Introduction

Amid rising voter disengagement and growing scepticism toward politics, proposals to restrict the number of terms elected officials may serve are seen as a means to reinvigorate political representation and restore institutional credibility. By ensuring regular rotation in office, term limits also provide a safeguard against abuses of incumbency and a response to calls for more inclusive, generationally diverse political leadership. Term limits have been proposed in various sectors not limited to elected members, including business and academia, as a means to refresh leadership and promote innovation. This reflects a trend where term limits are seen as a tool, among others, to address issues of representation and diversity, including gender and racial disparities in leadership roles (see section on 'Why introduce term limits to parliamentary mandates?' below).

The debate around term limits is not new. Term limits were used in ancient Athens and Rome to promote rotation in office, and modern term limits arose with democracy and written constitutions. The 500 members of the Athens Assembly (known as Boule) had a one-year mandate that could be renewed once in their lifetime but non-consecutively. In ancient Rome, elected magistrates (e.g. consuls, consular tribunes) served for a one-year term. To prevent the concentration of power and allow rotation of leadership, limitations were placed on how often persons could occupy the same position and how soon they could be re-elected. For instance, a consul typically had to wait 10 years before being eligible to serve as consul again.

While the idea of political rotation dates back to classical thought, including Aristotle, its modern constitutional trajectory began most visibly in post-revolutionary America.¹ Under the Articles of Confederation, congressional delegates (although they were not elected but were appointed by their respective state legislature) were limited to three terms in any six-year period (Article V). However, during the 1787 Philadelphia Convention, the proposal to include term limits in the United States Constitution was ultimately rejected. Federalists argued that such limits would undermine accountability and institutional knowledge, while Anti-Federalists feared the rise of entrenched incumbents and quasi-monarchical figures. The legacy of this debate would resurface later. Across the Atlantic, the revolutionary period in France also saw early calls for term restrictions. Inspired by American constitutional models, figures such as Robespierre and Pétion championed the idea of term limits as a means to protect revolutionary ideals. The 1791 Constitution even included a provision temporarily barring members of the Constitutional Assembly from sitting in the first legislature. However, the measure was short-lived and, after 1792, the issue largely faded from the political agenda.

In the late 20th century, term limits re-entered the American political mainstream, particularly during the 1990s reform wave associated with Newt Gingrich's 'Contract with America'. In September 1994, ahead of the upcoming Congressional elections, the House of Representatives Republican candidates signed a document, known as the 'Contract with America', which promised several reforms, should the Republicans win the elections. Among others, they proposed the introduction of a constitutional amendment to limit the number of terms a Representative or a Senator could serve in Congress. The argument was that politics should not be a lifetime job and that long-term politicians were less accountable and less responsive to electors' needs. Despite the Republican Party gaining control of both Chambers in Congress following the 1994 elections, this reform was never enacted. It is reported² that the proposal failed to gather the necessary majority/support as some Republicans and Democrats did not want to limit the people's choice during Congressional elections. They also argued that the proposal would create a situation of unjustified advantage for inexperienced 'want-to-be' legislators. Meanwhile, term limits were introduced at state level.

The US Supreme Court (SCOTUS), in US Term Limits, Inc. v Thornton, 514 U.S. 779 (1995) was called on to pronounce on the Arkansas State provision banning otherwise eligible candidates, who had already served three terms (six years) in the House or two terms (12 years) in the Senate, from appearing on the state ballot. In a 5-4 vote, SCOTUS stated that 'States cannot impose additional restrictions, such as term limits, on its representatives in the federal government beyond those provided by the Constitution'. In particular, state provisions could not violate a fundamental principle upon which American representative democracy is based – that 'the people should choose whom they please to govern them'. While federal reform efforts were unsuccessful – reiterated in Donald Trump's 2016 'Drain the Swamp' speech, the movement had more impact at state and local level. Since 1990, over 20 US states have adopted legislative term limits, many initiated by voters or citizen initiatives. These measures were credited with increasing turnover and disrupting long-standing political hierarchies. However, experts have found they also prompted unintended consequences, including a probable decline in legislative expertise and increased lobbyist influence. As a result, some State Legislators repealed their laws and several State Supreme Courts overturned term-limit laws, declaring them unconstitutional for differing reasons. As of January 2024, 16 US states maintain some form of legislative term limit, ranging from 2 to 12 years, depending on whether the limits apply consecutively or absolutely.

While the US term limits debate has been heavily shaped and driven by state-level and reform movements, the European context presents a markedly different trajectory. In the European Union and its Member States, term limits have traditionally been applied more narrowly – typically restricted to executive offices such as president, prime minister, or mayor. Legislative mandates, including those of Members of the European Parliament, are generally unlimited, reflecting both constitutional traditions and the principle of free parliamentary mandate.

Nevertheless, growing disillusionment with political elites and increased demand for institutional renewal have also begun to feed the European conversation. Public debates and party-led initiatives have periodically raised the question of limiting parliamentary mandates, although not without resistance. As this briefing explores, legal proposals, party statutes, and political rhetoric across Europe reveal a fragmented landscape in which term limits are simultaneously seen as tools of modernisation and as potential constraints on democratic choice.

An overview of the situation today

Today, few public offices around the world impose binding term limits on officeholders. Where they do exist, they most commonly apply to heads of state, heads of government or ministers. For instance, in the United States the 22nd Amendment to the Constitution limits the President to two four-year terms. In South Africa, the 1996 constitutional reform introduced a limit of two five-year terms for the presidency (Article 88(2) of the Constitution). Kenya's 2010 Constitution imposes the same two-term, five-year limit on its presidents (Article 142). After a 2008 Constitutional reform, the President of the French Republic cannot hold more than two consecutive mandates (Article 6 of the Constitution) – the difference being that France specifies 'consecutive' terms, theoretically allowing a former president to run again after sitting out two terms. In Germany, the Federal President can be re-elected only once for a consecutive term, while there are no term limits for the Federal Chancellor (the Head of Government) – for instance, Angela Merkel served four consecutive terms (2005‑2021).

By contrast, term limits for mayors vary widely across EU Member States and beyond, with no common standard. Some countries impose strict limits, particularly for larger municipalities. In Italy, mayors of cities with 5 000 to 15 000 inhabitants are limited to two consecutive terms, while bigger municipalities allow up to three, and the smallest (under 5 000 inhabitants) face no limits (Article 51 TUEL). Lithuania also limits mayors to three consecutive terms, while France, Spain, Luxembourg and Estonia impose no legal term limits, allowing indefinite re-election. In the Netherlands, mayors are appointed for renewable six-year terms, again without a cap. Some mayors, especially in smaller municipalities – such as in Spain – have held office for over 40 years. This diversity reflects differing national views on local accountability, political continuity, and democratic renewal.

The situation regarding elected Members of the European Parliament is different. For instance, no term limits apply to Members of the European Parliament or to leadership positions. According to Rule 2 of Parliament's Rules of Procedure (RoP), 'Members shall exercise their mandate freely and independently, shall not be bound by any instructions and shall not receive a binding mandate'. This provision reflects the principle of a free parliamentary mandate.

The question of internal term limits has nonetheless emerged periodically in parliamentary debate. In 2016, a group of 50 Members called for a cap on the term of the President of the European Parliament, proposing a limit of two terms – consecutive or non-consecutive. This initiative, led by now former Member Ashley Fox (ECR, United Kingdom) and backed by the European Conservatives and Reformists (ECR) Group, was widely seen at the time as an effort to prevent Martin Schulz (S&D, Germany) from serving a third term as President.

A 2019 article argues that, although term limits alone cannot narrow the distance between the electorate and Members of the European Parliament, they 'could lead to a healthier circulation of new politicians through Brussels, bring the parliament and the EU closer to citizens, and make EU policymaking even more relevant to more of them'.

Why introduce term limits to parliamentary mandates?

Research highlights several recurring themes behind the rationale for term limits. A core argument is their potential to prevent power concentration among political elites. By enforcing regular rotation, term limits are seen to enhance accountability, foster political renewal, and support more representative governance. However, term limits can have unintended effects. Studies indicate they may intensify party polarisation, as shorter legislative careers make lawmakers more reliant on party structures and less incentivised to cultivate cross-party collaboration. This can exacerbate partisan divides, rather than reduce them. It is also argued that, in fiscal terms, strict term limits have been linked to increased government spending, as reduced seniority among legislators affects bargaining dynamics and resource allocation. On a positive note, public auditors subject to term limits may exhibit stronger performance, improving transparency and accountability.

Promoting democratic renewal, addressing potential issues related to subsequent mandates, and preventing concentration of power are some of the arguments referred to by academics and political experts when discussing the need to introduce limits to an electoral mandate. Supporters of introducing term limits argue that long-serving politicians can become entrenched in their roles, potentially losing touch with the needs and concerns of their constituency. If the same group of elected officials are re-elected for extended periods, it may lead to this small group holding significant power, potentially hindering democratic accountability, which could increase the likelihood of corruption and abuse of power due to the accumulation of influence and connections. Another argument points to the need to encourage young generations to enter the political arena. For instance, to foster youth participation in political life in the EU, pundits have suggested that national parties promote issues that are of particular concern for young people as well as young candidates. They stress the importance of civic training and education in EU-related matters. Experts argue for civic and political education in schools across the EU, and stress the benefits that 'an educated electorate brings to civil society'. Inviting young people to get involved in politics (not merely during elections) and informing them about their civic rights could also empower them and help address their disengagement and disillusionment with politics.

Term limits may encourage a more diverse parliament that reflects the diversity and richness of a modern society. A number of policies are already in place at both national and EU levels to foster, for instance, the participation of women, people with disabilities, voters with migrant origins, or other under-represented groups in political life. However, this argument is not uncontested, as one source reports there is no statistically relevant difference between gender representation in parliaments with and without term limits.

Another main argument supporting the introduction of term limits stresses the need to address citizens' distrust in party politics by ensuring a turnover among elected officials. At the European Parliament in particular, this argument does not appear to be relevant, as the number of new Members sitting in the European Parliament has been consistently high at each election. In 2024 for instance, 50.6 % of the Members elected had never previously sat in the Parliament. The percentage varied between 90 % in Portugal – where 19 of the 21 Members are new to the Parliament – and 14 % in Estonia (1 in 7). Similarly, following the 2019 elections, new Members represented 58 % of the total.

Some pundits argue that, where used, the two main objectives of term limits are to address distrust towards the political elite and to curb the resulting growing abstention during elections. However, the link between term limits and election turnout is not clear. For instance, a 2017 study looking at a cross-national dataset of presidential elections held between 1950 and 2004 argued that 'voter turnout is lower in elections in which term limits prevent an incumbent president from running for office'. The article further stresses that this effect seems to be more prominent in weaker or non-consolidated democracies. However, another study, looking at the 2024 municipal elections in Costa Rica after a 2022 reform introduced term limits for mayors, argued that 'the adoption of term limits reinvigorated electoral competition but that its participatory gains were only modest, fostering turnout only in the largest cities'.

For many of these arguments, counter arguments are equally available.

The first, frequently-cited, argument against the introduction of term limits stresses that citizens should remain absolutely free to decide who they want to elect; introducing term limits would limit their choice. Moreover, in a healthy democracy, politicians are accountable above all to citizens, therefore the citizens will have the possibility to re-elect or reject them at each election. Secondly, long-serving elected officials develop a deep knowledge and understanding of societal challenges as well as legislative and institutional processes, which can be valuable for effective and responsive governance. Introducing an 'artificial' term limit could result in a loss of institutional memory 'that may lead to increase the imbalance in favour of the executive, even if the head of state and possibly ministers are not re-eligible, since the executive is seconded by a permanent public service'.⁵ Candidates running for parliament might also be less inclined to invest time and effort in campaigning and running for office if they know that their time as an elected official will be limited. Along similar lines, members of parliament might be less inclined to pursue political activities if they know that they will not have a possibility to be re-elected. It is also argued that higher turnover among politicians would lead to a higher level of inexperienced members entering parliament, which would ultimately favour a more prominent role for the executive and for interest representatives (i.e. lobbyists).

To sum up, there are arguments both in favour of and against introducing limits to a parliamentary mandate. The debate involves balancing the benefits of democratic renewal and the potential drawbacks of losing experienced leadership. Ultimately, the decision of whether or not to introduce such a term limit depends on several considerations, including but not limited to a country's specific circumstances, the role of its parliament and its accountability.