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Comparative Summary

This report discusses the regulation of campaign financing and spending in national elections and the availability of free airtime for campaign advertising in Austria, Canada, Finland, Israel, Japan, New Zealand, and the United Kingdom. Specifically, the individual country surveys address the following issues:

  • The extent to which each country applies limits on the amounts that can be contributed to political parties and candidates;
  • The existence of ceilings on campaign expenditures; and
  • The availability of free airtime for broadcast advertising.

Countries included in this study demonstrate different models used in regulating campaign financing. Canada, Israel, and Japan limit both campaign contributions and expenditures. The laws of Austria, New Zealand, and the United Kingdom impose spending limits on individual candidates and political parties, but few limitations on donations. Finnish legislation provides an example of a system where caps are put on contributions but not on the money spent in election campaigns. Countries that allow both unlimited donations and campaign spending were not included in this report.

While Austria, New Zealand, and the United Kingdom do not generally impose limits on campaign contributions from domestic donors, there are limits on donations from foreign sources. Such limits also exist in Israel and Finland. The donation limits in Canada, Finland, Israel, and Japan apply to different categories of donors and also vary depending on whether the recipient is a party or candidate. In Israel, different rules are applicable for primaries and national elections.

With regard to campaign expenditures, Finland appears to be the only country surveyed that does not impose restrictions. All other countries apply certain types of monetary limits on campaign- related spending. Japan applies different restrictions depending on what house of the legislature a candidate is standing for and the applicable electoral system. Japan is also the only country surveyed, apart from Finland, where there are no spending limits for political parties.

Canada, Israel, Japan, New Zealand, and the United Kingdom are identified as countries that allocate free campaign broadcasting time to both parties and candidates. The specific formulas or rules for allocation of free airtime are provided in the surveys for these countries; except for Japan, where no specific formula for such allocation is provided by law.

Although a special free allocation of airtime has not been identified for Finland, Finish political parties may use their allocated public funding to pay for airtime on commercial media outlets. Public funding for broadcast advertising by political parties is also provided in New Zealand. No specific provisions were identified in the Federal Act on the Austrian Broadcasting Corporation about media access or free airtime.

Additional  details  are  provided  in  the  chart  below,  which  compares  campaign  financing regulations on donations, expenditures, and free airtime allocation in the surveyed countries.

Table: Country Comparison of Donation Limits, Spending Limits, and Broadcasting Time

Country Donation Limits Spending Limits Broadcasting Time
Austria

In general no limits, but provinces may enact stricter rules.

Federal Presidential candidates:

€7 million. Political parties:

€7 million (about US$7.6 million). Individual candidate’s spending counts toward party limit unless sum does not exceed €15,000 (about US$16,300).

No specific provisions in Federal Act on Austrian Broadcasting Corporation.

Canada

Political parties & candidates:

Up to $1,525 per calendar year.

Candidates:

Calculated according to formula involving number of electors in the district, geographic size of district, length of election period, and an inflation adjustment factor.

Political parties:

Calculated using formula that involves the number of electors in districts in which a party has candidates, length of election period, and an inflation adjustment factor.

Others(individuals, corporations, or groups not standing in election):

Can$150,000 (about US$112,880) “base limit” on election advertising by third parties in 37-day election period, with base limit of Can$3,000 in particular electoral district. Increased if election period exceeds 37 days.

Free time by certain networks at least at level provided in last election.

Two minutes to each registered/newly eligible party that does not acquire paid broadcasting; remainder allocated in proportion to paid- time distribution (up to 6.5 hours) as determined by unanimous agreement among parties or decision of broadcasting arbitrator under statutory formula.

Finland

Candidates for Finnish Parliament:

Up to €6,000 (US$6,500) per election from same donor; unlimited from party and party organization provided amount does not include contributions received from donor exceeding cap.

Presidential candidates: No limit.

Political parties:

Up to €30,000 (US$33,000)

from same donor per calendar year.
None. Political parties may use allocated public funding to pay for airtime on commercial media outlets.
Israel

Primaries:

Limits generally based on number of eligible voters and position for which candidate competes.

National Elections: Candidate list or faction that notified of its intention not to receive government funding may receive higher amounts.

Calculated according to formula involving multiplication of set monetary amount by number of Knesset (Parliament) members a faction has on specified date.

Free broadcasting time to each participating party and candidate list during fourteen days prior to elections based on formula (fixed amount, extended by time corresponding to number of members party/ list had in outgoing Knesset).

Japan

Annual limits on individuals’ donations:

Per candidate: 1.5 million yen (about US$13,000), up to 10 million yen (about US$90,000).

To political parties: 20 million yen (about US$180,000).

Corporate & other nonpolitical donations permitted only for parties and political funding organizations, not to candidates, subject to annual caps depending on donor organization’s size. Annual limit ranges from 7.5 million yen (about US$66,000) to 10 million yen (about US$90,000).

No limit on donations by political organizations to a political party or funding organization.

House of Councillors candidates chosen by proportional representation: 52 million yen (about US$458,000).

House of Councillors candidates in plural-seat districts: limit calculated using formula involving number of voters in the district and the number of elected members, plus a base amount.

House of Representatives candidates in single-seat districts: limit calculated using formula involving similar aspects as for the House of Councillors formula.

No limit for House of Representatives candidates chosen by proportional representation as all campaigning is for the party rather than individual candidates.

Free airtime at major broadcasting stations for political parties with candidates and for candidates of small districts of House of Councillors/House of Representatives.

New Zealand

Generally no limits on donations to candidates or parties from NZ-based sources. An anonymous donation or overseas donation to candidate or party cannot exceed NZ$1,500 (about US$990).

In 3 months before election:

Candidates:

NZ$26,100 (about US$17,240).

Parties:

NZ$2,964,100 (about US$1,959,000), if have candidates in all 71 electorates.

Others(individuals, corporations, or groups not standing for election):

NZ$313,000 (about US$207,000).

Parties allocated public funding for radio and television advertising and free airtime for opening/closing addresses.

Candidates may spend up to spending limit.

United Kingdom

No limits on donations from “permissible donors” (UK- based).

Nonresident donors limited to £7,500 (about US$10,000) to a party.

Candidates:

  • Long campaign (starts 55 months from time Parliament first met, ends on date of dissolution of Parliament, when short campaign generally begins):£30,700 (about US$43,700) plus 9p (about $US0.13)  per voter in rural constituencies and 6p in borough seats.

  • Short campaign: Limits reduced to £8,700 (about US$12,380) plus 9p per voter in rural constituencies & 6p in borough seats.

Parties:

Either £30,000 (about US$43,000) per constituency/seat contested or maximum amount for each part of UK, whichever is greater.

Others (individuals or groups not standing in election):

Up to £500 (about US$700) to promote or disparage candidate.  In 365 days before election, “recognised third parties” can spend up to £319,800 (about US$456,000) in England, £55,400 (about US$79,000) in Scotland, £44,000 (about US$63,000) in Wales, and £30,800 (about US$44,000) in Northern Ireland.

Free airtime on national television and radio allocated to parties based on formula determined by independent communications regulator.

Source: Compiled by Ruth Levush based on information provided in this report, as reflected in individual country surveys.

 

Prepared by Ruth Levush
Senior Foreign Law Specialist
March 2016

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Last Updated: 05/16/2016