As we prepare for another election under the Mixed Member Proportional (MMP) system, it is worth noting that New Zealand is one of the few nations to have adopted this electoral model. The majority of countries still either opt for First-Past-the-Post or purely proportional systems. Another country that uses MMP is my native Germany.
However, there are even differences between countries using MMP, and as a German-born New Zealander, I cannot help but notice them at each election.
I am not saying that one or another version of MMP is better, but I find it quite remarkable how the same electoral system can feel so different depending on how it is run.
Now, I would not expect anyone in New Zealand to be familiar with the way Germany runs its MMP elections, and you probably need to have lived in both countries to appreciate the differences.
So let me take you through MMP in both its New Zealand and its German flavours: The same system, but different.
To begin with, the frequency of elections using the MMP system varies greatly. In New Zealand, we have a single MMP election every three years. Our parliamentary term of three years is short, but, unlike Germany, there are no state elections in between our general elections.
The story in Germany is quite different. With 16 federal states, each conducting its own parliamentary election – most with five-year terms – the arithmetic results in approximately one MMP election somewhere in Germany every three months.
Even when it is ‘just’ a state election, the whole nation watches because they are regarded as important indicators of the nationwide mood. Next weekend, for example, the states of Bavaria and Hesse will go to the polls. Together, they account for about a quarter of Germany’s population, and the outcomes will be watched closely all over the country.
The approach to early voting offers another point of divergence. In New Zealand, voters can cast their ballots any time in the two weeks leading up to election day. It is an increasingly popular option that adds flexibility to the voting process.
Germany does not share this penchant for pre-voting, at least not at polling stations. Instead, early voting is primarily conducted through postal ballots. But in some states, postal voting now starts six (!) weeks before the actual election day.
Then there is the atmosphere on election day itself. New Zealand opts for a quieter, more subdued environment. Legal restrictions require that hoardings be taken down, and public discussions about the election are kept to a minimum. This is a relic from a time when there were fears of undue influence.
Germany, by contrast, embraces the moment with fervour. Television and radio are filled with political discourse. While voters are still considering who to vote for, the experts on TV are already discussing coalition possibilities.
The biggest difference extends to how results are presented in the media. In Germany, once polls close on a Sunday at 6pm (not 7pm on a Saturday as in New Zealand), the two main public broadcasters, ARD and ZDF, promptly offer their ‘prognoses.’ These are highly accurate, scientifically derived predictions based on exit polls. They offer a clear picture of the likely outcome, and at 6.01pm the election night is practically over, unless the result hinges on a party making it across the 5-percent threshold by a few votes or not.
In New Zealand, we generally find ourselves on tenterhooks for much longer. Exit polls would not just be expensive to conduct but they are, in fact, illegal. Results from the electorates trickle in gradually, creating an atmosphere of suspense that endures for hours.
Another point of departure lies in the way the media discuss the outcome. Perhaps owing to our First-past-the-post history, New Zealand’s coverage often focuses heavily on individual constituencies. Viewers can expect a detailed rundown of who won each electorate seat, a crucial aspect of the election.
Germany’s media, on the other hand, places greater emphasis on the party vote, reflecting the prominence of party politics in shaping government. Viewers may hardly hear about individual constituency outcomes in the main broadcasts.
The final result of any German election is usually announced around midnight after the election. That is because in Germany, postal ballots must arrive by election day so they can be counted alongside the in-person votes.
In New Zealand, on the other hand, the presence of ‘special votes’ adds a layer of complexity and delay. These votes can be returned up to 10 days after election day and must be counted in the electorate where they were cast. This delay can change the number of seats a party ultimately gains, prolonging the final outcome for weeks.
The timing of coalition negotiations also contrasts sharply between the two nations – partly due to the differences in the time it takes to confirm a final result.
In Germany, because matters are usually clear early on, leading politicians discuss potential coalitions in a special TV broadcast just two hours after the polls close – on nationwide TV, even after state elections.
In New Zealand, on the other hand, the outcome is usually less clear-cut, and weeks can pass before a government is formed.
Lastly, the treatment of overhang mandates also differs between the two nations. In New Zealand, a party can end up with more electorate seats than its total share of seats based on the party vote. These are called ‘overhang’ seats, which can materially change the election outcome.
In Germany, a similar scenario would result also in compensatory seats being added for other parties, ensuring proportionality. While this practice maintains fairness, it has the drawback of further inflating the size of the parliament.
One final point: in Germany, the number of list seats matches the number of electorate seats. In New Zealand, the number of list seats is fewer than that of electorate seats, even though the final result will still be proportional to the party vote.
In sum, while both Germany and New Zealand employ the MMP system, the quirks and intricacies of its application in each country make for a markedly different democratic experience.
Perhaps, deep down, the differences are mainly cultural. Despite having an MMP system, New Zealand still approaches elections as an FPP affair, especially with its focus on constituencies.
In any case, voters in both countries have voices. They are just heard
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