Electoral Threshold: Purpose and Optimal Level

Berlyavsky L.G., Vorobyov N.I., Gelman V.Ya., Golosov G.V., Grezev A.V., Zhavoronkov S.V., Korgunyuk Yu.G., Kryzhov S.B., Mikhailov V.V., Khudolei D.M., Shpagin S.A.

Abstract

Experts in the field of elections and electoral law discuss the problems associated with the electoral threshold. The advantages and disadvantages of the electoral threshold, the possibility of determining its optimal size, as well as the rules for the transition to a "floating" threshold are discussed.

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Editor's Note

In the second half of the 20th century, the electoral threshold became an almost indispensable companion of proportional representation systems. Only a limited number of countries do not employ such a threshold; these are typically systems in which elections are held smaller constituencies and seat allocation methods put small parties at a disadvantage.

At the same time, threshold levels vary considerably across countries – from 0.67% in the Netherlands to 10% in Turkiye. The Federal Republic of Germany was the first to introduce a nationwide threshold, establishing a 5% requirement in 1949; this rule has been applied to Bundestag elections for over seventy years. In most Western European and several Latin American countries, thresholds are lower (typically 2–4%). In post‑socialist Eastern Europe, a 5% threshold is common, although higher requirements are often imposed on party coalitions. In 2007, the Parliamentary Assembly of the Council of Europe recommended that electoral thresholds should not exceed 3%.

In Russia, a 5% threshold was applied in State Duma elections from 1993 to 2003 and again since 2016, while in 2007 and 2011 it was raised to 7%. At the regional and municipal levels, thresholds were initially left to regional discretion and ranged from 3% to 10%, reaching as high as 25% in one case. In 2005, federal law set the maximum permissible threshold at 7%, after which most regions raised theirs to that level. In 2014, the maximum was reduced to 5%, and thereafter all regions adopted a 5% threshold, declining to set it lower (the only exception being municipal elections in Belgorod Oblast) [14: 337–354].

Electoral thresholds have been discussed quite actively in the academic literature. Arguments for and against have been advanced and rationales for introducing thresholds have been offered. Far fewer works, however, attempt to justify a particular numerical level of the threshold [1: 23–25, 137–138; 2: 32–35; 5; 10: 36–38; 12: 90–108; 13: 278; 14: 343–354; 16: 137–138; 17; 20: 93].

The 5% threshold in Russia was contested before the Constitutional Court. In 1998, the Court held that such a threshold was permissible, but subject to two reservations: 1. the electoral associations that pass the threshold must together obtain more than half of the votes cast by participating voters; and 2. more than one electoral association must pass the threshold.

In 1999, a "floating" threshold was introduced into the legislation. In essence, if only one party passes the statutory threshold, one additional party (the one with the highest vote total among those failing to pass) is admitted to seat allocation. If the parties that pass the threshold together obtain less than 50% of the vote, further parties are admitted in descending order of vote totals until the sum of votes cast for parties admitted to seat allocation exceeds 50%. These rules have not had to be applied in State Duma elections. At the regional level, however, the rule admitting a second party has been applied repeatedly.

At the same time, it has been argued that activating a floating threshold only when parties passing the 5% threshold together obtain less than 50% of the vote is insufficient to ensure the representativeness of parliament. In particular, it has been proposed to raise this benchmark to 75% [9: 191–192].

In Germany, too, the threshold has been reviewed by the Constitutional Court. It was deemed acceptable for Bundestag elections, but not for elections to the European Parliament [7].

Therefore, we believe the issues surrounding electoral thresholds merit continued study and discussion. We therefore posed seven questions on thresholds to election experts – legal scholars and political scientists. We received responses from eleven experts.

Question 1. What are the advantages of an electoral threshold?

Grigorii V. Golosov

It reduces party system fragmentation at the parliamentary level.

Yurii G. Korgunyuk

Its main value lies in increasing the responsibility of electoral actors: the threshold forces them to assess their chances soberly and pushes them toward building coalitions with potential allies.

Sergei A. Shpagin

The primary function of the threshold is to protect the legislature from excessive fragmentation of its membership and thereby to strengthen the stability of governmental support. A secondary function is to exclude radical and extremist groups from legislative work. As Aleksei M. Salmin, one of the founders of Russian political science, once put it: to "keep out the marginal and the accidental."

Nikolai I. Vorobyov

The so-called electoral threshold is undoubtedly necessary in proportional representation systems. First, it enables political forces (above all, parties) to consolidate for parliamentary elections. Second, it prevents excessive parliamentary atomization by limiting the emergence of small factions (associations and groups) representing minor or unpopular parties and movements. In this way, the threshold supports the development and refinement of the country's party and electoral systems.

Valentin V. Mikhailov

Where democracy is still consolidating, a wide array of groups, including marginal and pseudo-political ones, seek entry into the political arena and may succeed in meeting party-registration requirements and getting onto the ballot. A threshold helps keep such groups out of parliament.

A smaller number of parliamentary parties also makes it easier to structure deputies around a limited set of platforms, enabling a more durable majority and quicker collective decisions. Small parties pursuing influence may block important decisions, threaten to exit coalitions, or simply impede procedures.

At a moderate threshold of approximately 3–5%, voters face a clearer choice. Many will be reluctant to cast their vote for a party that clearly fails to reach the threshold.

Leonid G. Berlyavsky

In a number of countries, a barrier clause (electoral threshold) was introduced to reduce the risk that legislatures would be dominated by small, mutually hostile groupings representing only a minor share of the electorate. One of the first to establish such a clause (5%) was the Federal Republic of Germany, where federal electoral law admitted to the seat allocation in the Bundestag only those party lists that obtained at least 5% of valid votes. The clause has since been adopted quite broadly. Under this rule, parties that fail to reach the prescribed minimum are excluded from seat allocation. Threshold levels vary widely: the Netherlands at 0.67%; Denmark at 2%; Israel at 2%; in Ukraine (since 2006) the threshold for elections to the Verkhovna Rada was lowered from 4% to 3%; Moldova at 5%; Kazakhstan at 7% [3: 99].

Aleksandr V. Grezev

When it does not exceed 5%, a threshold tends to support the development of political and party culture and, in most cases, still ensures that 80–90% of the electorate is represented in parliament. It filters out very small parties – often spoilers and "mayfly" projects – that may confuse voters. It also facilitates coalition formation and, by extension, stable governments.

In Germany, the 5% threshold has for decades helped sustain democratic stability, and political crises have been relatively rare. The Netherlands offers the opposite example: coalition formation can take months, and new parties regularly enter parliament. Yet even the Dutch threshold of 0.67% has advantages and fits the country’s political tradition. For Germany, by contrast, lowering the threshold would be ill-advised: mainstream democratic parties can clear 5%, and repeated failure (such as that of the FDP) should prompt serious reflection. In Russia, under fair elections, I would also keep a 5% threshold, possibly allowing variation at the regional level.

Dmitry M. Khudolei

The only real advantage of an electoral threshold is to prevent excessive parliamentary fragmentation that would make it impossible to form a stable coalition capable of establishing a government. This is a political objective rather than a legal one. Ideally, parliament would contain only two coalitions (or even two parties), as is often the case in majority systems ("Duverger’s law"). Party-list elections make a two-party legislature practically unattainable, which is precisely why thresholds emerge: they are meant to reduce coalition breakdowns, government resignations, and snap elections, and thus to save public resources.

Thresholds also allow large parties to avoid coalition bargaining and to form single-party governments. In the latter case, the party effectively receives a carte blanche to implement its platform. Coalition governments (especially "grand coalitions") often require parties to abandon parts of their program, which can damage their ratings and undermine voters’ trust in the honesty and responsibility of electoral competitors.

Vladimir Ya. Gelman

The electoral threshold is the most vivid illustration of Giovanni Sartori’s statement that electoral systems are among the most manipulative instruments of politics [19: 273]. This is due to both the normative and positive nature of the electoral threshold as an institution. From a normative perspective, the very existence of an electoral threshold, as well as its level, shapes the choice between, on the one hand, maintaining more optimal political representation (which lies at the core of proportional electoral systems) and, on the other hand, ensuring the effectiveness of governments formed as an outcome of elections. It is evident that this fundamental dilemma has no fully satisfactory solution, as it is driven by two fundamentally different principles: representative democracy and effective governance.

Sergei B. Kryzhov

The beneficiaries of an electoral threshold are the parties that obtain additional seats on the basis of votes taken away from those who did not vote for them. Simplifying parliamentary work through a hypothetical reduction in the number of party factions can hardly be regarded as a serious argument for introducing an electoral threshold.

Sergei V. Zhavoronkov

Two arguments are commonly cited. First, a threshold is said to reduce fragmentation, facilitate the creation of a governing coalition, and increase political stability. Second, it is said to stimulate the formation of large parties representing substantial segments of society, since only such parties can clear the threshold.

Both arguments are questionable. Consider the Netherlands in the 21st century, where the threshold is effectively one seat in parliament (0.67%). Political leadership has nevertheless been relatively stable: with four-year parliamentary terms, Willem Kok led the government in 1994–2002, Jan Peter Balkenende in 2002–2010, Mark Rutte in 2010–2024, and Dick Schoof since 2024 (currently acting; new snap elections are expected in fall 2025). The period also saw early elections (five times, compared with four regular elections, only one government remained in office for less than a year) and changes in the governing party’s coalition partners.

Let us compare this with Belgium and Italy (in Belgium, the term of office was extended from four to five years starting in 2014; in Italy it has consistently been five years; elections in Belgium are conducted entirely under proportional representation, while in Italy, since 2017, a mixed system has been in place, whose proportional component resembles the elections to the Russian Constituent Assembly of 1917: seats are allocated within constituencies, so that a party may fail to cross the nationwide threshold yet still pass the threshold in a given constituency and thus gain representation). Belgium has seen nine prime ministers despite only one early election (in 2010), and even that one was held a year before the term ended. That election triggered a major crisis in which it took almost two years (541 days) to form a government. Italy has had ten prime ministers; only one (Silvio Berlusconi in 2001–2006) completed a full term, and it appears that Georgia Meloni may become the second. This is despite the fact that, since 2005, various forms of a "majority bonus" have been in place, increasing the number of parliamentary seats allocated to the winning party or coalition.

In short, it is not obvious that a low threshold or the absence of one produces instability. Nor is it clear that the creation of only large parties on the model of the United States or Malta is necessarily beneficial.

Question 2. What are the disadvantages of an electoral threshold?

Grigorii V. Golosov

It limits political representation.

Valentin V. Mikhailov

Electoral thresholds reduce the chances of social, political, and ethnic minorities obtaining parliamentary representation. In Russia in recent years, such groups may account for approximately 15–20% of voters.

Yurii G. Korgunyuk

The disadvantage lies in granting privileges to those participants in the electoral process who are already in a privileged position. Large parties get an electoral bonus virtually for nothing and are tempted to further strengthen their position not through work with voters, but through casuistic legal maneuvering.

Sergei A. Shpagin

The disadvantage of the electoral threshold consists in its reducing the level of parliamentary representativeness and creating serious obstacles to the representation of new and small political communities. In Russia, the first of these threats materialized in the 1995 State Duma elections, when the parties that passed the threshold together received only slightly more than 50% of the vote. The second emerged in the 2000s, when, for a number of reasons, the liberal segment of the party system dropped out of the State Duma, which had a negative impact on the quality of lawmaking.

Aleksandr V. Grezev

The main drawback of the threshold lies in partially "wasted votes" and in the narrowing of the spectrum of political representation in parliament. This can lead part of the population to become disillusioned with the very procedure of voting. It is also problematic when an ideology important for a full-fledged democracy disappears entirely from legislative bodies. In Germany, this has at times concerned the FDP. In addition, voters are sometimes forced to vote not for the party closest to them, but for one that has a real chance of overcoming the threshold, so that their vote does not go to waste.

Sergei B. Kryzhov

The electoral threshold constitutes a restriction of electoral rights. It places a restriction on the right of both the party and of the voters supporting it to be represented in parliament. Once an electoral threshold is in place, voters base their choice not only on party programs and candidates, but also on strategic considerations, assessing whether a vote for a party with uncertain chances of passing the threshold is likely to be wasted. As a result, the true distribution of political preferences within the electorate is distorted. The integration of new parties into political life is impeded, as they are deprived of an official parliamentary platform even after receiving hundreds of thousands or millions of votes.

Dmitry M. Khudolei

Any electoral threshold contradicts the principles of equal suffrage and electoral fairness. In essence, it distorts the real will of voters by artificially inflating the representation of large parties through depriving small parties of seats. The higher the threshold, the greater the disproportionality. Another adverse effect of the threshold is that it encourages insincere voting: supporters of small parties may vote for larger opposition parties that are certain to pass the threshold ("compromise voting"). Ultimately, even in the absence of voter bribery, coercion, or other forms of fraud, election results will still fail to reflect true preferences of citizens.

Leonid G. Berlyavsky

The use of an electoral threshold benefits large, well-organized parties that have been active for a long time and in practice infringes upon the interests of young or recently formed parties and electoral associations. For this reason, the very existence of electoral thresholds has repeatedly been reviewed by constitutional courts in a number of countries as well as by the European Court of Human Rights (ECHR). In particular, in 1987 and 1988 the European Commission of Human Rights rejected two complaints against a French law on elections to the European Parliament that established a 5% threshold both for access to seat allocation and for the return of the election deposit. According to the applicants, this law violated Article 3 of Protocol No. 1 to the European Convention on Human Rights.

Nikolai I. Vorobyov

In itself, an electoral threshold is of no harm to either the electoral or party systems. Harm arises only from the ill-considered use of such a threshold. First, when it is frequently changed on short-term, of-the-moment political grounds. Second, when it is unjustifiably high and does not correspond to the realities of the country’s existing party system. This most often results from subjective approaches to threshold design on the part of ruling political forces, including those represented in parliament.

Electoral and political practice in countries with party systems at different levels of development shows that the most optimal threshold is around 3% (5% at most). But not 7, 9, or even 10%, as has been the case in Russia at both federal and regional parliamentary elections.

Sergei V. Zhavoronkov

Russia’s 1995 election serves a vivid illustration to this situation. The formation of a State Duma with a communist majority was not the result of majority support for the communists, but rather of the coincidence of two factors: the failure to pass the electoral threshold by parties supported by almost half of voters (49.5%), and the substantial lead of the CPRF (22.3%) over the LDPR, which placed second with 11.2%. As a result, the main redistribution of seats worked in favor of the CPRF. Consequently, there was a substantial (effectively twofold) distortion of voters’ will on party lists: having received 22.3% of the vote, the CPRF obtained 44% of the list seats.

But even when the number of voters left without parliamentary representation is not as astronomical as it was in Russia in 1995. I just cannot comprehend why small parties should not be allowed to hold a few seats and how it may harm democracy. On the contrary, the very logic of creating a proportional electoral system lies precisely in protecting minority rights. Otherwise, we may encounter oddities such as contemporary Germany: in 2025, the Sahra Wagenknecht Alliance, having received 4.97% of the vote, obtained no seats at all, whereas in 2021 The Left, with 4.87%, was admitted to seat allocation thanks to having won three single-seat constituencies.

Vladimir Ya. Gelman

Choosing a particular level of the electoral threshold may entail major political consequences, either excluding political parties (and their voters) from parliamentary representation or granting large parties substantial — and often clearly unjustified — bonuses in the form of extra seats.

In this respect, assessments of the advantages and disadvantages of the electoral threshold depend on the interests of those making them. A textbook example is Türkiye 2002 elections, in which an evidently inflated 10% threshold (introduced intentionally to deprive Kurdish parties of parliamentary representation) ensured a majority of seats for the Justice and Development Party, which received only 34.2% of the vote. But how, for example, should one assess the outcome of Germany’s 2025 elections, where, under the “classic” 5% threshold, the Sahra Wagenknecht Alliance (supported by nearly 2.5 million voters) received 4.97% of the vote and failed to enter the Bundestag? Advocates of political representation (and voters of that alliance) are likely to subject the threshold to sharp criticism in this case. At the same time, supporters of governmental effectiveness (and voters of the CDU/CSU and SPD, which formed the German government after the elections) are more likely to defend it. Had the Sahra Wagenknecht Alliance entered the Bundestag — it fell short by only 13,000 votes out of 60.5 million — the political consequences of the elections would likely have been entirely different. For this reason, discussions about the advantages and disadvantages of electoral thresholds inevitably lead to questions about who benefits from them, and under what conditions.

Question 3. In what cases is an electoral threshold unnecessary?

Leonid G. Berlyavsky

In cases where a majority voting system is used.

Sergei V. Zhavoronkov

In all cases. Reducing the threshold Dutch-style to the level of a single parliamentary seat has no disadvantages allows a full representation of voters’ preferences.

Yurii G. Korgunyuk

In elections to supranational representative bodies such as the European Parliament, where the failure of a particular party "family" in one country may be offset by its success in another.

Grigorii V. Golosov

The legal threshold is only necessary when district magnitude (M) is large, starting with approximately M > 10. This is why the threshold is not necessary in proportional representation elections held in small-magnitude (3 to 5) and medium-size (6 to 9) districts.

Aleksandr V. Grezev

At the local level – in city/town and rural councils – a lower threshold is advisable. In small multi-seat constituencies (for example, in Ireland under the single transferable vote system), a high threshold is redundant.

Valentin V. Mikhailov

Once a country has reached a high level of political culture, small parliamentary factions that enter the governing majority will not obstruct procedures or threaten to leave coalitions over minor issues; on the contrary, their primary objective will be the effective functioning of parliament as an independent institution. However, the development of multi-party democracies shows that such conditions are still a long way off.

Sergei A. Shpagin

Like any other individual legal provision, the electoral threshold functions only in conjunction with other norms of electoral law. In particular, it makes no sense in elections conducted in single-seat constituencies, and its application is rather questionable in constituencies with a small number of seats. One may even propose a general pattern for discussion: the smaller the constituency, the less useful an electoral threshold becomes.

Dmitry M. Khudolei

I do not think an electoral threshold is necessary at all in regional or local elections, since the number of seats to be filled in constituencies is usually not very large. In effect, there is already a natural threshold, and there is therefore no point in introducing an additional legal one. At nationwide elections, the threshold could also be abandoned if voting were conducted not in a single constituency, but in several territorial one (as in the Germany), each electing approximately 30–35 deputies.

Sergei B. Kryzhov

The absence of any substantiated justification for an optimal threshold level indicates that the electoral threshold is fundamentally unjustified. It is a product of arbitrary use of political power on the part of the incumbent legislator, who pursues the goal of preserving its own position in parliament, among other things. An electoral threshold is unnecessary where human and civil rights are genuinely recognized as the highest value, rather than subordinated to the unfounded discretion of the legislator.

Nikolai I. Vorobyov

In my view, an electoral threshold should not be established when proportional representation is used in municipal elections or in elections to small regional parliaments.

Back in its day (in 2002), the Central Election Commission of the Russian Federation took into account the complexity of applying proportional representation in Russia’s regions to develop and approve the Methodological Recommendations on the Choice of a Type of Proportional Electoral System in Drafting Laws of the Subjects of the Russian Federation on Elections of Deputies to Legislative (Representative) Bodies of State Power (approved by CEC Resolution No. 167/1419-3 of 25 December 2002) [15]. I believe these recommendations reasonably proposed using proportional representation for the election of regional parliaments only where the number of seats allocated under the proportional system was at least twenty. As for the electoral threshold, it was recommended that it not exceed 5%.

At the same time, the subjects of the Russian Federation were advised to legislatively lower the specified threshold if only one list of candidates was admitted to seat allocation, or if the lists that passed the threshold together received 50% or less of the votes cast by participating voters.

Question 4. What factors determine the level of the electoral threshold?

Sergei B. Kryzhov

The extent to which the legislature fears that parties it considers undesirable may gain entry to parliament.

Valentin V. Mikhailov

These include the authorities’ commitment to democratic principles, the number of parties and blocs on the ballot, district magnitude, and the overall level of electoral culture.

Dmitry M. Khudolei

One important factor is the desire to artificially create a workable (in authoritarian systems, a controllable) parliament. It is evident that during the formative stage of a party system, parliamentary fragmentation will be at its highest, as was the case in Poland after the collapse of the socialist regime. Over time, however, such a threshold largely loses its importance, since the disproportionality it produces becomes relatively small.

Yurii G. Korgunyuk

The relevant factors vary from one context to another. In the early stages of democratic transition, a general desire for clearer political structuring of parliament may lead to an increase in the threshold. When a single political force acquires a monopoly position, this likewise creates incentives to raise the threshold. By contrast, efforts to limit such monopolization tend to push the threshold downward.

Sergei A. Shpagin

The electoral threshold level is closely linked to a country’s prior political experience, the nature of its party system, and the overall character of its political regime. Italy, for example, has experimented with four different electoral systems with varying thresholds since World War II. At present, the threshold is set at 3%, which allows the multiparty system typical of this country to be represented more or less fully.

Aleksandr V. Grezev

A wide range of factors affects threshold size, including historical development, political culture, national composition, geographical conditions as well as pragmatic considerations. At the same time, the integrity of elections must remain the primary concern, since where electoral distortions occur the threshold itself becomes secondary. A system that functions reliably offers little justification for change. Thus, while Germany’s current threshold operates effectively, other countries, such as Italy or Spain, require institutional arrangements better suited to their own circumstances.

Grigorii V. Golosov

There are two crucial factors: district magnitude (M, the number of representatives per district), and whether the electoral system is purely proportional or mixed. In districts with M > 30, a threshold of around 3% appears to be optimal. Where M ranges from 10 to 30, it would be reasonable to set the threshold according to the formula \(B = M / 10\), that is, from 3% in a thirty-seat district to 1% in a ten-seat one. A "floating threshold," of the type outlined in general terms in the editorial introduction, also appears to be appropriate. Besides, if elections are conducted in more than one proportional-representation districts, the thresholds should be set at the district level rather than nationwide.

Sergei V. Zhavoronkov

Above all, political conjuncture plays a decisive role, as it does in many other areas. Initiatives concerning the threshold are usually advanced by representatives of the governing coalition and typically aim at raising it. This is clearly illustrated by the case of Israel, where the threshold was increased from 1% at the 1992 elections to 1.5%, then to 2% in 2003, and finally to 3.25% in 2015. Notably, the last increase was promoted not by the election winner (Likud), but by smaller coalition partners (Yisrael Beiteinu, led by Avigdor Lieberman, and Yesh Atid, led by Yair Lapid). Political actors confident of clearing the threshold tend to seek either the elimination of smaller competitors on their flanks or the exclusion of parties regarded as "non-systemic."

Nikolai I. Vorobyov

Comparative evidence from countries with differing levels of party-system development suggests that relatively low thresholds (around 1–3%) are typical of democratic states with well-developed party systems. By contrast, elevated (or even excessively high) thresholds are more characteristic of countries with underdeveloped party and electoral systems and authoritarian political regimes.

Accordingly, the threshold level is shaped primarily by the subjective, of-the-moment political calculations of legislators (incumbent members of parliament in particular) who modify electoral rules, as well as party and electoral systems more broadly, in line with their own interests. This tendency is reinforced by the absence of genuine political debate during the drafting of electoral legislation. Such practices have occurred, and continue to occur, in Russia, where not only the threshold itself, but also the electoral system, the electoral process, and the party system have repeatedly been altered to serve the interests of those in power.

Vladimir Ya. Gelman

In the most general sense, threshold level reflects the expectations that political actors hold regarding future electoral outcomes when initiating its introduction and further changes. These expectations enable the manipulative use of the threshold as a political instrument: politicians often seek to secure the most favorable conditions for themselves before elections. In practice, however, such expectations sometimes prove misguided – as in Türkiye in 2002, when a large-scale political crisis led to the electoral collapse of all parties that had previously formed the governing coalition. More broadly, whether one like it or not, political decision-making tends to be guided primarily by actors’ self-interests. Institutional inertia also plays an important role. While it proved relatively easy in Türkiye to introduce and maintain an albeit ultimately unsuccessful threshold, it is difficult today to imagine abandoning Germany’s deeply entrenched 5% rule after more than seven decades. Most often, however, institutional choices – both with regard to electoral systems in general and thresholds in particular – follow patterns borrowed from domestic or foreign experience. It is therefore unsurprising that many post-Communist countries adopted the 5% threshold in the 1990s, drawing on the West German model.

Leonid G. Berlyavsky

Among the most important factors are constitutional constraints. In particular, Article 152 of Portugal’s 1976 Constitution explicitly ­prohibits the introduction of an electoral threshold.

Electoral thresholds are commonly associated with proportional representation. However, the evidence presented in the "Сomparative Report On Thresholds and Other Features of Electoral Systems Which Bar Parties from Access to Parliament," prepared by the European Commission for Democracy through Law (the Venice Commission) suggests that this link is not as straightforward as it may be assumed to be. First, electoral thresholds may be provided for in the legislation of countries using majority systems (for example, in France, where a candidate must win 12.5% of registered voters in order to advance to the second round) as well as mixed systems (Italy – 4%, Lithuania – 5%, and others). Second, the legislation of a number of countries employing proportional representation (Bosnia and Herzegovina, Finland, Luxembourg, Iceland, Switzerland, Portugal, Chile, and South Africa) does not provide for any formal electoral threshold at all. Third, alongside the legally established electoral threshold, the report introduces the so-called natural (implicit, effective) threshold, defined as the share of votes that a party actually needs to obtain in order to gain parliamentary representation under the electoral system in force in a given country. This indicator varies considerably across electoral systems: in majority systems (United Kingdom – 35%; Belarus and France – 50%), mixed systems (Hungary – 11.5%), and proportional systems (Luxembourg – 4.8%; Finland at 5%; Portugal – 6.7%; Switzerland at 9%; Belgium – 9.2%; Spain – 9.7%; Iceland – 10.8%; Ireland – 15%) [6: 5–9].

Question 5. Is it possible to establish an optimal level for the electoral threshold?

Sergei A. Shpagin

It is unrealistic to establish an electoral threshold once and for all. This parameter is shaped through trial and error.

Dmitry M. Khudolei

Either the threshold is not needed at all, or it should not exceed 3%. At that level, more than 75% of voters usually support parties that clear the threshold.

Yurii G. Korgunyuk

The threshold should, as a rule, be low, around 2–3% Experience shows that higher thresholds create incentives to resolve political competition by establishing monopolistic control.

Nikolai I. Vorobyov

An absolutely precise threshold is hardly attainable. Still, for a given country, and in light of the development of its political and party systems, a range of 3–5% appears optimal.

Grigorii V. Golosov

In mixed electoral systems, the German-type 5% threshold may be acceptable, but only if one of the German rules applies: parties that win a specified number of district seats should be allowed to participate in seat allocation regardless of their proportional vote share.

Aleksandr V. Grezev

Ideally, the threshold should not exceed 5% at either the national or regional level. In countries with different political traditions and social structures (such as Israel or the Netherlands) a 5% threshold would be too high. A uniform standard therefore makes little sense.

Valentin V. Mikhailov

For all I know, the issue could be formalised as a mathematical problem and yield a definite result. This would be an intellectually engaging exercise. The difficulty is that the starting assumptions would change from one election to the next. Under these conditions, it is hard to imagine such a model carrying much weight in parliament, where thresholds are typically set on the basis of previous practice and political intuitions about what a democratic parliament should look like.

Sergei B. Kryzhov

Since the setting of an electoral threshold is a subjective process, I would argue that for those who determine it on the basis of their own interests, the "optimal" level is simply the one that keeps undesirable parties out of parliament. This process typically involves analysing opinion polls, estimating campaign resources, and forecasting electoral results. For those who set the rules, there is no scientifically grounded method for identifying an optimal threshold. In practice, virtually any threshold can be presented to voters as optimal.

I can identify only one case of a genuinely optimal threshold. It is the 5% in a proportional representation system electing ten deputies. In this configuration, a party needs votes equivalent to half a seat in order to get one seat.

Vladimir Ya. Gelman

Discussion of the optimal electoral threshold inevitably encounters the problem of defining the criteria of optimality, which depend on what is prioritized: governability or political representation. Theoretically, it is probably possible to propose a mathematical model that would take both criteria into account and, after adjusting for the structure of party systems (such as fragmentation and volatility) as well as a number of other parameters (for example, ethnolinguistic fragmentation), calculate an optimal threshold for each specific country. However, it would be naïve to expect such a model to serve as the basis for political decision-making: in practice, politicians rarely strive for normative optimality, especially in matters as sensitive to them as the level of the electoral threshold.

Leonid G. Berlyavsky

Attempts to determine an optimal electoral threshold have been made repeatedly, as evidenced by the case law of constitutional courts and supranational bodies.

For example, the Constitutional Court of Italy in 1993 and the European Commission of Human Rights in 1996 rejected a complaint against the Italian law on legislative election, which required overcoming a 4% threshold in order to participate in the proportional allocation of seats. In 2001, the ECHR declared inadmissible a complaint against the provisions of the Statute of Autonomy of the Canary Islands, which established a 6% threshold of votes across the entire autonomous community or 30% in a single constituency. In 2007, it found Latvia’s 5% threshold compatible with the European Convention on Human Rights; and in 2008, it upheld Turkiye’s 10% threshold. In 2007, the Parliamentary Assembly of the Council of Europe recommended that electoral thresholds for parliamentary elections should not exceed 3%.

Similar attempts can also be found in the work of scholars of electoral law. A. Lijphart argued that a major contribution to the comparative study of electoral systems was made with the publication in 2005 of the collective volume "The Politics of Electoral Systems," edited by M.Gallagher and P.Mitchell, whose empirical basis consisted of electoral law sources from 22 countries [8]. In the preface to this volume, Lijphart recommended that new democracies adopt proportional representation with predominantly closed party lists and a relatively low electoral threshold (2–3%), which, in his view, would enable minority representation in the national legislative body [8: ix].

Against this background, it is worth noting that this very electoral system (apart from the higher electoral threshold) was tested in the Russian Federation’s legislation on elections to the State Duma in 2007 and 2011. The system has subsequently been criticised for over-stabilising the political system, weakening territorial representation, concentrating legislative power in the hands of a few political parties, and fostering close ties between "career deputies" and executive authorities. This provides further confirmation of A. Lijphart’s claim that "no electoral system is perfect." The modernisation of an electoral system depends instead on a country’s political experience, its commitment to democratic principles, its ability to respond flexibly to voters' demands, the willingness of electoral actors to seek compromise, and the ongoing refinement of electoral legislation.

Controversy surrounding the fairness of the "threshold" in federal parliamentary elections continued. The Federal Law No. 51-FZ of 18 May 2005 "On Elections of Deputies to the State Duma of the Federal Assembly of the Russian Federation" (Article 82 Part 7) raised the threshold for party representation in State Duma from 5 to 7%. Subsequently, Federal Law No. 94-FZ of 12 May 2009 introduced Article 82.1, which provided for the allocation of seats to federal party receiving no less than 5% but less than 7% of the vote. The enactment of this provision was justified by the President of the Russian Federation in his 2008 Address to the Federal Assembly [18].

Nevertheless, the results of the 2011 election to the State Duma of the sixth convocation showed that none of the parties excluded from the seat allocation managed to cross the 5% threshold and put one or two of its representatives into parliament.

Question 6. Is it acceptable to set different electoral thresholds for different electoral actors (for example, parties and blocs)?

Sergei V. Zhavoronkov

An electoral threshold is not necessary as such, so there's no reason to raise it either for all participants or electoral blocs.

Dmitry M. Khudolei

Such rules should probably not be introduced, as they directly violate the principle of equality among political parties and other electoral associations.

Nikolai I. Vorobyov

In my view, establishing different electoral thresholds for different participants in the political process is unacceptable and simply unfair.

Sergei B. Kryzhov

Unacceptable, although there are no such restrictions for the legislator. Deputies are equal in their rights regardless of who nominated them. And candidates should not be discriminated against on that basis.

Yurii G. Korgunyuk

Such differentiation interferes with coalition agreements, whereas democracy is effective only when society and the political class develop the ability to negotiate and compromise.

Grigorii V. Golosov

It is acceptable if the legislator is particularly concerned about the stability and consolidation of the party system. But, generally speaking, it is not a good idea.

Leonid G. Berlyavsky

Acceptable. For example, the electoral system in Hungary applies a 5% threshold for parties at the national level and a 10% threshold for party blocs. A similarly high threshold for blocs exists in Turkiye.

Sergei A. Shpagin

Introducing different thresholds for different electoral actors is quite possible. Such experience exists in the very same Italy: under the 2005 electoral law, the threshold was 2% for parties and 10% for blocs. However, this practice did not add to government stability.

Valentin V. Mikhailov

Different thresholds may be set for parties and for blocs (or lists, as in Israel). For example, 5% and 7% thresholds for parties and blocs, respectively, as in Lithuania. A bloc is a political formation with less clearly defined goals and weaker internal ties, whose constituent elements may leave the bloc after elections. As a result, such formations often have a shorter lifespan than a parliamentary term. After a bloc is reshuffled, deputies remain bound by looser commitments to voters than during the pre-election period. When such a political entity gains seats in parliament, its contribution to consolidation around government goals is smaller and less predictable than that of a party, especially a party with established traditions and a stable platform.

Aleksandr V. Grezev

The question of setting different thresholds for parties and blocs remains contested. In some countries, blocs do not exist at all, and the system functions well without them. In others, such as Eastern Europe and Italy, blocs play a significant role. In general, it seems reasonable to set a higher threshold for coalitions – around 7% for alliances of two or more parties, but not higher. There have been cases where parties running on a joint list failed to enter parliament precisely because of this choice. A particularly telling example is Slovakia in 2020, when the liberal alliance Progressive Slovakia, together with its partner, received 6.97% under a 7% threshold. Had the party run independently, it would have exceeded 5% and secured parliamentary representation.

Question 7. Should the bar for switching to a "floating threshold" be raised from 50% to, say, 75%?

Grigorii V. Golosov

Yes.

Sergei B. Kryzhov

It should be. The higher, the better.

Nikolai I. Vorobyov

I believe that raising the bar for switching to a "floating threshold" from 50% to 75% is neither justified nor necessary.

Sergei A. Shpagin

Raising the level at which the "floating" threshold applies to 75% is an interesting idea, but it requires broad discussion. In democratic systems, this rule may increase the legitimacy of the elected parliament; in non-democratic systems, it is unlikely to have any effect.

Yurii G. Korgunyuk

At the very least, one could do a test run. In any case, a situation in which parties that pass the threshold receive only slightly more than 50% of the vote points either to an excessively high threshold (which can be addressed by lowering it) or to a weak capacity of society and the political class to reach agreements (which is a more advanced issue, and there are no effective remedies for it).

Sergei V. Zhavoronkov

Where an electoral threshold exists, some of its negative effects can be mitigated by the system of "compensatory votes" used in Israel. According to that system, parties may conclude an agreement (with no more than one other party) under which votes insufficient to secure a seat may be transferred to an ally, provided that both parties pass the threshold.

Aleksandr V. Grezev

The bar for switching to a "floating threshold" should not be raised from 50% to 75%. The 50% requirement is justified, since a parliament in which parties clearing the threshold receive less than half of the total vote loses both legitimacy and representativeness. Raising the bar to 75% would effectively amount to abandoning the very idea of a threshold, as in most cases it would require admitting too many parties. This would upset the balance between representation and stability.

Valentin V. Mikhailov

Yes, the bar should be raised to 75–80%. Although in the most recent State Duma election, parties that cleared the threshold received all in all over 85% of the vote, in 2003 this figure was below 72%, which was clearly insufficient: more than a quarter of voters were left without representation. At the time, there were many short-lived parties (over 20 in total), but they nevertheless met the formal requirements for party registration. There were also serious suspicions that the vote shares of Yabloko and the Union of Right Forces were played down in order to prevent them from crossing the threshold. This further increased the number of voters without representation in the State Duma. A further transformation of the Russian electoral system could again lead to party proliferation and manipulation at the expense of smaller parties, raising the risk of a repeat of 2003.

Dmitry M. Khudolei

Yes, absolutely. I believe it is unacceptable to reduce the will of the majority to 50%+1 in cases where elections are not held in single-seat constituencies and voters have only one vote. In other words, the classical Loosemore–Hanby index (half the sum of the absolute deviations in party representation) is not entirely appropriate in such cases. Several years ago, I proposed my own definition of an "effective" party: a party whose vote total is equal to or exceeds the Droop quota. In case of single-seat constituency elections, the Droop quota is indeed 50%+1. It makes little sense to speak of distorted proportionality if the winning candidate secures a majority in the first round (the will of the majority is then respected). In such cases, the Loosemore–Hanby index should be calculated solely on the basis of the winner’s vote share and will in any event be BELOW 25% (for example, 49% divided by two). In legislative elections with a large number of seats (100 or more), virtually all parties exceed the Droop quota. Consequently, a modified 25% Loosemore–Hanby index for "effective" parties corresponds to a situation in which electoral associations admitted to seat allocation jointly receive 75% of the vote. I therefore propose a 3% threshold, provided that the parties admitted to seat allocation have obtained MORE than 75% of the vote. In this case, the will of the majority is not distorted, because if we subtract 25% from 75%+1 vote, it still yields 50%+1 vote [11].

Leonid G. Berlyavsky

Given the still developing and unstable multiparty system in the Russian Federation, the electoral threshold may function, depending on the context, as either an acceptable or excessive instrument. Under Articles 1 and 13 of the Russian Constitution, democracy grounded in political pluralism and multiparty competition presupposes the presence of opposition and rules out a monopoly on power. Therefore, if only one electoral association clears the "threshold," even where it has received a majority of the votes, it cannot be allocated all deputy seats in the federal constituency, as this would contradict the principle of proportional representation in a democratic system. In such cases, it would be advisable for the Federal Assembly to establish a legal mechanism that ensures compliance with the democratic foundations of the constitutional order of the Russian Federation, for example through the introduction of a "floating threshold" [4].

At the same time, Italian electoral legislation deserves attention for its elaborate system of thresholds. In elections to the Chamber of Deputies, different national-level thresholds apply to parties and party coalitions, while in Senate elections thresholds are set by constituency and are twice as high. For access to seat allocation in the Chamber, a party must secure at least 4% of the vote and a coalition at least 10%, with each coalition party obtaining no less than 2%. In Senate elections, the threshold goes as far as 20% for coalitions and 8% for coalition parties.

Received 26.09.2025, revision received 10.10.2025.

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