Every legal claim on this page renders from the evidence register — its source passage, pinpoint citation and verification state included.
Electronic and workplace balloting is a new option layered onto the statutory ballot rules unions already run elections and industrial-action votes under. A draft Order and a draft Code of Practice, laid before Parliament on 22 June 2026, add electronic voting, hybrid voting, and — for industrial action ballots only — an in-person workplace vote. A House of Commons committee approved both on 8 July 2026, and the government's own timetable puts the change live in August 2026 — but approval by both Houses and the formal making of the Order were still outstanding when that timetable was published, so nothing below is in force yet.
The government's published implementation timetable schedules electronic and workplace balloting for August 2026, and the duty to inform and strengthened right of access for October 2026 — subject to the required parliamentary approval and commencement steps.
Formal state
Planned — not yet commencedgovernment timetable only — no text yet
“Measures that will take effect in August 2026 electronic and workplace balloting for Statutory Trade Union Ballots Measures that will take effect in October 2026 The trade union measures include: the duty to inform workers of their right to join a trade union strengthening trade unions’ right of access”
Quoted verbatim from the identified source · Plan to Make Work Pay and Employment Rights Act: timeline update (GOV.UK policy paper, updated 15 April 2026), "Timetable for changes being introduced in 2026". This authored restatement is published exactly as recorded in the evidence register.
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fact/era-implementation-timetable
The draft Order and Code of Practice enabling electronic and workplace balloting were approved by a House of Commons delegated legislation committee, with recorded opposition.
Formal state
Matter of recordrecords an event, not a legal provision
Quoted verbatim from the identified source · Hansard, Sixth Delegated Legislation Committee, 8 July 2026, Division 1 (repeated as Division 2 for the Code of Practice). This authored restatement is published exactly as recorded in the evidence register.
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fact/balloting-committee-approval
This page is not about choosing or becoming a scrutineer. Running a statutory ballot is legally reserved to a closed list of approved independent scrutineers, and nothing below names, scores or recommends one. It is about a narrower and, for most unions, more pressing question: would the union's own data be ready if it wanted to use these new methods at all?
The person that question falls to at the Amalgamated Society of Depot and Warehouse Staff (ASDWS) is Sana Qureshi-Holt, the union's membership and data lead. Nothing below assumes ASDWS has decided to run an electronic ballot — only that Sana Qureshi-Holt has been asked what it would take.
Demand 1 of 5
Personal contact channels
The minister piloting the new rules through committee was direct about what comes first — everything else on this page follows from it:
The minister confirmed in committee that unions will need to gather members' personal email addresses or mobile numbers before they can begin electronic balloting.
Formal state
Matter of recordrecords an event, not a legal provision
“As electronic ballots will require the use of personal email addresses or mobile numbers, unions will need to gather that information from their members before they commence.”
Quoted verbatim from the identified source · Hansard, Sixth Delegated Legislation Committee, 8 July 2026, Kate Dearden MP (Parliamentary Under-Secretary of State for Business and Trade). This authored restatement is published exactly as recorded in the evidence register.
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The underlying Code requirement is more specific than "an email address." It has to be genuinely personal — not one the employer or the union itself issues or controls — and both permitted electronic routes depend on it:
Electronic voting requires an eligible voter's unique personal email address or compliant personal mobile number; delivery may be by email, mobile message, or a qualifying internet messaging service. Employer-controlled and union-controlled contact details must not be used; shared or duplicate contact details cannot be used.
Formal state
Laid — not yet in forceofficial text exists; not commenced
“Electronic voting – the independent scrutineer distributes the voting access method to voters electronically. This could be done by sending the voting access method in an email to a personal email address or in a message to a personal mobile telephone number or internet message via a qualifying internet messaging service.”
Quoted verbatim from the identified source · (Draft) Code of Practice on Electronic and Workplace Ballots (laid 22 June 2026), para. 17.a (see also paras. 54-56 and the failure list at para. 158). This authored restatement is published exactly as recorded in the evidence register.
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fact/balloting-evoting-personal-contact
It also has to be unique. The Code exists partly to close the obvious workaround — routing several members' ballots through one shared inbox or one shared phone:
Voting access methods associated with more than one voter must not be sent to the same email address or mobile telephone number — contact details are unique to a single voter.
Formal state
Laid — not yet in forceofficial text exists; not commenced
“The voting access method must be sent to a unique email address or telephone number. a. Only voting access methods associated with a single voter can be issued to a single email address or mobile telephone number.”
Quoted verbatim from the identified source · (Draft) Code of Practice on Electronic and Workplace Ballots (laid 22 June 2026), para. 55. This authored restatement is published exactly as recorded in the evidence register.
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fact/balloting-unique-contact-details
Story event — not a legal step
Sana Qureshi-Holt runs a first check of ASDWS's own contact records against these three rules. The union holds a work email address for most of its Thornebeck Distribution Ltd members — collected for newsletters, years ago — but a personal address or mobile number, the kind the Code actually requires, for barely half.
Demand 2 of 5
Keeping personal and voting data apart
Once a scrutineer holds a member's contact details, the Code requires them to be kept apart from anything about how — or whether — that member voted, linked only by an identifier that reveals neither on its own:
The voter's relevant personal information and voting information must be stored separately, linked through a unique identifier.
Formal state
Laid — not yet in forceofficial text exists; not commenced
“The unique identifier must be associated and stored with both the relevant personal information and the voting information, which must be stored separately.”
Quoted verbatim from the identified source · (Draft) Code of Practice on Electronic and Workplace Ballots (laid 22 June 2026), para. 78. This authored restatement is published exactly as recorded in the evidence register.
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Demand 3 of 5
Single-use, re-issuable credentials
Each voter's route into the ballot — the link or code a scrutineer sends them — is built to be used once. It stops working the moment they vote, or when the ballot closes if they never do:
A voting access method must become ineffective once the voter has submitted an electronic voting form — or, if unused, at the closure of the ballot — and must be capable of being re-issued.
Formal state
Laid — not yet in forceofficial text exists; not commenced
“A voting access method must— (a) be unique, (b) be designed in a way which is resistant to attempts to infer or create other voting access methods, (c) be capable of being re-issued, and (d) become ineffective— (i) once the person to whom it was issued has submitted an electronic voting form for the ballot, or (ii) if the person does not vote, at the closure of the ballot.”
Quoted verbatim from the identified source · The Trade Unions (Permissible Means of Voting) and Employment Rights (Unfair Dismissal) (Amendment) Order 2026 (draft), inserted Schedule A1A, Part 1, para. 2(2). This authored restatement is published exactly as recorded in the evidence register.
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fact/balloting-single-use-credentials
Story event — not a legal step
The same rule also requires it to be re-issuable. If a member tells Sana Qureshi-Holt their voting link never arrived, or landed in a work inbox they can no longer reach, the Code already provides for the scrutineer to issue it again — not for the union to invent a workaround.
Demand 4 of 5
Audit, monitoring and certification
For electronic and hybrid balloting, the minister told the committee the rules go further than any single requirement — audit and monitoring arrangements sit alongside the protection of voter information and mandatory certification for scrutineers:
The minister stated that, for electronic and hybrid balloting, the draft Order and Code set out requirements covering the protection of voter information, the security of voting systems, and detailed audit and monitoring arrangements, alongside the scrutineer's mandatory independent cyber-security certification.
Formal state
Matter of recordrecords an event, not a legal provision
“For electronic and hybrid balloting, that includes requirements relating to the protection of voter information, the security of voting systems and detailed audit and monitoring arrangements, alongside mandatory independent cyber-security certification that must be held by scrutineers before they can provide those methods.”
Quoted verbatim from the identified source · Hansard, Sixth Delegated Legislation Committee, 8 July 2026, Kate Dearden MP (Parliamentary Under-Secretary of State for Business and Trade). This authored restatement is published exactly as recorded in the evidence register.
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fact/balloting-audit-monitoring-arrangements
This site has the minister's word that detailed audit and monitoring arrangements exist; it has not located the instruments' own operative text setting out what they contain. The one part of that summary it can quote directly is the scrutineer's security certification:
For electronic balloting, the independent scrutineer must hold valid Cyber Essentials Plus certification covering the relevant systems and networks for the entire duration of the ballot.
Formal state
Laid — not yet in forceofficial text exists; not commenced
“The independent scrutineer must hold one or more valid Cyber Essentials Plus Certificates; in respect of the computer networks and systems they intend to use for conducting the ballot. The certificate must be valid for the duration of the ballot.”
Quoted verbatim from the identified source · (Draft) Code of Practice on Electronic and Workplace Ballots (laid 22 June 2026), para. 46. This authored restatement is published exactly as recorded in the evidence register.
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fact/balloting-scrutineer-cyber-essentials
Demand 5 of 5
Only approved scrutineers may run it
None of the above is something a union could run itself, however ready its own data turns out to be. A statutory ballot has to be conducted by an independent scrutineer, and for workplace voting specifically, only with the employer's consent as well:
Workplace voting is available only for statutory industrial-action ballots, requires the employer's consent, and must be conducted under an appointed independent scrutineer.
Formal state
Laid — not yet in forceofficial text exists; not commenced
“Workplace voting - an in-person ballot, conducted on or near to the site of the employer for which the industrial action ballot is being held. a. The consent of the employer is mandatory before workplace balloting can be used for an industrial action ballot.”
Quoted verbatim from the identified source · (Draft) Code of Practice on Electronic and Workplace Ballots (laid 22 June 2026), para. 18 (scope also para. 6; scrutineer operation paras. 113-117). This authored restatement is published exactly as recorded in the evidence register.
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fact/balloting-workplace-voting-scope
"Independent scrutineer" does not mean any outside organisation a union might choose. It means one from a closed, government-approved list:
The government intends to expand the closed list of organisations legally permitted to act as independent scrutineers for statutory ballots.
Formal state
Announced intenta ministerial statement of intention
“In the coming months, we will progress work on updating that order to expand the list of named permitted scrutineers.”
Quoted verbatim from the identified source · Hansard, Sixth Delegated Legislation Committee, 8 July 2026, Kate Dearden MP (Parliamentary Under-Secretary of State for Business and Trade). This authored restatement is published exactly as recorded in the evidence register.
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fact/balloting-scrutineer-list-expansion
The list currently in use was substituted in 2017 — the third time it has been replaced since the 1993 Order first set it, and, as far as this site's sources show, the most recent:
The Trade Union Ballots and Elections (Independent Scrutineer Qualifications) (Amendment) Order 2017 replaced the list of organisations named in Article 7 of the 1993 Order as qualified to act as independent scrutineers for statutory trade union ballots and elections. The same list had previously been replaced in 2002 and in 2010.
“This Order amends the 1993 Order by replacing the list at Article 7 of bodies specified by name as being qualified for appointment. That list was previously amended in October 2002 by the Trade Union Ballots and Elections (Independent Scrutineer Qualifications) Order 1993 (Amendment) Order 2002 and in April 2010 by the Trade Union Ballots and Elections (Independent Scrutineer Qualifications) (Amendment) Order 2010.”
Quoted verbatim from the identified source · The Trade Union Ballots and Elections (Independent Scrutineer Qualifications) (Amendment) Order 2017 (S.I. 2017/877), Explanatory Note (not part of the Order). This authored restatement is published exactly as recorded in the evidence register.
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fact/balloting-scrutineer-list-2017-substitution
Story event — not a legal step
Choosing which approved scrutineer to appoint, when ASDWS eventually does, is Marisol Adeyemi-Clarke's decision to sign off as organising officer. This journey stops well before that point — it only asks whether the union's own data would be ready for whoever she appoints.
Where the regime stands
Two further follow-ons from the 8 July committee session are worth tracking, because each will eventually change what this page says. The Order carries its own statutory review duty:
The draft balloting Order contains a statutory review clause: the Secretary of State must review the regulatory provision, report and publish; the first report is due within five years of commencement and subsequent reports at intervals of no more than five years.
Formal state
Laid — not yet in forceofficial text exists; not commenced
“(3) The first report must be published before the end of the period of five years beginning with the date referred to in article 1(3). (4) Subsequent reports must be published at intervals not exceeding five years.”
Quoted verbatim from the identified source · The Trade Unions (Permissible Means of Voting) and Employment Rights (Unfair Dismissal) (Amendment) Order 2026 (draft), Part 2, art. 11(3)-(4); the review duty itself is art. 11(1). This authored restatement is published exactly as recorded in the evidence register.
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fact/balloting-review-clause
And the government told the committee it intends to put a standing oversight body around the whole system:
The government announced it intends to launch a senior oversight board — unions, businesses, scrutineers and cyber-security experts — to oversee the operation of electronic balloting in practice, within months of the 8 July 2026 committee debate.
Formal state
Announced intenta ministerial statement of intention
“As part of that, in the coming months we intend to launch a senior oversight board comprised of unions, businesses, scrutineers and cyber-security experts, who will share feedback on the operation of electronic balloting.”
Quoted verbatim from the identified source · Hansard, Sixth Delegated Legislation Committee, 8 July 2026, Kate Dearden MP (Parliamentary Under-Secretary of State for Business and Trade). This authored restatement is published exactly as recorded in the evidence register.
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fact/balloting-oversight-board
The transition map tracks all four statutory changes, including this one, as their formal stage moves.
What this page rests on
This is a narrative walkthrough, not a branching journey with statutory clocks — that depth belongs to the access journey. Five demands, each stating what the regime requires, who it actually binds, and where personal data sits: read in order, that is a first draft of a gap list, not just an explanation.
Every legal claim above traces to the versioned evidence register the same way every other page's claims do — its source passage, pinpoint citation and verification state included. Anything found wrong lands on the public corrections log.