Government Shutdowns: A Comparative Analysis of the United Kingdom and the United States

Government shutdowns, characterized by the cessation of government operations due to the failure to pass funding legislation, have become a recurring phenomenon in the United States. In contrast, the United Kingdom has never experienced a government shutdown. This article delves into the reasons behind this stark difference, exploring the distinct political, legislative, and procedural factors that contribute to the occurrence of shutdowns in the US and their absence in the UK.

Key Facts

  1. UK Parliamentary System: The UK operates under a parliamentary system, where the executive branch is dependent on the support of the legislature to remain in power. This means that if a government cannot command a majority in Parliament, it would be dismissed.
  2. Fixed-Term Parliaments Act: Until the passage of the Fixed-Term Parliaments Act in 2011, government shutdowns in the UK were impossible due to parliamentary convention. The act abolished these conventions, but it did not lead to a government shutdown.
  3. Possibility of Shutdown: There were speculations that a government shutdown could have been possible in the UK, especially in the context of Brexit. Some Members of Parliament proposed an amendment to “starve the government of cash” and create a “Donald Trump-style shutdown” in the event of a no-deal Brexit. However, the Fixed-Term Parliaments Act was repealed in 2022, making it virtually impossible for a government shutdown to occur.

Legislative Power and Budgetary Process

The legislative power dynamics in the UK and US significantly influence their respective approaches to budget approval and the likelihood of government shutdowns. In the UK, the executive branch, comprising the party or coalition in power, holds the sole authority to propose spending plans. Parliament, consisting of members from various political parties, has an oversight and approval role but limited influence over the budgetary timeline or the amendment of spending plans. This contrasts with the US, where Congress, which may be split or controlled by a different party than the executive, plays a more substantial role in the budgetary process. The US president initiates the budget process by outlining the administration’s funding priorities, but the Constitution grants Congress the power of the purse, enabling it to tax and spend. Furthermore, legislation like the 1974 Congressional Budget Act has bolstered congressional control over the budget timeline, providing more opportunities for disagreements and delays.

Thresholds for Budget Approval

The voting rules in the UK and US legislatures further contribute to the differing likelihood of government shutdowns. Passing the US budget is inherently more complex, requiring the support of both the Senate and the House of Representatives. In the UK, however, the House of Commons holds the primary authority in budget approval, with the House of Lords having limited power to amend or block budget-related legislation. Additionally, securing budget approval in the UK requires only an absolute majority vote in the House of Commons, which is typically attainable by the party in power or through alliances with smaller parties. In contrast, the US Senate has a 60-vote threshold to close debates before proceeding to a majority vote to pass a bill, making budget approval more challenging.

Political Stakes and Consequences

The political stakes associated with budget approval differ significantly between the UK and the US. Members of Congress may face political consequences for their votes on the budget, but their jobs are not immediately at risk. In the UK, however, the party or coalition in power must maintain the confidence of the House of Commons to remain in office. Losing formal votes of confidence can lead to the fall of the government, forcing resignations or triggering new elections. This raises the stakes for members of Parliament, discouraging them from voting against the budget and potentially causing a dissolution of Parliament and new elections.

Appropriation Rules

Finally, the rules governing appropriation further distinguish the US and UK approaches to budget approval. For decades, US federal agencies could continue operating even without passed funding bills. However, a ruling by then-Attorney General Benjamin Civiletti in 1980 deemed it illegal for governments to spend money without congressional approval. This ruling exacerbated the severity of shutdowns in the US. In contrast, the UK has distinct appropriation rules, such as “votes on account,” which allow the government to obtain an advance on the funds needed for the next financial year, mitigating the risk of shutdowns.

Conclusion

The absence of government shutdowns in the UK compared to their frequent occurrence in the US can be attributed to several key factors. The UK’s parliamentary system, with the executive branch dependent on legislative support, creates a strong incentive for cooperation and compromise in budget negotiations. The voting rules, requiring only an absolute majority in the House of Commons, facilitate budget approval. Additionally, the high political stakes associated with budget votes in the UK discourage members of Parliament from jeopardizing the government’s stability. Finally, the UK’s distinct appropriation rules, allowing for advances on funding, provide a safety net against shutdowns. These factors collectively explain why government shutdowns, a recurring challenge in the US political landscape, have never occurred in the UK.

References

  1. “Government Shutdown.” Wikipedia, Wikimedia Foundation, 13 Jan. 2024, en.wikipedia.org/wiki/Government_shutdown.
  2. Martin, Garret. “4 Reasons Why UK’s British Parliament Has Never Had an American Congress-Style Government Shutdown.” Fortune, Fortune, 30 Sept. 2023, fortune.com/europe/2023/09/30/why-government-shutdown-common-in-america-never-britain/.
  3. Martin, Garret. “Shutdowns Are a Uniquely American Drama.” School of International Service, American University, 29 Sept. 2023, www.american.edu/sis/news/20230929-shutdowns-are-a-uniquely-american-drama.cfm.

FAQs

Why has the UK never experienced a government shutdown?

The UK’s parliamentary system, with the executive branch dependent on legislative support, creates a strong incentive for cooperation and compromise in budget negotiations. Additionally, the voting rules, requiring only an absolute majority in the House of Commons, facilitate budget approval.

How does the UK’s parliamentary system differ from the US system in terms of budget approval?

In the UK, the executive branch proposes spending plans, and Parliament has an oversight and approval role but limited power to amend or block them. In the US, Congress plays a more substantial role, with the power to tax and spend, and the budget requires approval from both the House of Representatives and the Senate.

What are the political stakes associated with budget approval in the UK?

The party or coalition in power in the UK must maintain the confidence of the House of Commons to remain in office. Losing formal votes of confidence can lead to the fall of the government, forcing resignations or triggering new elections. This raises the stakes for members of Parliament, discouraging them from voting against the budget and potentially causing a dissolution of Parliament and new elections.

How do the appropriation rules in the UK differ from those in the US?

The UK has distinct appropriation rules, such as “votes on account,” which allow the government to obtain an advance on the funds needed for the next financial year, mitigating the risk of shutdowns. In contrast, US federal agencies could previously operate without passed funding bills, but a ruling in 1980 deemed it illegal for governments to spend money without congressional approval, exacerbating the severity of shutdowns.

What are some key differences between the UK and US legislative processes that contribute to the differing likelihood of government shutdowns?

In the UK, only the executive branch can propose spending plans, and Parliament has limited power to amend them. In the US, Congress plays a more significant role in the budgetary process, with the power to tax and spend. Additionally, the US Senate has a 60-vote threshold to close debates before proceeding to a majority vote, making budget approval more challenging.

How do the political stakes associated with budget approval differ between the UK and the US?

In the UK, members of Parliament face the risk of triggering a dissolution of Parliament and new elections if they vote against the budget, as the government must maintain the confidence of the House of Commons. In the US, members of Congress may face political consequences for their votes on the budget, but their jobs are not immediately at risk.

What are some examples of how the UK’s parliamentary system and voting rules have prevented government shutdowns?

The UK’s parliamentary system, with the executive branch dependent on legislative support, creates a strong incentive for cooperation and compromise in budget negotiations. Additionally, the voting rules, requiring only an absolute majority in the House of Commons, facilitate budget approval.

How do the UK’s appropriation rules differ from those in the US, and how does this impact the likelihood of government shutdowns?

The UK has distinct appropriation rules, such as “votes on account,” which allow the government to obtain an advance on the funds needed for the next financial year, mitigating the risk of shutdowns. In contrast, US federal agencies could previously operate without passed funding bills, but a ruling in 1980 deemed it illegal for governments to spend money without congressional approval, exacerbating the severity of shutdowns.