What are the major differences between Parlimentary and Presidential systems.

February 28, 2007 6:58 PM

What are the major differences between the Presidential system of government that people in the US are familiar with and the Parlimentary system which much of western europe has adopted.

I've done some snooping around the interwebs, but haven't found a really clear answer to this question so if someone has a link to a good article or page, I'd appreciate it.

And yes, I'm aware that this is like first year poli-sci. It's been a while :)

posted by KenFox to law & government (34 comments total)

I'm assuming that you're familiar with the US system, so why not look at the world's cliffnotes: Wikipedia.

Politics of the United Kingdom
posted by chrisamiller at 7:21 PM on February 28, 2007

In parliamentary systems (at least those descending from the English tradition), cabinet ministers are typically seated members of the House. In the American system the cabinet is appointed by the President, and those appointed to the cabinet are not usually responsible to a specific constituency.

Committee chairs in the House and Senate play a similar role to that of ministers in parliament, but the fact that the executive has an independent and unelected cabinet (I find) makes a huge difference.
posted by TheWhiteSkull at 7:30 PM on February 28, 2007

In the US, the people elect a representative, and the people seperately elect a person who will cast a vote for a president. The representatives ratify laws, the president has veto power, but can be overridden.

In the UK, they elect a representative, and all the representatives get together and vote for a prime minister. The representatives ratify laws, some unelected representatives ratify them, too, and the Queen has veto power, but cannot be overridden (afaik).
posted by TheNewWazoo at 7:32 PM on February 28, 2007

Better Wikipedia link: Westminster system. The UK and a few other places have a relatively pure Westminster parliamentary government, but a majority have blended systems -- a parliamentary legislature, but an independent executive with varying degrees of power.

The major difference probably comes down to the vote of confidence. There are many structural differences, but they amount to finessings of the how. The vote of confidence can be held if the government is in crisis, and at the least will force the current government to form a new cabinet, at the most force new elections.

One of the more silent changes in the American system during my lifetime has been the denouement, you may call it, of any kind of cabinet government in the US. We just have too many cabinet-level positions now for any one of them to be effective, and the current administration has effectively abandoned regular cabinet meetings. The department secretaries have almost no political visibility, or power, as a result.

In the UK system, cabinet ministers have considerable independent power comparable to the head of a Senate committee. There is, therefore, a greater emphasis on harmonious constituency relations.
posted by dhartung at 7:34 PM on February 28, 2007

I'll add (based on Canada, which uses the Westminster system as well, and also has the Queen of England as its head of state) that the Queen (actually her representative to Canada, the Governor General) does have veto power that cannot be overridden, but this is a totally ceremonial. If she ever actually used that veto power, you can bet she wouldn't be our head of state for much longer.
posted by Emanuel at 7:40 PM on February 28, 2007

Oh dear - here's where I prove that all those polisci courses weren't wasted on me.

Well, Western European countries use different types of parliamentary systems; France uses mixed Presidential-Parlimentary. I think the easiest way to answer your question is to compare the American system to the Westminster-style parliament in use in other English-speaking countries (with some variation, of course).

The key difference is that the American system is one of representative government, while the Westminster system is one of responsible government, which means that the Executive is responsible to the Legislature, and requires its confidence to remain in power.

While in the U.S. system, the Executive (President and Cabinet) are separate from the Legislature, in Westminster parliaments the Prime Minister and Cabinet are also elected legislators. They sit in the House of Commons (or the Upper House, though of course that's unusual these days; after the last Canadian election, for instance, a Senator was appointed Minister of Public Works, but that was highly unusual). If the government loses a vote on a matter of confidence (such as the budget, a motion of non-confidence, or any other matter which the government declares to be a confidence matter), then the government (Executive) falls. This means an election must be called. No such parallel exists in the U.S. system; if President Bush fails to get a bill passed that he has sent to Congress, nothing happens. If there is a budget impasse between the President and Congress, the government (i.e. the functions of the bureaucracy) may shut down, but the Executive need not resign.

Thus, Americans and those in Westminster systems use the word "government" in different senses - Americans to mean the institutions of the state; others to mean both that and the Executive (and, in common parlance, legislators who are from the governing party or coalition - "members of the government; government MPs" - who are not actually part of what is strictly the government, i.e. Cabinet).

So, the American system is predicated on the separation of powers, and checks and balances, while Westminster systems fuse the Executive and Legislative branches of government. However, in Westminster systems the head of government and head of state are distinct. The head of state is (at the moment, in a lot of places, and for the purpose of this illustration) the Sovereign - i.e. Her Majesty Queen Elizabeth II (Long May She Reign, yada yada). The head of government is the prime minister. The Queen is represented by vice-regents when she is not in town - in Canada, we have the Governor-General at the federal level and Lieutenant-Governors in each of the provinces. The head of state is basically a figurehead, but the separation of the functions is quite crucial in ensuring stability in the whole system. One of the reasons that the Presidential order of succession is so important is that the President is the head of state - without a President, the whole system is in jeopardy. If the Prime Minister kicks the bucket, no one worries about the whole system collapsing, because the head of state just recognizes another prime minister. If the election is in doubt, there is no deadline by which the dispute need be resolved or the country is left without a head of state. And finally, the head of state is there to prevent any chicanery - if a prime minister called an election and lost but refused to resign (which is what he technically does before the head of state asks someone else to form a government, which must pass its Speech from the Throne in the House to demonstrate it has the confidence of the House), and instead showed up at the palace/residence and said, "I would like you to issue the writs for another election," she would say no.

Anyway, I could go on, but I probably shouldn't. Again, key differences:

1. Representative v. Responsible Government - fusion of executive and legislative branches; executive responsible to legislature
2. Unified head of state and government v. bifurcated head of state (Crown) and government (Ministers of the Crown)

If you want to know more about Responsible Government, you can do no better than reading this: Responsible Government: Clarifying Essentials, Dispelling Myths and Exploring Change.

A few final observations: the part about the government being "responsible" to parliament is what stops governments in Westminster systems from being elected dictatorships. There was a time, not so long ago (early 19th-Century), when in Canada, for instance, the British basically decided who they wanted to be government, and they appointed them Ministers. Even if the population elected a legislature opposed to the government, the most they could do was stop them passing laws, not stop them from governing through Orders-in-Council, because the executive was not responsible to them. But if a government today has a majority in the legislature, it can pass bills and there's very little the opposition can do about it, except make a stink.

It's worth noting that while the President of the United States is always called the most powerful man in the world because of the huge power of the United States, he's actually much less powerful within his own system than Prime Ministers are in theirs, especially if they have a majority government.

As I said at the beginning, there's plenty of variation among European systems. But I'm going to stick to what I really know about. Hope this helps.
posted by Dasein at 7:43 PM on February 28, 2007 [4 favorites]

Put in one line.

The major difference between a Parliamentary system and a Presidential system is that control the executive (i.e. the people who run the government) and the legislature (i.e. the people that make the laws) are the same thing in a Parliamentary system whilst in a Presidential System the executive is a separate entity from the Legislature.
posted by sien at 8:00 PM on February 28, 2007

Oh, one more link. Sorry these are a little Canada-specific, but they will give you a really good picture of Canadian government, and since it's quite similar to other Westminster systems in a lot of ways, it may be helpful. It's called How Canadians Govern Themselves, and if you read it together with the link above, you'll know more about the Canadian variety of responsible government than most Canadians.

Note that Britain, unlike Canada, doesn't have a written constitution. "Written constitution" means "codified constitution" - you have to read lots of different British Acts of Parliament to understand how the government functions, and they have no Bill of Rights. Canada has the British North America Act (now called the Constitution Act 1867) and the Constitution Act 1982, which includes the Charter of Rights and Freedoms, and American-style Bill of Rights (which, paradoxically, a lot of Canadians use to define their country).

The document goes into more detail than you'll want about Canadian government, but some sections will be useful for explaining how responsible governments work - the governing party is the party with the most seats in the House after a general election, etc.
posted by Dasein at 8:02 PM on February 28, 2007

Let's play a mind experiment. Let's say the United States is a parliamentary democracy.

The most powerful political figure in the US would not be the President - it would be the House Majority Leader, Harry Reid* - aka the Prime Minister.

The Cabinet (Secretary of Defence, Treasury, State) are not appointed by the president, but are drawn from the ranks of the Congress and the Senate and are almost always members of the party that hold the majority in the lower house (in this case, the Democrats). They are chosen by the Majority Leader (PM).

Laws are introduced and debated in the Congress and must pass both houses.

There is still a President, and he may have wide ranging powers including dissolving the house, calling elections and acting as head of the military. BUT he can only use those powers as the Majority Leader tells him. He might say.

'Mr President, the Congress has passed this bill and I request that you sign it into law'

'Mr President, the Congress believes the members of Orangeland are about to invade. I request that you attack them'.

'Mr President, I think TheOtherGuy would be a wonderful Minister for War. I request that you appoint him.

Through convention (and often constitutionally) the President is obliged to do as he is told by the House Majority Leader.

*The Speaker of the House often has little more power than regular members of the parliament.

Of course this is a gross oversimplifcation - but it should give you a rough idea of how the Westminster System (and its variants) compare with the US Presidental System
posted by TheOtherGuy at 8:13 PM on February 28, 2007 [1 favorite]

A note on this comment: Canada's head of state is not the Queen of England, but the Queen of Canada.

One thing I don't get is how you can have Westminster-style systems with fixed election dates. What would happen if the government fell too early for the next election date, or were scheduled to fall well after the next election date?
posted by oaf at 8:15 PM on February 28, 2007

oaf, the government could still fall, and the next election date would be adjusted based on when it falls. I'm not sure what you mean by "scheduled to fall."
posted by Dasein at 8:33 PM on February 28, 2007

The concentration of power in a Westminster style system can actually be quite a diffuse thing; In the Australian system, for example, which for all intents and purposes is pretty similar to the Canadian system.

Is the Queen the person with the most power? In theory, sure. She "appoints" Governers General, Prime Ministers, can dissolve Parliament, and has veto over laws. In practice, if she tried to excercise any of that power, we'd pretty swiftly decide to become a republic. In practice, the appoints the Governer General the Prime Minister tells her to, the ministers the Prime Minister tells her to.

The Governer General? He's the one who actually signs the laws. But his role is pretty much entirely ceremonial - opening Parliament, cutting ribbons, all that stuff. In Australia, Governers General are usually fairly benign, respected figures - former judges, religious leaders, scientists, sports people, artists - they do what the Prime Minister tells them to, and enjoy the nice accomodation while they do it. When the Governer General has tried to excercise his power, constitutional crisis has resulted.

So, the Prime Minister. He's running Cabinet, picking ministers, telling the Queen and the Governer General what he wants. Fine. But he is subject to overthrow from within his own party - after all, the party picks their leader. He can lose his seat in an election based on what his local constituants think of him. And his government can be the subject of a no-confidance motion. By my understanding, there are many fewer ways to get rid of a bad President, than there is to get rid of a bad Prime Minister.
posted by Jimbob at 8:38 PM on February 28, 2007

I'm not sure what you mean by "scheduled to fall."

I mean, what if the government has only been in power for three years, and the election date is a year later. Does the government have to be dissolved in time for the next date, or can they wait the extra year.
posted by oaf at 8:43 PM on February 28, 2007

oaf; are you talking about the natural cycle of elections, or are you talking about special circumstances, ie. a vote of no confidance?

I don't know about the Canadian system, and I wasn't aware they have fixed election dates.

In Australia, election dates aren't fixed - they can be any time, actually, up until a final date by which the Prime Minister has to dissolve Parliament. He could hold an election six months after the previous one if he really wanted to; to consolidate power, reaffirm a mandate. In practice, the public would get pretty pissed off about this. But there is a time limit by which the election has to be held. Australian federal parliaments sit for three years. That's the cut off date; we have elections about every three years.

I would assume in Canada, if they have fixed election dates, that those dates would reflect the length of time, constitutionally, that governments are allowed to be there. Governments would, I imagine, be "scheduled to fall" at the time of the election. In special circumstances, early dissolution for whatever reason, I would imagine it's easy to hold a poll early. Any Canadians want to elaborate? I'm guessing the "fixed election dates" is a convenience imposed on top of more rigorous constitutional rules.
posted by Jimbob at 8:50 PM on February 28, 2007

a note on TheOtherGuy's comment---Harry Reid is majority leader of the Senate, a body loosely derived from England's House of Lords*. The majority leader of the House of Representatives is Steny Hoyer, D-Maryland.

*-May not seem as much like it these days, but remember---before approx. 1912 (I think), senators were not elected but rather appointed by the governor of the state they would represent.... Also, the Senate's powers I believe were once quite a bit less than they are today---this is reflected, for example, in the fact that certain bills (especially the Budget) have to begin in the House of Representatives.
posted by FlyingMonkey at 8:54 PM on February 28, 2007

this is reflected, for example, in the fact that certain bills (especially the Budget) have to begin in the House of Representatives.

Something common to the Westminster system, as implemented in Australia. "Money Bills" have to originate in the House of Reps as well.
posted by Jimbob at 8:57 PM on February 28, 2007

Many non-Commonwealth/non-English speaking countries have a governance system very similar to the English-speaking system. The seven continental and Scandinavian monarchies certainly do.

Japan and the western European republics are a substantially similar, with most of the variation coming from having more power in the upper house of parliament and more power in the head of state, elected Presidents being deemed a bit more worthy of a say than monarchs (or their stand-ins, as in Canada, Australia and New Zealand).

France is the only western European country which comes remotely close to the U.S and Latin American norm of strong Presidents with a direct popular mandate, but it's still quite watered down: the powers of the French President are distinctly less than those of the U.S. or Brazilian Presidents.
posted by MattD at 8:59 PM on February 28, 2007

It's also very important to note that one distinctive, and attractive, aspect of the U.S. system is that people elect their legislators in their own right and for their own sake and often with respect to local interests and needs. In a parliamentary system, your legislative vote is simply a means to the end of disposing of national electoral power.

An English example: if you don't like Tony Blair you shouldn't vote Labour no matter how much you like the Labourite standing in your constituency, or how good a job he's done in securing public funds for local projects, etc. Skill as a legislator and assiduous constituent service is little valued: everyone's goal is to establish themselves as national politicians and prospective ministers, and those who do it well are actually rewarded by being moved to safe constituencies, hundreds of miles from where they live or where they're from, and where they don't even need to engage in the pretense of local politicking.
posted by MattD at 9:05 PM on February 28, 2007

In Canada, you have to have an election within 5 years of the last one. But that election can be called at any time in those 5 years at the either the discretion of the prime minister or the fall of the party in power. And its already been discussed above that it takes more than losing a vote to make a government fall. They have to lose a vote on something major, usually the budget.

Compared to American elections, Canadians campaign for a much shorter length of time. The campaign has to be a minimum of 36 days and in the past decade that's how long they last. But they've gone as long as 74 days.
posted by thecjm at 9:14 PM on February 28, 2007

An excellent, if technical, book on the implications that the difference between presidential and parliamentary government has for the actual functioning of that government is Do Institutions Matter? by R. Kent Weaver and Bert Rockman.
posted by awesomebrad at 10:22 PM on February 28, 2007

Wow, thanks for all the responses, that really gets me started.
posted by KenFox at 11:16 PM on February 28, 2007

I don't know about the Canadian system, and I wasn't aware they have fixed election dates.

Federally, they don't, but Ontario does.
posted by oaf at 11:22 PM on February 28, 2007

Harry Reid is majority leader of the Senate ... The majority leader of the House of Representatives is Steny Hoyer, D-Maryland.

True, but assuming that the House of Representatives were a parliament, Nancy Pelosi would have been appointed by the Head of State, the otherwise unimportant bureaucrat George W. Bush, to be Prime Minister. She would form a government and appoint cabinet members. Somebody else would have been appointed Speaker, because in a parliament that's a less important position -- similar to the US Senate's President pro tem. Steny Hoyer, on the other hand, as Pelosi's trusted right-hand man, would have been given an important cabinet position, as has Gordon Brown, or appointed Deputy Prime Minister.
posted by dhartung at 11:30 PM on February 28, 2007

Is the Queen the person with the most power? In theory, sure. ... In practice, if she tried to excercise any of that power, we'd pretty swiftly decide to become a republic.

I'm not sure I totally agree with that, Jimbob. It's an argument that gets trotted out here to serve the republican cause - but, from what I understand, the worst outcome the monarch can cause from any direct intervention is the calling of a general election.

In other words the monarch performs the role of the "last honest man", ready to push the reset button if the system locks up.

We had a touch of this in '74 - caused by the Queen's representative, not the Queen herself - and the outcome (another general election) was the right thing to do, even if the behind-the-scenes stuff was pure bastardry.

(Of course, this wouldn't necessarily be a good thing if the monarch was a contrarian raving looney bent on having subject nations be the playthings of their whims. Which is why the option of becoming a republic needs to be kept available.)
posted by Pinback at 11:59 PM on February 28, 2007

Well, Pinback, it can be argued that the the Governor General has the reserve power to withhold assent to Bills that Parliament has passed if he is not satisfied with the Bill presented to him. This is the sort of thing that, if it actually happened, would cause a lot of strife. Of course, the last time the Queen did that was in 1708...
posted by Jimbob at 12:48 AM on March 1, 2007

sien wrote: The major difference between a Parliamentary system and a Presidential system is that control the executive (i.e. the people who run the government) and the legislature (i.e. the people that make the laws) are the same thing in a Parliamentary system whilst in a Presidential System the executive is a separate entity from the Legislature.

Not necessarily. Many Parliamentary systems have two chambers each of which must pass a bill before it becomes law. The government (executive) is generally appointed by the lower house, but if the upper house is controlled by a different party they can hold the government to ransom in various ways.

For example, Australia used to be reasonably well governed, because an independent Senate stopped the government from passing most of the really stupid laws it wanted to. It also made sure that various checks and balances were actually respected. When the Coalition gained control of both houses everything really started to go to shit (and has continued to do so).
posted by A Thousand Baited Hooks at 1:07 AM on March 1, 2007

the last time the Queen did that was in 1708

Send me to pedant's corner:

In 1999, Queen Elizabeth II, acting on the advice of the government, refused to signify her consent to the Military Action Against Iraq (Parliamentary Approval) Bill, which sought to transfer from the monarch to Parliament the power to authorize military strikes against Iraq. Due to the Crown's refusal to consent to the bill's hearing, it was automatically dropped.
posted by dmt at 2:35 AM on March 1, 2007 [1 favorite]

Thanks for the clarification flyingmonkey. I thought Reid was congressman.. non-american here :)
posted by TheOtherGuy at 3:32 AM on March 1, 2007

Expanding on sien's comment, look into the concept of Separation of Powers. This Wikipedia link explains it in the context of the differences between the US and UK, and also mentions France and several "unusual systems not using three branches".
posted by Robert Angelo at 5:29 AM on March 1, 2007

I would focus on the substantive differences, rather than the organizational differences. Not "how are these things structured differently", but "due to the different structures, how do these things WORK differently in practice".

So. In practice. In practice, third parties work. In the U.S., it's only advantageous to have two large parties, because a smaller party cannot elect a President, where increasingly much of the power of government resides. In parliamentary system, and in the U.S. House and Senate, third parties work great - they often end up the swing votes on crucial issues, and thus have power nearly comparable to larger parties. (Imagine if the swing vote in the U.S. Senate right now resided in a contingent of five Green Senators, rather than in Joe Lieberman.)

In practice, the leader of government CANNOT be a dumbass. It's guaranteed that the leader of government is someone who fought his/her way to the leadership of her own party, which cannot be done by a stupid person. They may still have principles repugnant to your own, of course; but they MUST HAVE a minimum amount of diplomacy and intelligence. In the U.S. the only requirements to be President are name recognition and money - there is no built-in filtering process which excludes dumbasses. This filtering principle also excludes famous actors, celebrities, and so on. You cannot simply leap from being a famous actor to running the government (you can still use fame to get into parliament, but then you'd have to claw your way to the top of your party based on IQ and diplomacy).

In practice, the government is much more responsive to the people. Many governments are minority, meaning the ruling party does not have a simple majority of parliament, and thus if the other parties decide to gang up on the rulers, they get thrown out of office. In the U.S., once you're in, you're IN - you've got a four-year lock on power. There's a line in V for Vendetta: "People should not fear their government, their government should fear the people." This is true in parliamentary systems, not true in presidential ones.

And finally, there's one which I'm not sure is a true difference between the systems or an "as-implemented" difference. In the parliamentary systems I'm familiar with, the out-of-power parties have substantial power to interrogate the leader of the government. Every single day (or most days anyway), the leader of government has to take questions from people HOSTILE to his policies, for 45 minutes. This results in the leader THINKING about how defensible those policies are beforehand, because if he's doing something stupid, he's going to be put on the hot seat every single day. I don't think GWB has taken even one question from a person hostile to his policies, in six years. The U.S. equivalent - occasional missives from Congress demanding that the President provide this report or that report on his activities - have generally been ignored, under the doctrine that Congress can't tell the President what to do. It's pretty much impossible for a parliamentary leader to exist in the same "no-bad-news bubble" as a U.S. President can.
posted by jellicle at 6:39 AM on March 1, 2007

That's a bit rah-rah about parliamentary systems.

Parliamentary systems are arguably more responsive, but not because they gnash their teeth about having an election called against their wishes. Minority governments, while they've happened, are quite rare in the UK. The UK government is arguably more responsive because the government has an overwhelming power to make whatever it wants become law. So if you elect a majority who promised something if they get elected, you will get that something very quickly.

If anything, a majority government in a Westminster system should be less concerned about elections. They can put them off marginally longer if they want to, and they can call a new one whenever things seem to be going well politically.

*-May not seem as much like it these days, but remember---before approx. 1912 (I think), senators were not elected but rather appointed by the governor of the state they would represent

Elected by state legislatures. There were very deep corruption problems associated with this, or at least perceptions of them.
posted by ROU_Xenophobe at 6:55 AM on March 1, 2007

If you want to look at the biggest difference between US and parliamentary systems, the answer won't be constitutional or institutional. The answer will probably be the astonishing and penetrating weakness of American political parties.

In most of the world, parties and party leaders control access to their party label. If the leaders of the Social Democrats don't want you to run as a Social Democrat, then you can't, plain and simple. If you vote in right-wing ways, the Social Democrats can kick you out and you can't run as one again. If you insist on voting your way instead of the way the larger party decided, you're out on your ass.

In the US, parties are legally forbidden from controlling their own nominations. Instead, they are required to use primary elections (or occasionally caucuses), and these primaries are open to essentially any citizen who wants to vote in them (though you can't usually vote in more than one party's primary). No matter how right-wing you are, if you win the Democratic primary you are the Democratic candidate. Even if you have pledged to crush the Democrats, see them driven before you, and hear the lamentations of the women, the Democratic party cannot stop you from running as a Democrat. Also, if a no-shit Nazi eugenecist or grand wizard of the Klan happens to win a primary because the locals are fuckheads, the larger party cannot do diddly-squat about it.

This does a lot of things. Mostly, it means that politics in the US is a lot more locally-driven and least-common-denominator driven than it is in parliamentary systems. In most of the rest of the world, an individual politician has to worry about keeping his or her party leaders happy, and party leaders are probably not dipshits (though they might be evil) and are generally concered with bigger-picture national politics. In the US, your career doesn't depend on party leaders, it depends entirely and only upon voters in the local district. Voters who care a lot more about local projects than big-picture national politics, voters who don't think a lot about politics generally, and voters who are a lot more likely to be dipshits.

In general, it also means politics is more base-driven than elite-driven. This is not a good thing, because survey evidence has shown again and again that most Americans either don't understand concepts like free expression or just don't care about them -- it's the relative elites that do. This is part of why we get despicable things like anti-gay ballot measures instead of things like health care.
posted by ROU_Xenophobe at 7:10 AM on March 1, 2007

Whoops, looks like my (albeit drunken) Mackenzie-Papineau joke got modded. Must have been the Family Compacts.
posted by TheWhiteSkull at 9:40 AM on March 1, 2007

Well, in civics class terms, the biggest difference in a parliamentary system is that there are only two branches of government - the executive is either entirely contained within, or all-but-entirely subject to, the legislative branch.

I'm told by People Who Know that the largest practical difference is that the United States and France[*] may be the only two stable presidential systems in the world. Generally they collapse into civil war, dictatorship, or both within a couple of decades.

* And France's constitution only made it through the last presidential election cycle in tact by the skin of its teeth - we'd be on the Sixth Republic by now if the whole country hadn't held its nose and voted for Chirac simply to prevent his last remaining opponent from getting any vote share.
posted by genghis at 10:04 AM on March 1, 2007