Core finding: other systems turn a budget impasse into a political event (caretaker government, election, coalition deal) while services continue via legal backstops (contingency funds, interim budgets, “provisional twelfths,” etc.).
14.1 United Kingdom — Supply as Confidence + the Contingencies Fund
- What happens in a crisis: Failure to pass “supply” is treated as a confidence matter; the government resigns or seeks an election. The civil service continues under caretaker conventions.
- Cashflow backstop: HM Treasury’s Contingencies Fund advances cash “for urgent services in anticipation of provision by Parliament,” letting departments keep paying bills pending Estimates/Appropriation Acts. Recent Accounts (2023–24 and 2024–25) set out usage and controls. (GOV.UK)
- Example in practice: Ministers sought Contingencies Fund advances to bridge defence spending until Supplementary Estimates received Royal Assent (Hansard, 29 Feb 2024). (Hansard)
Take-away: UK continuity is financial (Treasury advances) and constitutional (confidence rules) — no shutdown.
14.2 Canada — Caretaker Conventions (PCO)
- Caretaker period: Begins after a loss of confidence or dissolution; ends when a new Cabinet is sworn in. Public services continue; departments avoid major new initiatives without explicit approval. Official guidance was updated in March 2025. (Canada)
- Practice notes: Legal authorities for ongoing programmes persist; the restraint is on policy discretion, not day-to-day delivery. Supplementary briefings emphasise how operations proceed during elections. (Government of Canada Publications)
Take-away: Political reset, administrative continuity.
14.3 Australia — 1975 Supply Crisis (the “Dismissal”) and Modern Caretaker Rules
- Historic stress test (1975): Senate blocked supply; Governor-General dismissed PM Gough Whitlam on 11 Nov 1975, appointing Malcolm Fraser caretaker on condition he secure supply and call an election. The Senate then passed supply; both Houses were dissolved. (naa.gov.au)
- Today’s operation: Detailed Guidance on Caretaker Conventions (PM&C) explains that public services continue, deferring contentious decisions until after the election. (PM&C)
Take-away: Even at maximum political drama, services kept running; the remedy was electoral, not administrative shutdown.
14.4 Belgium — 589 Days Without a Formed Government (2010–11)
- Record coalition deadlock: Belgium went 589 days without a new federal Cabinet. The state operated under caretaker governments and extended prior-year budgets by parliamentary measures. Essential services continued. (Bundesministerium der Finanzen)
Take-away: Extreme coalition fragmentation produced political paralysis but no shutdown of services.
14.5 Germany — Constitutional “Interim Budget” (Basic Law, Article 111)
- Automatic continuity: If the budget is not adopted in time, Article 111 allows the Federal Government to continue spending (e.g., legal obligations, ongoing institutions) within defined limits — effectively an interim budget until appropriation passes. (Gesetze im Internet)
- Recent, real example (2024–25): Germany explicitly operated on an interim budget based on Article 111 while the 2025 Budget Act was pending; official reports detail expenditure ceilings and the transition back to full appropriations. (Bundesministerium der Finanzen)
Take-away: Continuity is constitutionalised; no legal space for shutdowns.
14.6 European Union — “Provisional Twelfths”
- Rule: If the annual EU budget is delayed, the EU can spend each month up to one-twelfth of the prior budget (“provisional twelfths”), with safeguards and ceilings in the EU Financial Regulation. (EUR-Lex)
Take-away: A built-in, rules-based stopgap preserves operations across institutions and programmes.
14.7 Northern Ireland (UK) — Devolved Deadlock Without Service Stops
- When Stormont collapses: Westminster can pass a Northern Ireland Budget Bill or authorise spending to maintain services during executive suspensions. Service quality can strain, but operations continue. (House of Commons Library briefings; recent press.) (EUR-Lex)
Take-away: Political impasse → intervention/bridging budgets, not shutdown.
14.8 What These Cases Teach the U.S.
- Continuity by law: Systems embed automatic or ministerial authority to keep paying for core functions.
- Confidence logic: Budget failure is resolved politically (election, coalition deal) rather than by stopping administration.
- Bridging finance: Funds like the UK Contingencies Fund supply cashflow until Parliament regularises appropriations.
- Transparency & limits: Mechanisms are bounded (caps, monthly fractions, reporting), protecting the purse while avoiding service collapse.
References
- ABC News (2025) ‘The inside story of Gough Whitlam’s dramatic 1975 dismissal’, 9 November. (ABC)
- Australia, Department of the Prime Minister & Cabinet (2024) Guidance on Caretaker Conventions. Canberra: PM&C. (PM&C)
- Germany, Federal Ministry of Finance (2025) ‘Overview of federal budgetary and financial data… (interim budget under Article 111)’, Monthly Report, 20 June. (Bundesministerium der Finanzen)
- Germany, Federal Ministry for Economic Affairs (2025) Annual Economic Report 2025 (notes interim budget management). Berlin. (Economics & Energy Ministry)
- Government of Canada, Privy Council Office (2025) Guidelines on the conduct of Ministers, Ministers of State, exempt staff and public servants during an election (Caretaker). Ottawa. (Canada)
- HM Treasury (2024) Contingencies Fund Account 2023–24. London: HMT; and GOV.UK notice (2024–25). (GOV.UK)
- Hansard (2024) ‘Contingencies Fund Advance: MOD 2023–24 funding’, House of Commons, 29 February. (Hansard)
- National Archives of Australia (n.d.) ‘The Dismissal, 1975’. Canberra. (naa.gov.au)
- European Union (2018) Financial Regulation (EU, Euratom) 2018/1046 (provisional twelfths). Brussels: EU; EUR-Lex. (EUR-Lex)
- Wikipedia (cited for chronology only) ‘1975 Australian constitutional crisis’ (cross-checked against ABC and NAA). (Wikipedia)