Big picture: outside the U.S., core public services keep running during budget crises. Countries build in caretaker rules, automatic or provisional funding, and constitutional backstops so there is political change (elections, new coalitions) rather than administrative stoppage.
7.1 United Kingdom — “Supply” as confidence + cashflow backstops
- Loss of supply = political event, not service halt. If a UK government cannot pass a Budget/Supply, it is treated as a confidence matter; the government resigns or seeks a general election. Civil service continues under caretaker conventions until a new administration forms. (Institute for Government explainer.) (Institute for Government)
- Cashflow bridge: The HM Treasury Contingencies Fund can advance cash “for urgent services in anticipation of provision by Parliament,” enabling departments to keep paying essential bills pending Estimates/Appropriation Acts. (HM Treasury report; Erskine May.) (GOV.UK)
So what? Even amid hung parliaments or delayed Budgets, hospitals, policing, and benefits continue to operate; the “penalty” for fiscal deadlock is political turnover, not shutdown.
7.2 Canada — caretaker government, services continue
- Caretaker period begins when a government loses confidence or Parliament dissolves; it ends when a new Cabinet is sworn in. The public service keeps operating and avoids major policy decisions without explicit authorisation. (Privy Council Office guidance, updated 2025.) (Canada)
- Operational continuity: Departments keep delivering programmes under existing statutory authority; the constraint is on new initiatives/appointments, not day-to-day services. (PCO; Canadian commentary.) (Canada)
7.3 Australia — explicit caretaker conventions + fiscal machinery
- Caretaker conventions apply from dissolution to government formation: the public service continues delivery, deferring major, contentious decisions. (Dept. of PM&C / Dept. of Finance.) (finance.gov.au)
- Election-period fiscal rules: Independent bodies (e.g., Parliamentary Budget Office) operate under special protocols during caretaker, keeping fiscal analysis running while policy decisions are paused. (pbo.gov.au)
7.4 Belgium (2010–11) — record 589 days without a formed government
- Belgium functioned 589 days without a new federal Cabinet (2010–11). Caretaker governments and month-to-month extensions of prior budgets maintained services; Parliament passed measures to continue spending while coalition talks dragged on. (Wikipedia)
Lesson: Even extreme coalition deadlock did not produce a shutdown; the state operated on provisional authority until a Cabinet was sworn in.
7.5 Germany — Basic Law Article 111 (automatic provisional budget)
- If the federal budget is not adopted in time, Article 111 of the Basic Law permits the Federal Government to continue spending on essential items (legal obligations, ongoing institutions, approved projects) up to provisional limits, often based on the previous year or a draft budget. (Basic Law text; MoF/EU documentation referencing Art. 111.) (Gesetze im Internet)
7.6 European Union — “Provisional twelfths”
- Under the EU Treaties/Financial Regulation, if the annual EU budget is not adopted, the Union may spend each month up to one-twelfth of the previous budget (with rules/ceilings) — the “provisional twelfths” system — ensuring continuity of programmes and payments. (Treaty text; 2018 Financial Regulation.) (Legislation.gov.uk)
7.7 Northern Ireland (UK) — devolved impasse without shutdown
- When the Stormont Executive collapses, Westminster may pass a Northern Ireland Budget Bill to authorise spending, or UK departments exercise powers to maintain services, even amid political deadlock. (UK Commons Library briefing.) (Parliament Research Briefings)
- Public services have faced strain and under-funding during prolonged stalemate, but they do not stop; the problem is service quality, not legal authority to spend. (Recent reporting.) (The Guardian)
7.8 What these cases have in common
- Continuity by design: Legal or constitutional mechanisms (caretaker rules, contingency funds, provisional budgets) keep the state running.
- Political, not administrative, consequences: Failure to pass a budget triggers elections, confidence votes, or coalition reshuffles — not a halt to payrolls or permitting.
- Statutory baselines: Many programmes have standing or multi-year appropriations; where gaps exist, provisional authority fills them.
7.9 Contrast with the United States
| Feature | U.S. | UK/Canada/Australia | Belgium | Germany | EU |
|---|---|---|---|---|---|
| System type | Presidential separation | Parliamentary | Parliamentary coalition | Parliamentary-federal | Supranational |
| If budget not passed | Shutdown of non-excepted activities (Antideficiency Act) | Loss of supply → political change; services continue | Caretaker + provisional extensions | Art. 111 provisional budget | Provisional twelfths |
| Continuity mechanism | None automatic; needs CR/new law | Caretaker conventions + cash advances (e.g., Contingencies Fund) | Parliamentary stop-gaps | Constitutional fallback | Treaty/Regulatory fallback |
7.10 Take-away
Outside the U.S., legal continuity is the norm: when politics stalls, governance persists. The U.S. is the outlier because a strict reading of the Antideficiency Act, combined with multiple veto points, forces agencies to cease unfunded operations rather than coast on provisional authority.
References
- European Union (2018) Financial Regulation (EU, Euratom) 2018/1046. Brussels: EU. Available at: EUR-Lex (Accessed 9 Nov 2025). (EUR-Lex)
- European Union (n.d.) Treaty provision on provisional twelfths (ex-Art. 315 TFEU). Available at: legislation.gov.uk (Accessed 9 Nov 2025). (Legislation.gov.uk)
- Federal Republic of Germany (n.d.) Basic Law (Grundgesetz), Art. 111. Available at: Federal Ministry of Justice portal (Accessed 9 Nov 2025). (Gesetze im Internet)
- HM Treasury (2024) Contingencies Fund Account 2023–24. London: HM Treasury. (GOV.UK)
- Institute for Government (2019) ‘Unclear constitutional rules add to uncertainty in a hung parliament’. London: IfG. (Institute for Government)
- McCarthy Tétrault (2021) ‘What you need to know about the caretaker convention’. Toronto: McCarthy Tétrault. (mccarthy.ca)
- Northern Ireland Budget Bill (2017) House of Commons Library Briefing CBP-8122. London: UK Parliament. (Parliament Research Briefings)
- Progressive Policy Institute (2013) ‘How Belgium Survived 20 Months Without a Government’. Washington, DC: PPI. (Progressive Policy Institute)
- UK Parliament (n.d.) Erskine May: Contingencies Fund. London: UK Parliament. (erskinemay.parliament.uk)
- Wikipedia (last updated 2025) ‘2010–2011 Belgian government formation’. (Used for chronology cross-check; primary facts corroborated via PPI piece and press.) (Wikipedia)
- Australia Department of Finance (2025) ‘Grants process – caretaker conventions link’. Canberra: DoF; and Parliamentary Budget Office (2024) Guidance 2/4 – Costing policy proposals during the caretaker period. (finance.gov.au)
- Privy Council Office (2025) Guidelines on the conduct of Ministers, Ministers of State, exempt staff and public servants during an election. Ottawa: PCO. (Canada)