every representation made. If any person or body makes a representation to the Commission and does not receive an acknowledgment, they should contact the Commission to ensure it has received the representation. If your representation is not acknowledged, then it is highly likely the Commission has not received the representation and it will not be considered in the Commission’s deliberations. If you have not received an acknowledgement in response to your representations please get in touch with the Commission.
All representations which the Commission receives will be published on the Commission’s website alongside the Commission’s Draft Proposals and Final Recommendation Reports. To protect the privacy of individuals participating in the reviews, the Commission will take the following approach to redacting personal information contained in the written representations that the Commission publishes.
Representations from public figures and officials (such as councillors, Members of Parliament or Members of the Senedd) acting in an official capacity:
the Commission will publish the name of any public figure or official writing in an official capacity
however, all postal and email addresses, telephone numbers and signatures will be redacted
Representations from members of the public, and from public figures or officials writing in a personal capacity:
the Commission will redact the name and postal address of individuals submitting representations, but will publish the approximate location of the individual’s postal address – that is, by reference to the village, town or city stated
all email addresses, telephone numbers and signatures will be redacted
The Commission will also redact anything in a representation that could be illegal, libellous or both.
The Commission wishes to encourage representations from those with local knowledge of their area to suggest appropriate electoral arrangements to the Commission when a review is being undertaken. The Commission will accept representations by email, letter or via its consultation portal. All communication details will be provided at the start of a review.
Conclusion
An electoral review is an exercise of the Commission’s statutory responsibility, the application of powers given to the Commission, and the use of judgement which the legislation calls for. The Commission’s policies are intended to give confidence in how it will approach the challenges in any review, but do not preclude striking the right balance in the particular circumstances of the communities and principal council under review. The Commission exercises a collective judgment in determining issues in its reviews and the consideration given to the issues and the reasoning adopted will be explained in the Commission’s reports.
May 2025
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