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I appreciate that the USA has a larger population and more layers to it system of governance, but I don't understand how the UK can transition between governments practically overnight and the USA takes two months. The UK might not be the flawless in its execution of the transition but they managed to maintain a reasonable continuation of government, but spending 5% of a term with a lame duck president seems very damaging to a country. So just how does the UK manage to transition leadership so quickly compared to the USA? Why are there so many appointments to fill compared to the UK?

(I appreciate that other countries, especially in the EU, waste large amounts of time trying to form governments but it's the transition time that I'm specifically asking about)

(This question is not a duplicate of do any other countries take as long as the us to transfer government power that question is asked and answered more broadly, and the answers around Prime Minsters are largely looking at countries which have a caretaker system in place)

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    Thank you I hadn't seen the question, but I'm not sure it really answers the question. I'm familiar with the UK shadow cabinet and their function, but I'm just not convinced that having 21 shadow cabinet members on stand-by makes the difference between a 1 day handover and a 2 month handover. – gingerbreadboy Nov 25 '20 at 14:05
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    Closely related (though not identical): politics.stackexchange.com/questions/826/… – Steve Melnikoff Nov 25 '20 at 15:38
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    citizens vote Nov 4. Counts are due December 8 (long time due to counting, horse transport, and recounting, and more horse transport). Electors vote December 14. Those votes counted January 6 (more horse transport), (this is the day we find out who officially won the presidency), then January 20 is inauguration. So there's only 14 days between the final vote and inauguration, officially. – Mooing Duck Nov 25 '20 at 23:07
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    I'm not sure I'd agree it's a "waste of time" if it's a feature of the chosen electoral and parliamentary system that governments were difficult to form. – gktscrk Nov 26 '20 at 6:24
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    @gingerbreadboy There are other factors in addition to those already provided in the current answers to this question and the answers to the linked questions. One is that there are essentially two to three lost weeks between election day and inauguration day thanks to Thanksgiving Day, Christmas Day, and New Years Day. – David Hammen Nov 26 '20 at 8:41
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Two factors in the UK allow a very quick change of government when an election delivers a decisive result:

  1. There is a permanent government-in-waiting in the form of the Official Opposition. Typically, the Leader of the Opposition becomes Prime Minister, and then tends to appoint shadow ministers to the positions that they were previously shadowing (though not always, and the LotO has more-or-less a free hand to appoint whomever they want from available MPs and peers, with the option of appointing more peers to fill other jobs).
  2. The number of appointed roles is tiny compared to the US - a little over 100, compared to many thousands in the US. In addition, there's no equivalent to Senate confirmation.

As a result, a new PM can be in place the day after the election, with the most important roles filled soon after. More junior posts tend to take a few more days to be appointed.

(My own answer to a related question goes into a bit more detail, with sources, on the numbers in the UK vs the US.)

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    You've also got to take into account a large, largely permanent upper civil service who're happy to serve whichever master is in the hot seat that week. – Valorum Nov 25 '20 at 22:57
  • @Valorum: indeed; see my linked answer and its comments. – Steve Melnikoff Nov 25 '20 at 22:59
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    @Valorum Exactly. unlike in the US where many thousands of civil service positions change with each administration, the UK civil service remains intact. The reason is simply that it serves the Crown (which is permanent) and not the Government (which is ephemeral). For example, we have Her Majesty's Revenue and Customs, Her Majesty's Treasury inter alia. – Oscar Bravo Nov 26 '20 at 8:31
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    This is a good answer, but one other thing I'd add is that a lot of preparation for transition can be done before the election - the Institute for Government has an excellent paper (albeit from 2009) breaking down the different stages. I'd particularly highlight the contact with the Civil Service as significant - it's not just that they're able to remain in post to serve a new government, it's that they've already been able to start preparatory work. – Andrew Nov 26 '20 at 12:54
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    Another factor, I would suggest, is in the way that a UK general election delivers an immediate and definitive result. There being 650 constituencies each representing roughly 100,000 constituents, makes it simpler to count and administer. It is basically all done over one night and all MPs officially declared on the spot. In the US, the result may well be "called" by news channels, but it then takes several weeks to produce anofficial result for each state. And then the Electoral College has to meet. – WS2 Nov 26 '20 at 17:33
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In addition to what is already mentioned in the other answers, I would like to point out that you are both overestimating and underestimating the time the transition takes in the US.

The US Presidential Election is an indirect election. In the election on November, 4th, the citizens of the USA did not elect the President. They elected the Electoral College. It is the Electoral College that elects the President, and this vote does not happen until December, 14th. So, if you are simply counting from election to inauguration, then the transition period is actually only five weeks. And the votes are only counted on January, 6th, so if you are counting from the moment that we know who the winner is, then that is only two weeks.

On the other hand, about 1000 of the political appointees require Senate confirmation, and these confirmation hearings can drag on for months! So, if you count from election to having every single member of Cabinet, every agency Director, etc. installed and confirmed, that can require the better part of a year.

The appointees are really the crux here. In the UK and many other countries, the overwhelming part of the government bureaucracy are professional bureaucrats with no political affiliation. Their job is simply to enact the will of the government, whoever that may be. Only the very top level of bureaucracy are political appointees, and only this top level needs to be exchanged.

In the US, however, political appointees go much, much lower into the actual nuts and bolts of the bureaucracy. There are thousands and thousands of posts that will need to be filled, and as mentioned above, up to 1000 of those posts require Senate confirmation. Consider that the Senate will likely have a Republican majority when Joe Biden is inaugurated, and you can imagine that that is not easy.

Not only is it the case that simply filling all those thousands of positions takes very long, there is an additional problem: because this change is so deep, a lot of institutional knowledge is lost every time the administration changes. In order to prevent that from happening, there need to be lengthy handovers between the old and new bureaucrats. In a country like the UK, the same person works in the same department maybe for decades, and then has multiple years to train their replacement. This works to preserve institutional knowledge.

And let's not forget that every one of those multiple thousand appointees may have an entire staff of their own, or at least a secretary or an assistant.

All in all, the really simple answer is: there is just a lot more stuff to do.

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The second factor in @SteceMelnikoff's answer results from the UK having a permanent civil service. The most radical possible effect on any government department of a change in leadership is receiving a new Minister (roughly equivalent to US Secretaries in that both are appointed by the Head of Government), who may or may not be from the predecessor's party.

The most senior member of the civil service in a given department is called a Permanent Secretary, and all the knowledge needed to continually run the minutiae of the department rests with them and the civil servants closest to them. The Cabinet Secretary plays a similar role over and above all departments, and is the head of the Civil Service. So when there's a new Minister (Prime Minister), the Permanent (Cabinet) Secretary just gives them some notes to get them up to speed, for when they want to declare new policies.

And the Civil Service continually prepares white papers on every policy request they can conceive, based on prior Ministers of every party, manifesto policies, and so on. (Prior to elections, parties list policy commitments in a printed form called manifestos; these are the main basis of legislative efforts should they win, and manifesto policies face less opposition from the Civil Service and House of Lords than do mid-term policy decisions.) This is more feasible than it may sound. Because Cabinet members are almost entirely appointed from the House of Commons, especially senior party members in safe rather than marginal constituencies, there are only ever so many possible new Ministers who need to be on the radar.

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    I'm trying hard to resist the temptation to recommend as references the sitcoms Yes, Minister and Yes, Prime Minister, which are all about how power is divided between Secretaries and Ministers, due to the former's permanence. – J.G. Nov 26 '20 at 18:12
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    I would upvote this for the comment alone. Sir Humphrey Appleby (as well the minister he is destined to serve under) are quite relatable. In my humble opinion the real question here is Why does the United States NOT have a permanent civil service? – Jyrki Lahtonen Nov 28 '20 at 8:47
  • Mind you, some internet acquaintants (from UK) implied that some debacles around Brexit were caused by the fact that special advisors and such have popped up. "Insulating" the ministers from the more knowledgeable civil servants. – Jyrki Lahtonen Nov 28 '20 at 8:53
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    @JyrkiLahtonen Apropos special advisers: my understanding is that what you have heard is correct, and that there has been friction between them (as political appointees advising the minister) and the career civil servants; that's particularly the case when the advisor has stepped outside his role as a party animal and attempted to issue instructions. They came to prominence in the Blair government which also tried to dilute the civil service role, the result was that at least one minister complained that she was inadequately trained for her job which now required supervising minutiae. – Mark Morgan Lloyd Nov 28 '20 at 14:11
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    @CSM: For parliamentary states, there is always a government with ministers - not civil servants - in charge, even if it's in a caretaker capacity, and it's typically the incumbent government that does this. Northern Ireland is the outlier here, as due to its unusual constitutional make-up, it really didn't have a devolved (i.e. local) government. IIRC, civil servants kept things ticking over, while the government in London stepped in to legislate for Northern Ireland when it became necessary. – Steve Melnikoff Nov 28 '20 at 23:27
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I appreciate that the USA has a larger population and more layers to it system of governance, but I don't understand how the UK can transition between governments practically overnight and the USA takes two months.

It doesn't take two months. Or at least, it wouldn't if everyone just knuckled down and got on with it. Indeed, it used to be much longer. The original text of the constitution makes no mention of a start date for a presidency. Once the Constitution was adopted, a proto-congress set the date of March 4th as the beginning of the new Government (and since the Constitution DID specify terms, also the start date of all future governments):

During the summer of 1788, the Constitution was ratified by the final few states needed to put the new government in place. In response, meeting during the following September, the Confederation Congress adopted a resolution fixing March 4, 1789, as the date “for commencing proceedings” under the new government. As a result, the terms of the first President, Vice President, Senators, and Representatives began on March 4, and because the Constitution states that those terms are to last for four, four, six, and two years, respectively, they would end on a future March 4.

And elections were subsequently legislated as falling on "the Tuesday next after the first Monday in the month of November", leading to a ~4 month interregnum. The reasoning for that timing is usually given as being after harvest time, but before the onset of winter's foul weather made travelling to vote difficult. So, the original gap was kinda a mixture of legislative accident and, probably originally necessity - members of government were spread across distances that could take weeks to communicate over, and longer to cross - particularly given people invited to Washington from their homes would necessarily have to tie up most of their affairs at home (since it'd be harder to make on-the-fly decisions about events) and additionally bringing much of a household with them (can't exactly fly home on weekends).

This was eventually cut back a bit by the 20th Amendment to the current 2 month period. The retention of the still lengthy gap is most often attributed (at least that I have seen) to lame-duck Senators and Congressmen opposing all efforts to change it - after all if they're voted out then they're benefited most by having as lengthy a time as possible to make any changes they want without having to continue pandering to the electorate.The 2 month gap was basically a compromise.

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The US has set up a series of important dates that fix the duration of the transition process. Election Day is the Tuesday after the first Monday in November. On this day, the Electors that elect the President are elected. On the first Monday after the second Wednesday in December, the electors of each state (and DC) gather in their state’s capital (or in Washington DC) and cast their votes for President which are then sent to Congress. On 3rd January, the new Congress (the newly elected House of Representatives and the Senate which has rolling terms) meets for its inaugural sessions. On 6th January, Congress meets in a joint session to count the votes cast for President and on 20th January this elected President is inaugurated.

With the exception of casting and counting votes, these processes occur automatically, i.e. no formal inauguration is needed for the new President’s term to begin on 20th January at noon Eastern. However, all these dates are set in stone by statute or constitution/constitutional amendment. So even if the incoming President were willing to speed things up and the outgoing President agrees they cannot modify the dates the constitution, amendments and statute set out.

The UK’s political system has grown over centuries and there is no single consolidated document that one could call ‘constitution’. In addition to that, the Office of Prime Minister essentially receives its power not from a popular vote but through appointment by Her Majesty. There is no term length or limit set and although the Prime Minister should (by convention, not by statute) command a majority in the House of Commons, the appointment of a Prime Minister does not depend on any act that the House of Commons or anyone other than the Monarch performs.*

Therefore, as soon as the results of an election are known a defeated Prime Minister can declare their resignation suggesting that the hitherto Leader of the Opposition be appointed their successor, even if Parliament is still out of session due to the election. Parliament need not act but the Queen will appoint the new Prime Minister.

Indeed, there is good reason for the new British Prime Minister to be appointed before Parliament meets and indeed well ahead: the State Opening of Parliament (the first day of business to begin a new session) traditionally includes a speech from the throne. This is by modern convention a speech the Government writes for the Queen to read. As it details the new Government’s goals and outlines the legislation it intends to introduce, it should be written by the incoming Government which necessitates a very rapid transition after an election.

By contrast, in many other parliamentary democracies (e.g. Germany), the term of a leader of government (here: Chancellor) is tied to that of the parliament (here: Bundestag). Thus, if the Bundestag constitutes itself before a coalition government has been formed, the President is required to re-appoint the former Chancellor as chargé d’affaires to ensure continuous government even if they lost the election as was the case in 2005. While formally the Chancellor is appointed by the President that is done on the advice of the Bundestag so a formal Bundestag vote is required for a new Chancellor to take office – even if the new one is the old one. The transition thus cannot be faster than constitution of parliament post election but it can definitely be slower.


* While typically a motion of no confidence will either lead to an election being called or a Government resigning, I have not found any source stating that the resignation of a Prime Minister be automatic following a successful no confidence motion. While the Prime Minister will be unable to continue governing, it would, in my understanding, still depend on the Queen to dismiss them and appoint a successor if the Prime Minister refuses to resign for whatever reason. Indeed, another answer suggests precisely that it is within the Queen’s powers to dismiss a Prime Minister if they refuse to resign but no longer command a majority.

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  • The Fixed Term Parliaments Act does set a maximum term length of 5 years, but that is just a normal law, so can be changed by any government that controls a majority. – user1937198 Nov 26 '20 at 11:43
  • I think this is a good answer. I'd argue that the convention about the PM commanding a majority in the Commons is as much about practicality as anything else; a government which can't pass its legislation - and even more crucially, can't pass its budget - will struggle to govern. – Steve Melnikoff Nov 26 '20 at 12:07
  • Re Queen's Speech: in theory, it can be delayed if necessary, if parties need more time to form a government. What's not clear is what would happen if the UK were to have a Belgium-style situation, if it were to take weeks or months (or more) to form a government. Parliament can't legislate without a Queen's Speech, but it's unclear what a caretaker government could put in such a speech. – Steve Melnikoff Nov 26 '20 at 12:12
  • "...even if Parliament is still out of session due to the election." That's guaranteed; Parliament doesn't meet until a week or two after the election; the Commons then elects its Speaker, and spends a week swearing everyone in. Only after all that has happened do we get to the State Opening and the Queen's Speech. – Steve Melnikoff Nov 26 '20 at 12:15
  • Also related to this, the fact that the UK has an evolving constitution means that it adapts more easily to changing circumstances. As communications have become faster over the centuries, the timescales have shortened, without the need for anyone to get a super-majority in favour of shortening them. (Not that the flexibility of the constitution doesn't also have its own set of problems...) – Michael Kay Nov 27 '20 at 15:29
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Remember that the U.S. Constitution is difficult to change, especially these days, especially the election part.

The various time limits were baked into the constitution back when horseback was the only way of transporting elected politicians from far-off states to the Capitol. "Don't you dare start (the graft?) without me!". The U.S.A, even the original 13 colonies (Maine to Georgia), were spread along 1,295 miles (2,084 km) straight line distance.

In the U.S., election winners come from each state, from each electoral district, and must travel to the Capitol (Philadelphia? ) to govern.

In England, a King is crowned. his governing authority radiates from a central point.

Inverness to London is 903km (561 miles). Less than 1/2 the distance.

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