In the contemporary world the upper house of a bicameral national legislature (i.e., a legislature with two houses) is often called a senate. Among the countries where this is so are: Argentina (Senado), Austria (Senat) Belgium, Brazil, Canada, Colombia, France (Sénat), Ireland (Seanad), Italy (Senato), Poland, Portugal, Spain, and the United States. Those who sit in a senate are usually called senators.
Although every national senate has its distinctive features, there are certain general characteristics shared by most, though not all, senates.
- Senates tend to be relatively small bodies, always much smaller than the corresponding lower house: e.g., in the United States (Senate 100 members; House of Representatives 435); in Ireland (Seanad Έireann 60; Dáil Έireann between 153 and 160 (depending on variation in the size of the population)); in Italy (Senato della Repubblica 320; Camera dei Deputati 630); in France (Sénat 348; Assemblée Nationale 577); in Australia (Senate 76; House of Representatives 150); in Canada (Senate 105; House of Commons 338); and in Argentina (Senado 72, Cámara de Diputados 257).
- There is considerable variation between countries in the methods by which senators are appointed. In the United States, since 1913, senators have been elected directly by the citizens of the states they represent. Similarly, appointment is by direct election in Australia and Argentina, and also in Italy - though in the last case with the qualification that a small number of senators (at present 5) are members ex officio (former Presidents of the Republic) or are appointed by the President of the Republic ‘for outstanding merit in social, scientific, artistic, or literary fields’. In contrast the French Sénat is elected by elected officials (such as regional councillors, mayors, members of the Assemblée Nationale, etc.); members of the Irish Seanad are appointed by various methods (11 nominated by the Prime Minister 6 elected by graduates of Irish Universities, and the remainder (43) chosen from various panels of candidates representative of different aspects of national life (e.g., agriculture, industry, the arts); and Canadian senators are appointed by the Governor-General on the recommendation of the Prime Minister.
- The age at which citizens become eligible for appointment to the Senate is typically higher than the age at which they become eligible for election to the lower house: e.g., in the United States and Argentina the lower age-limit for the Senate is 30, and in Italy it is 40, whereas in all these countries the age limit for election to the lower house is 25.
- Senators are elected for longer terms of service than are members of the lower house. In the United States, Australia, and Argentina, for example, senators serve 6 year terms, whereas members of the corresponding lower house are elected for 2, 3, and 4 year terms respectively. In France members of the Sénat serve 9 year terms, members of the Assemblée Nationale, 5 year terms, while in Canada senators are appointed for life, though subject to compulsory retirement when they reach 75.
- Senates often have legislative parity with the corresponding lower house: i.e., bills may be introduced in either house but cannot become law without the consent of both houses. This is the case in the United States (with the exception of revenue-raising bills, which must originate in the House of Representatives), in Argentina, and in Italy (where the referendum in December 2016 on a proposal to reduce the powers of the Senate was decisively defeated). Formally the French Sénat and Assemblée Nationale have equal legislative powers, though the convention is that where there is protracted disagreement between the two bodies – a rare occurrence – the Assemblée Nationale will prevail. In Ireland, however, the Seanad is much weaker than the Dáil: it can only delay bills with which it disagrees.
Regional and metropolitan senates
In the United States all the individual states (except Nebraska) have a senate as the upper house of the state legislature, while in Germany the city council of many of the major cities (such as Berlin and Hamburg) is known as a senate (Senat). Also in Germany, the judges in the higher courts are referred to collectively as the Senat, though individual judges are not called senators.
In the United Kingdom the term Senate is rarely used in a political context: the upper house of the United Kingdom Parliament is the House of Lords, and the devolved legislatures of Scotland, Wales, and Northern Ireland (the Scottish Parliament, the National Assembly for Wales, and the Northern Ireland Assembly) are all unicameral. However, the building which houses the debating chamber of the National Assembly for Wales is known as The Senate (Senedd), and between 1921 and 1972, when the devolved legislature of Northern Ireland was bicameral, the upper house of the Parliament in Belfast was known as the Senate. In Scotland, the Court of Session and the High Court of Justiciary, where the most important judges sit, are known collectively as the College of Justice, and the members of the group are Senators of the College of Justice.
In the United Kingdom the word Senate is most frequently encountered, especially by students, as the name of the supreme academic body in a university. An (academic) senate, composed of professors, heads of departments, other senior members of the academic staff, and (nowadays) a number of student representatives, has responsibility for, e.g., approving degree programmes, issuing degrees, and confirming the appointment and promotion of academic staff.