Election Practices: A Cross-National Overview

We should recognize that the recent Senate Special Election reflects the strengths and weaknesses of U.S. campaign system. Highlighting the campaign process of culturally similar industrialized countries can help to shed light on alternative campaign practices and spending on elections. Two of our European allies have a comprehensive election system like the United States but similarities change after that. Both the United Kingdom
and Germany permit government and private funding under a managed system of regulations.

The current law regarding campaign financing in the United Kingdom is contained in two acts the Representation of the People Act 1983 (RPA) and the Political Parties Elections and Referendums Act 2000 (PPERA). The UK system of regulating campaign financing focuses on limiting the expenditure of political parties and individual candidates, rather than limiting the donations that can be received by these parties and individuals. There are three types of election regulations: 1) To promote a party or its policies; 2) Expenditures incurred by a third party; and 3) Election expenditures incurred on promoting a specific candidate. The party that wins the most seats in at the general election (Parliament) forms the government. Allocation of 2 million pounds (4 million dollars) is made to eligible parties based on legislation by party size from the Electoral Commission. Parities can collect funding from citizens, corporations, and associations registered with the EC. The 2005 election in the U.K. saw the Conservative and Labor Parties receiving most of the financing, with the Liberal Democrats taking the balance.

On the other hand, the political parties are the main players in the German election process rather than the individual candidates or members of Parliament. Germany elects the Federal Diet, the federal legislature, by popular vote every 4 years. The members of the Federal Council, The other chamber of the federal legislature, is appointed by the state government. The length of election campaigns is not defined by federal law. Germany has provided public funding to the political parties in every election since WWII. The Federal Constitutional Court has frequently ruled on the fair distribution of government funds to the parties and on the tax treatment of private donations, thus causing frequent changes in legislation. Parties receive funds in proportion to the latest election results plus a matching fund consisting of private donations. Financial statements must be submitted to the legislature on a yearly basis. Individuals may deduct 50 percent of their donations from taxable income or claim a tax credit. There are no limits on private or corporate contributions. The disbursement of funds is based on Euros, and a party may not receive more public annual funds than it has earned or otherwise generated during the year. Private funding of political parties is also encouraged, as a counterweight to heavy government funding. Private donations must be disclosed immediately. Donations from charitable organizations and from trade unions, professional associations, and industrial or commercial associations are prohibited.

Back in the U.S., I expect that the recent Supreme Court decision lifting the ban on corporate campaign spending will create havoc and contribute to more head butting elections in the near future.