Despite Guido presenting them with compelling evidence that anti-Brexit billboard campaign ‘Led By Donkeys’ are in breach of EU election spending limits, the Electoral Commission tell Guido that they are simply “monitoring the activities” of Led By Donkeys. They add that Led By Donkeys are “fully aware” that they will have to register if they spend more than £20,000 in England, or £10,000 in any other part of the UK. According to their own figures they’ve already spent over £230,000…

Since the Electoral Commission haven’t found the time in between staging Brexit Party stunts to open their investigation so far, Guido thought he would help them out with their inquiries. Here’s what we know so far:

Led By Donkeys (LBD) have crowdfunded over £438,000 to support their anti-Brexit campaign.

to support their anti-Brexit campaign. The spending limit for Non-Party Campaigns (in England) is £159,750 – if they’re registered with the Electoral Commission.

– if they’re registered with the Electoral Commission. LBD do not appear on the register with the Electoral Commission.

appear on the register with the Electoral Commission. LBD have catalogued over 230 anti-Brexit billboards they’ve put up in England alone.

anti-Brexit billboards they’ve put up in England alone. LBD themselves estimate the cost at £1,000 each .

. The Electoral Commission’s guidance says that activity counts as regulated campaign spending if it is both aimed at the public (“the public test”) and is intended to influence voters to vote for or against particular parties or candidates (“the purpose test”).

particular parties or candidates (“the purpose test”). Guido has analysed every billboard put up by LBD and found that over 200 (205) directly target politicians from just two parties : the Conservatives and the Brexit Party.

: the Conservatives and the Brexit Party. Just 8 target politicians from any other party – over 96% are targeted at two specific parties.

are targeted at two specific parties. LBD’s own stated aim is “showing our fellow citizens that this Brexit failure was founded on lies and hypocrisy”.

is “showing our fellow citizens that this Brexit failure was founded on lies and hypocrisy”. LBD have recently started producing even more sophisticated adverts directly mimicking the Brexit Party’s branding.

They’ve also created an entire fake website for the Brexit Party which features on their posters.

for the Brexit Party which features on their posters. Design costs, staff travel, website design and hosting all also count as regulated spending.

Here’s what we don’t know:

Who are Led By Donkeys? They’re completely anonymous, their crowdfunder is anonymous, their fake website is registered through a third party.

Why are they not registered with the Electoral Commission? They’ve clearly spent over £20,000 which is the limit for registration. If they want to play a big part in an election the public has a right to know who they are.

How have they managed to buy over £230,000 worth of political advertising – according to their own figures – without breaching the spending limit of £159,750 in England for Non-Party Campaigners? And what’s happening to the remaining £279,000 from their crowdfunder?

Have their donations even come from permitted UK donors? Until they register, we just don’t know.

Led By Donkeys probably think they’ve been clever enough to get around the rules by not sticking ‘VOTE LIB DEM/CHANGE UK’ on their billboards. As the Electoral Commission’s own guidelines make clear, their hundreds of billboards still clearly qualify as regulated campaign spending. Clever political adverts are still political adverts. At least the Electoral Commission can proceed with their investigation much more quickly now we’ve done their work for them…

UPDATE: Following Guido’s campaign for transparency, Led By Donkeys have now registered with the Electoral Commission. It turns out they are all Greenpeace activists…

See also: Anti-Brexit Billboard Campaign in Massive Apparent Breach of Electoral Law