What is an unincorporated association?

An unincorporated association is a type of organisation that can donate to a political party, such as a members club or a group of councillors.

On 17 July 2025 the government released its policy paper, Restoring trust in our democracy: Our strategy for modern and secure elections, which outlined the framework of a new elections bill to be brought forward in this parliament.

The paper had many stated aims, one of which was “protecting our elections against interference”, by “strengthening the rules around donations”. One of the reforms posited was tightening the rules around unincorporated associations.

The Representation of the People Bill had its first reading on 12 February 2026 and its second reading on 2 March 2026. Clause 62 outlines the amended provisions relating to unincorporated associations.

What is an unincorporated association?

An unincorporated association is “an association of individuals who have come together to carry out a shared purpose”, according to the Electoral Commission.

An unincorporated association has:

1. an identifiable membership which is;
2. bound together by rules or an agreement between members, though this;
3. may or may not be formalised (for example in a written constitution).

Examples of unincorporated associations are members’ clubs, political dining clubs or groups of councillors.

An unincorporated association is allowed to make donations to political parties and other regulated political campaigners, as long as it is based in and carries on business or other activities in the UK.

The Electoral Commission political finance online database shows that donations from unincorporated associations total nearly £64 million since 2001. This represents 3.9% of all donations recorded on the database during that period.

In its 2021 review, Regulating Election Finance, the Committee on Standards in Public Life commented that:

most of the major political parties have fundraising groups or clubs which are [unincorporated associations], while other unincorporated groups have appeared which have a less obvious link to any party

For more information on donations see House of Commons Library briefing, Political financing: Donations, loans and state funding.

How are unincorporated associations currently regulated?

When an unincorporated association makes political contributions of more that £37,270 in a calendar year, it must register with the Electoral Commission. There are currently 15 unincorporated associations held on the Electoral Commission’s register.

Political contributions are considered to be:

• a donation or loan to a registered political party
• a donation to a registered non-party campaigner
• a donation to a registered referendum campaigner
• a donation to a registered recall petition campaigner
• a donation or loan to a regulated donee, which is:
  • a holder of elective office
  • a member of a political party
  • a group of party members (also known as a members association)

Electoral law states that the Electoral Commission must be informed within 30 days of the contribution date which took the total over the £37,320 threshold.

Once registered, unincorporated associations have to disclose all the reportable gifts they received in the calendar year prior to, of, and following the contribution which took the UA over the £37,320 threshold. Gifts include:

• donations of money or property
• bequests
• subscription/affiliation fees
• the payment of expenses
• the provision on non-commercial terms of property, services or facilities for the benefit of the association

Reportable gifts are:

• a single gift more than £11,180
• two or more gifts given which aggregate to more than £11,180 in a calendar year (though gifts under £500 do not count towards this total)
• additional gifts given by a source which has already been reported as giving a gift if the value exceeds £2,230

Once registered an unincorporated association must report these gifts quarterly.

Offences related to unincorporated associations

There are three offences under electoral law. They are:

• when an association fails to give notice/report to the commission within relevant timeframes (without reasonable excuse)
• the report provided by the association does not meet the reporting requirements set out in law (without reasonable excuse)
• the declaration is false

For detailed guidance see the Electoral Commission website: When does an unincorporated association have to register with us?

What concerns have been raised about unincorporated associations?

Unincorporated associations were raised as a point of weakness in the Hayden Phillips Review of political financing, which was instigated by the loans-for-honours affair following the 2005 general election. And, as a result of this, the current transparency/registration regime for unincorporated associations was (largely) set in place in the Political Parties and Elections Act 2009.

However, concerns remained and on 27 February 2019 a Westminster Hall Debate dedicated to UAs was held. In it, debate sponsor Martin Docherty Hughes (SNP), asked of the then Cabinet Office Minister Chloe Smith:

Why, given all the ways in which individuals and organisations can donate money to political parties and groups in a transparent and straightforward manner, do we still allow this backdoor method, which seems to me to be easily exploited by those who would seek to obscure the provenance of funds?

In response, Chloe Smith said:

The Government believes that the rules governing permissible donors and the reporting rules for unincorporated associations are sufficiently comprehensive. The permissible donor rules capture the groups that operate in this area, and the relevant reporting rules provide appropriate transparency, but do not swamp these often small organisations in red tape, which is a consideration. The Government therefore have no plans to amend the law.

In its 2021 review, Regulating Election Finance, the Committee on Standards in Public Life took evidence on the regulation of unincorporated associations. The committee noted that:

There is nothing inappropriate in [unincorporated associations] being donors but establishing their status is difficult as [an unincorporated association] is not a hard-edged legal entity.

It reported that the Electoral Commission identified two vulnerabilities with the current regulation:

1. That those who give to unincorporated associations are not required to be permissible donors which means that “they could legitimately receive money from overseas sources and donate that money to political parties”.
2. No transparency is required from unincorporated associations that donate to candidates as opposed to parties, and it knew of one unincorporated association that funded a number of candidates at the 2019 general election.

They also took evidence from anti-corruption organisations such as Spotlight on Corruption and Transparency International UK who advocated for reducing the level at which unincorporated associations report political gifts to £500.

However, in a written submission the Conservative Party said:

Smaller, voluntary sector organisations tend to be set up as unincorporated associations. It is healthy for democracy for parties to raise money from such small-scale fundraising. But, as a consequence, heavy-handed compliance regimes (that might be suitable for ‘big business’) is not in the public interest and undermines democratic participation.

The committee ultimately made three recommendations related to unincorporated associations:

1. PPERA should be amended to require unincorporated associations that meet the threshold for registration with the Electoral Commission to conduct permissibility checks on relevant donations (which are those that are intended for political activity).
2. The government should amend the law to simplify disclosure requirements that apply to unincorporated associations. The rules should provide greater transparency around political gifts made to unincorporated associations donating more than £25,000 (now £37,320) in a calendar year and should be straightforward and simple to comply with.
3. The law should be amended such that disclosure requirements apply when unincorporated associations provide donations to candidates.

What measures are in the Representation of the People Bill?

The government’s policy paper published in June 2025 argued that unincorporated associations “are a potential route for foreign or otherwise illegitimate money to enter electoral campaigns and therefore are a point of vulnerability”.

Clause 62 of the Representation of the People Bill makes a number of provisions regarding the unincorporated association regime, they are to:

1. extend the transparency requirements to include unincorporated associations that make contributions to candidates;
2. make minor amendments so that only donations made for political purposes are included;
3. reduce the threshold for which UAs have to report political contributions from £37,270 in a calendar year to £11,180;
4. require unincorporated associations that are subject to reporting requirements to appoint a responsible person;
5. prohibit unincorporated associations subject to reporting requirements from making political contributions from gifts received from impermissible donors;
6. reduce the threshold value of gifts UAs have to report from £11,180 to £2,230;
7. require unincorporated associations to report additional information about donors who have given them gifts used for political purposes.

The Electoral Commission released a detailed media briefing after the bill had its first reading on Thursday 12 February, they said the reforms to unincorporated associations represented “a key and proportionate change to the system”.

During the second reading debate Zoe Franklin (Liberal Democrat), said that the Liberal Demoicrats welcomed the “measures in the Bill that protect our democracy from the corrupting influence of dark money”. She pointed to the reforms to unincorporated associations as an example of this, but said that the Liberal Democrats “will call for further important changes to strengthen the bill in this area”.

Lauren Edwards (Labour) said that the bill “takes welcome steps to prevent unincorporated associations from being used to conceal donations from impermissible sources, and to reduce the level at which they must register with the Electoral Commission and report gifts”. However she also argued that reporting thresholds remained “unnecessarily high” and advocated to reduce “the reporting threshold for unincorporated associations to £500—equal with the permissibility threshold”.

Neither Labour minister speaking in favour of the bill mentioned the provisions on unincorporated associations.