Senedd by-election 23 October 2025 (Caerphilly): guidance for civil servants

A by-election to the Senedd constituency of Caerphilly will take place on 23 October 2025. The purpose of this guidance is to inform staff of the arrangements for handling government business during the pre-election period, so as to avoid being seen or perceived to influence the election campaign in any way, to maintain the impartiality of the Civil Service, and to avoid criticism of an inappropriate use of official resources.

To note - references to Ministers within this document encompass: the First Minister, Welsh Ministers (currently known as Cabinet Secretaries), the Counsel General and Minister for Delivery and Deputy Ministers (currently known as Ministers).

There will be a by-election to the Senedd constituency of Caerphilly on Thursday 23 October 2025.

As Welsh Government officials, our role is to continue to support Ministers in their work as usual, whilst being aware of the need to avoid action or activity which is, or could be construed as being, party-political or likely to have a direct bearing on the by-election in Caerphilly. Particular care should be taken in respect of announcements relating to this constituency.

This guidance applies immediately, until and including polling day on Thursday 23 October 2025. During the pre-election period, our activities and those of ministers will be under very close scrutiny.

In line with the Ministerial Code, ministers will not undertake any engagements, make any announcements or take decisions, which are or could be construed as conferring party-political or electoral advantage in relation to the by-election in Caerphilly. That basically means that Ministers will not ordinarily conduct any high-profile or sensitive official business during the pre-election period in the Caerphilly constituency.

The day-to-day business of civil servants will continue, in most cases, as usual. However, there may be some areas in which our activities are restricted.

It is important that the public has confidence during any pre-election period that Welsh Government resources which includes the time and attention of the civil service, are not used to help any particular political party or to support any political activity during a by-election campaign.

The civil service is required to be strictly neutral and impartial in respect of elections. To help ensure this, the First Minister invites the Cabinet of the Welsh Government to commit to observing guidance to prevent any actual, or perceived, use of public resources for campaigning purposes or for any actions designed primarily to influence the outcome of the election; and the Permanent Secretary, with the support of the First Minister, agrees complementary guidance for the civil service on conduct during a pre-election period.

These actions are underpinned by the respective codes of conduct for Ministers and for civil servants, which are referred to below. Please see links to the Ministerial Code and the Civil Service Code.

The purpose of this note is to provide general guidance on the impact the election campaign will have on us as civil servants. Staff working in the Senedd Commission will receive separate guidance, prepared in the light of their particular circumstances. Additional guidance is included for colleagues in the communications profession and those involved in statistical as well as survey and broader research activity. The principles of this guidance will be conveyed to NHS bodies in Wales. A summary of guidance for Welsh Government Arm’s Length Bodies (ALBs) and other devolved public bodies in Wales is included at the end of this advice and partnership teams should ensure they discuss this guidance with all their public bodies.

The Civil Service Code continues to apply during the campaign. Under that, we must adhere to 2 basic principles at all times:

1. to be, and to be seen to be, politically impartial, and
2. to ensure that public resources are not used for party-political purposes.

During the pre-election period, ministers should not be asked to take high profile or sensitive decisions in relation to the Caerphilly constituency. Such decisions should be deferred until after polling day. Non-sensitive, routine matters or very urgent matters should continue to be dealt with.

More generally, we should continue to submit advice and briefings to Ministers, and otherwise carry out their work as normal, taking account of the usual requirements for impartiality. This means making sure that nothing in our work (including briefing and answers to correspondence) suggests support for, or opposition to, one or more political parties, or could be taken to do so. If in doubt, advice should be sought from the relevant Director General/ Director.

We should not undertake any work (including announcements, meetings or campaigns), which is likely to attract media attention, and/or is politically sensitive or high-profile in relation to the Caerphilly constituency. When planning such activities, the pre-election period should be avoided altogether. Separate guidance on consultation exercises is set out below.

Neither should we agree to make joint announcements with UK government departments in relation to the Caerphilly constituency. This guidance applies to Welsh Government officials, however, officials in Whitehall may not be as constrained during the pre-election period. In any case, making an announcement jointly during the pre-election period would almost certainly be a breach of these guidelines for the Welsh Government. Therefore, any joint announcements of any kind should be postponed until after the election. If you are in any doubt, please consult with communications as per the contact details at paragraph 15.

Where the Welsh Government is preparing new policy, programmes or legislative proposals, which will have an impact solely on the Caerphilly constituency, and is required to consult, consultations should not ordinarily commence during the pre-election period.

Consultations that have begun before the beginning of the pre-election period may continue, with appropriate constraints regarding publicity, provided that the consultation is neither high profile nor sensitive or does not impact prominently on the Caerphilly constituency.

Where a joint consultation between a UK government department and the Welsh Government is proposed, every attempt should be made to avoid any consultation commencing during the pre-election period (or indeed running into it, if it will be contentious or high-profile). Where this is unavoidable due to a legislative timetable at Westminster, or where there is a particular danger that Wales could be excluded from legislation, which could be detrimental to the public interest, the consultation should proceed but with sensitivity to the election campaign.

Where a UK government department is consulting on a UK, a Great Britain, or an “England and Wales” basis, we should draw their attention to the pre-election period and ask them to be sensitive to the election campaign.

We should continue to provide recorded information in response to enquiries from parties, candidates and others in line with usual process.

All requests for recorded information fall under the Freedom of Information Act and must normally be responded to within 20 working days. Requests which seek disclosure of recorded information, which is not in the public domain, should continue to be dealt with according to the FOI guidance. However, during the pre-election period, it is particularly important for staff to be mindful of the political implications of responses to requests. The handling of requests which are likely to have political implications should be discussed with an appropriate Director General / Director.

All requests for recorded information should be treated equally, regardless of any known political affiliation of the person making them.

Election candidates should be treated equally. This means that letters from election candidates received during the pre-election period should be responded to by ministers.

Holding replies will only be necessary if the proposed response is likely to attract local media attention other than in a trivial or cursory reference or deals with politically contentious issues. Holding replies will be issued by private secretaries on advice from officials.

Other than as described above, guidance on who should receive ministerial/TO correspondence remains unchanged and will be determined by Correspondence Unit in the usual way.

Where possible, the public appointment process should be completed (i.e. relevant Welsh Minister takes a decision on appointment in line with the usual submission process and appointment publicised) before the pre-election period begins. Appointment processes that have already begun may continue, but particular care should be taken if the process has particular relevance to the Caerphilly constituency. If you are in any doubt about a particular appointment process, please discuss with the Public Bodies Unit in the first instance. This advice applies similarly to any requests for extensions or reappointments.

All officials should familiarise themselves with the rules on political activity, as the majority of civil servants are required to apply for permission before taking part in political activity.

Any Welsh Government employee wishing to undertake any political or campaigning activity in relation to the election, including standing as a candidate, should first seek permission in writing, via their line manager, from their Human Resources Business Partner.

The test that is applied in deciding whether to give permission is whether the applicant is working in a "sensitive area", which is explained in full in the policy on political activities. The Welsh Government may attach conditions or restrictions to any permission that is granted. For example, anonymous telephone canvassing may be permitted but not door-to-door canvassing or speaking at meetings. The Senior Civil Service, Executive Bands (Grades 6 and 7) and Fast Streamers are precluded from national political activity, which includes Senedd elections.

Industrial and non-office grades have blanket permission to take part in political activity.

Welsh Government premises and resources should never be used for campaigning purposes. We should not allow the use of Welsh Government premises for such purposes in any circumstances, or the display of election posters. Similar guidance will be issued to NHS bodies, Arm’s Length Bodies, etc. on the use of their estate.

Grants

Avoid opening or advertising grant schemes during the pre-election period.

Officials should avoid opening or advertising any grant schemes during the pre-election period, which could be perceived as or actually relating to the Caerphilly constituency area, or would and could be construed as being party-political and/or having a bearing on the constituency area by-election in any way. For any such grant schemes as described above, that are open for applications ahead of the pre-election period, every effort should be made to ensure decisions are made and organisations notified of the outcomes ahead of the pre-election period. If this is not possible, consideration should be given to delay opening of the grant scheme until after the Caerphilly by-election.

Every effort should be made to issue grant award letters ahead of the pre-election period. If this is not possible, an assessment should be made as to whether the grant is considered high-profile and/or sensitive in respect of the Caerphilly constituency area and by-election. If considered high profile and/or sensitive, appropriate advice must be sought (Director General/Departmental Director/Grants Centre of Excellence) before any grant award letters are issued. In urgent or critical cases, it may be possible to issue on an exception basis but again advice must be sought before any legally binding grant award letters are issued.

If the grant award letters are not deemed high profile and/or sensitive and considered more “business as usual” grants, efforts should still be made to issue grant award letters ahead of, rather than during, the pre-election period.

Officials should be aware that any grant award letters which need to be issued during the pre-election period on an exceptional basis also need careful consideration to ensure the grant funding issued aligns with the rest of this guidance.

The grant award letter is a legally binding agreement, and it can put public funds at risk if guidance and advice are not followed.

Any internal planning and development of new grant schemes, including attending the Grants Assurance Panel, can of course take place as normal.

Please contact Grantscentreofexcellence@gov.wales for further advice and support regarding grants, or if staff are in any doubt as to what steps to take.

Procurement activity during the pre-election period

Procurement activity which relates wholly or mainly to the relevant constituency and / or where the relevant Member’s input would typically be sought as part of the procurement process (‘relevant procurements’) should be scheduled to ensure that the advertisement or award of contracts does not occur during the pre-election period. Where relevant procurement activity commenced ahead of the pre-election period, every effort should be made to ensure decisions are made and organisations notified of the outcomes ahead of the pre-election period. Officials should work with their allocated procurement lead to determine realistic and achievable timescales.

Procurement activity above £25,000 (excl. VAT)

Officials should avoid advertising any contract opportunities or awarding any contracts during the pre-election period for relevant procurements which:

• are high profile and likely to attract media attention, and / or
• create significant long-term commitments, and / or
• are politically sensitive.

An assessment should be made to determine whether the relevant procurement should be considered high-profile or sensitive during the pre-election period. Advice should be sought from the relevant Director General and / or Director before commencing any activity.

Any internal planning of non-contentious procurement activity can take place as normal.

Procurement activity below £24,999.99 (excl. VAT)

Please speak to your Deputy Director before proceeding with any relevant procurement activity £24,999.99 and below.

Advice on the procurement of Research is within the wider Welsh Government advice at Annex B.

If you are in any doubt about what to do, then please speak to CPS/CPICT or contact CPSprocurementadvice@gov.wales.

Officials in ministerial private offices should continue to provide support to ministers in their official duties at all times during the pre-election period.

Ministers might be undertaking campaign activity and, as such, private office staff may wish to discuss the principles of this guidance with their ministers prior to the start of the formal pre-election period, or when appropriate.

Ministers will, as usual, be subject to the terms of the Ministerial Code, which requires them to maintain a separation of their ministerial and political roles. Private Office officials should continue to support ministers in their official duties at all times. This includes ensuring that Private Office officials, and not a member of a minister’s personal or constituency staff, attends each official engagement, and if one candidate is invited to attend an official ministerial engagement, all other candidates must also be afforded the same opportunity. Officials in Private Offices should familiarise themselves with the guidance on handling correspondence and Freedom of Information outlined in this document.

Private Office officials should never attend engagements which are explicitly for campaigning purposes. Nor should they allow Welsh Government resources to be used for campaigning purposes. In particular, they should not book official cars or rooms in Welsh Government premises or elsewhere, commission speeches or briefing, or arrange any other support, for party and campaigning engagements.

Ministers’ party and campaigning engagements in relation to the by-election should continue to be recorded in their official diaries.

Special Advisers will continue to provide advice and support to ministers, including political advice, in line with the code.

The code sets out the implications of a Special Adviser considering undertaking any public campaigning activity or wishing to be a by-election candidate.

Please refer to the specific guidance, which is attached to this guidance note. Guidance for staff in communications directorate is attached at Annex A and guidance for staff involved in statistical, survey and broader research activity is at Annex B.

There is a long-standing principle that public bodies must be politically impartial. Although Arm’s Length Bodies – statutory bodies, Welsh Government-owned companies, statutory office holders and Commissioners – operate independently of the Welsh Government, they are still government organisations and must not appear to influence or attempt to influence the outcome of any election. They cannot be seen to seek endorsement by political parties at any time. Each body should refer to its Code of Conduct for how staff and Board members should behave during the pre-election period.

An Arm’s Length Body’s resources, including their properties and buildings, must not be used for party political purposes at any time. Board members or staff of public bodies should not attend political party events in an official capacity during the formal pre-election period. Public bodies should not begin or continue any advertising or consultation campaigns during the pre-election period. If, in exceptional circumstances, advertising or publicity is required in this period, bodies must seek advice from their partnership team. Bodies should also consider whether existing publicity for events, exhibitions or other continuing activity could be considered party political and ensure any such publicity material is removed or changed until after the election. No response to any consultation should be published until after the election.

Staff who wish to stand for election or campaign for a party or candidate should refer to their terms and conditions of employment.

Board members appointed by Welsh Ministers should not make any public statements during the election that could be seen as favouring one or more parties, nor should they seek or accept endorsement of the body’s plans or activities from any party or candidate. Board members must abstain from all controversial political activities and be – and be seen to be – politically impartial. The only exception to this is when a Board member has been appointed to the body because they hold elected office, such as members of local authorities. Only in that case will those Board members be allowed to take a public role in the election.

This should only affect ministerial appointments to bodies which are connected to, or have a direct impact on, the Caerphilly constituency. If you are making an appointment to such a body before 23 October, then you should talk to the Public Appointments Team about the options available.

You should discuss any doubts you have with your line manager in the first instance. You can get more help and advice, particularly on specific cases, from the following individuals. Please submit your query by e-mail.

For queries on:

• Ministerial briefing and similar - the relevant private secretary
• Ministerial correspondence – Correspondence unit (via the correspondence mailbox)
• public access to information – Freedom of Information Officer mailbox
• issues relating to funding decisions, costing party policies, etc. - Budget and Government Business
• personal conduct of staff (including special advisers) wishing to engage in campaigning activity, etc. - your HR Business Partner Team
• announcements, events, marketing and publicity - Head of Strategic Communications or Head of News;
• specific queries from staff involved in statistical or survey work – Head of Statistics or Chief Social Research Officer
• specific queries from staff on the conduct of research – Chief Social Researcher
• specific queries relating to Legislative Consent Motions (LCMs), Statutory Instrument Consent Motions (SICMs) or queries on UK government activity or proposed joint UKG / WG activity - Constitution and Justice Division
• policy and legislation in relation to the conduct of the election itself –Local Government and Planning;
• arm’s length bodies and public appointments – Public Bodies Unit
• officials in private offices - Cabinet Secretariat.

Any other queries concerning this guidance please contact Cabinet Secretariat.

Cabinet Secretariat
September 2025

This guidance is for all staff involved in communications and marketing and supplements the general Guidance for Welsh Government Staff. This guidance applies immediately, until and including polling day.

The by-election in Caerphilly means that great care must be taken in any Welsh Government communications which could have a direct bearing on this constituency ahead of polling day. There must be no perception that government decisions or announcements are being made with the intention of influencing the way votes might be cast in the by-election.

These might include an investment project supported by the Welsh Government, or new investments in health or education capital schemes within the constituency boundaries, for example. Government communications resources should also not be used to highlight any existing projects of this type within the constituency prior to the by-election. Any media inquiries specifically related to the constituency should be responded to with existing lines to avoid any risk that new information is seen to be disclosed during the pre-election period.

However, as this is a by-election, rather than a full election, then the business of government should continue as normal. This means that announcements can be made across the range of government policy on an all-Wales or regional basis without constraint. As above, however, if case studies or other more specific material is used, they must not relate directly to the Caerphilly constituency.

As with all periods of heightened political sensitivity, if staff have any doubts whatsoever in relation to the handling of proposed announcements, these must be referred to either the Head of News or Head of Strategic Communications for advice.

The overall message is to exercise great caution and always check if there is any doubt in your mind about what may be permitted in the pre-election period with the following individuals:

Head of News 03000 258786
Head of Strategic Communications 03000 256839

This guidance is aimed at all staff involved in statistical, survey and research activity. This includes professional analysts in Knowledge and Analytical Services (KAS) and any other staff across the Welsh Government involved in these activities. The guidance should also be taken into account by our partner organisations and other official statistics producers in Wales. This guidance supplements the Guidance for Welsh Government Staff. The guidance covers the pre-election period, which is effective immediately, until and including polling day on 23 October 2025.

The guidance is not exhaustive and any other issues that arise during the campaign should be raised in the first instance with the Chief Statistician or the Chief Social Research Officer who will provide guidance.

Principles

1. As always, for official statistics ensure compliance with the Code of Practice for Statistics and the associated Pre-Release Access to Official Statistics (Wales) Order 2009. For research, the Government Social Research (GSR) Code and publication protocol continue to apply in the pre-election period.

2. Do not compete with parties and candidates for the attention of the public.

3. Do not, and do not appear to, engage in party politics or be used for party political purposes.

Release of statistics

4. Issue statistical outputs that have already been pre-announced before the start of the election period. Do not issue any unannounced ad hoc statistical outputs, and avoid postponing any regular or pre-announced outputs, as the motive for doing so may be questioned.

5. If a postponement of a statistical output cannot be avoided, be transparent on the reasons for postponement in any public communication and, if possible, state when the postponed statistics are likely to be published. Avoid postponements that would move publication of statistics from before polling day until after wherever possible.

6. There may be some exceptional circumstances which require the publication of unannounced ad hoc statistics (for example, when an unpublished statistic has been used publicly). This should always be discussed with the Chief Statistician.

7. Continue to publish social media posts relating to the publication of statistical outputs through the @statisticswales and @ystadegaucymru accounts. However, during the pre-election period avoid generating new infographics or charts for social media that have not previously been produced and issued.

8. Always take great care to be impartial and objective in the way you present and describe statistics, and in face-to-face briefing. Pay particular attention to the presentation of statistics related to the Caerphilly area. Avoid introducing new analysis that is solely focused on the Caerphilly area, or new analysis at local authority level which could have a bearing on the by-election.

9. New statistics blogs should be avoided during the pre-election period.

Publication of research reports

11. In general, publication can continue during the pre-election period for a by-election unless it relates specifically to the by-election area or has information released at local authority level which could have a bearing on the by-election. In this case it should be discussed with the Chief Social Research Officer to ensure there are no electoral or political implications from the publication.

Procurement of research

12. In general, procurement activity can continue as normal unless it specifically relates to research on the by-election area. Advice should be sought on individual cases from the Chief Social Research Officer.

Requests for information or advice

13. Handle requests for factual information in line with the Guidance for Welsh Government Staff.

14. Be even-handed in meeting factual information requests from candidates – for example in the level of detail you provide, and how promptly.

15. Continue to meet requests for factual guidance on methodology.

16. Handle with great care any requests for advice on interpreting or analysing statistics, especially requests related to parties’ policies or manifesto pledges. Costings of policies or pledges should not be undertaken without first consulting Budget and Government Business Division.  

17. The routine publication of material issued in response to requests for statistical information on a fortnightly basis will continue throughout the pre-election period and you should ensure the statistical publications team (Stats.web) are informed of such requests. It is important that this is done on a systematic basis which avoids the perception of being selective.

Requests for published material

18. Meet requests for small numbers of leaflets, background papers or free publications which were available before the election period. Do not meet bulk orders without the Chief Statistician’s or Chief Social Research Officer’s approval, as they might be intended for campaigning purposes.

Surveys

19. Regular, continuous and ongoing censuses and surveys may continue. So may ad hoc surveys that support a continuing statistical series.

20. Other ad hoc surveys may give rise to controversy or be related to an election issue. Where this is likely, consider postponing or cancelling them. If this would be difficult or costly seek advice from the KAS Survey Advice Team.

Research fieldwork

21. In general, fieldwork associated with a research project can continue as normal but fieldwork caried out in the by-election area should be discussed with the Chief Social Research Officer who would consider the need for a sample which includes representatives from the by-election area and the political and electoral impact of the study.

Advice

22. If in doubt consult the contacts below or the contacts given in the main Election Guidance.

Knowledge and Analytical Service contacts

Chief Statistician 
Chief Social Research Officer 
Heads of Statistical Policy and Standards