Constitution (1789), Article V
United States
- 3 approvals
-
Highest bar 75%
- Referendum: Not required
- House of Representatives Two-thirds of members voting 67%
- Senate Two-thirds of senators voting 67%
- States Three-quarters of the states (38 of 50) ratify 75% By state legislatures or ratifying conventions, as Congress chooses.
A national convention called by two-thirds of state legislatures is an alternative route that has never been used. 27 amendments in over 235 years; the President has no formal role.
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Constitution (1950), Article 368
India
- 4 approvals
-
Highest bar 67%
- Referendum: Not required
- Some parts unamendable
- Lok Sabha Majority of total membership and two-thirds of those present and voting 67%
- Rajya Sabha The same special majority 67%
- State legislatures Half of the states — only for federal provisions 50% Needed for changes to, for example, the election of the President, the Union–state distribution of powers, or Article 368 itself.
- President Must give assent Made compulsory by the 24th Amendment (1971).
Cannot be amended
The 'basic structure' (Kesavananda Bharati, 1973): courts can strike down amendments that destroy it.
Some provisions, such as creating new states, change by ordinary law. India has amended its constitution more than 100 times.
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Constitution (1993), Articles 108 and 134–137
Russia
- 3 approvals
-
Highest bar 75%
- Referendum: On some routes
- Some parts unamendable
- State Duma Two-thirds of all deputies, as for a federal constitutional law 67%
- Federation Council Three-quarters of all members 75%
- Regional legislatures Approved by at least two-thirds of the federal subjects 67% Needed for amendments to Chapters 3–8 (Article 136).
Cannot be amended
Chapters 1, 2 and 9 (the foundations, rights and freedoms, and the amendment rules) cannot be revised by the Federal Assembly: three-fifths of both chambers can only convene a Constitutional Assembly, which may adopt a new constitution or put one to a popular vote (Article 135).
The 2020 amendments, which reset the President's term count, also went to a week-long 'all-Russian vote' that the law did not require. Changes to the list of federal subjects (Article 65) are made by federal constitutional law on admitting a new subject; Russia used it for the annexations of 2014 and 2022, which are not internationally recognised.
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Constitution (1982), Article 64
China
- 2 approvals
-
Highest bar 67%
- Referendum: Not required
- Proposal The NPC Standing Committee, or one-fifth or more of NPC deputies 20%
- National People's Congress At least two-thirds of all deputies 67%
Ordinary laws need a majority of all deputies. The Standing Committee, not a court, interprets the constitution (Article 67). Official English text: en.npc.gov.cn.cdurl.cn/constitution.html.
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No single codified constitution (Constitution Act 1986, Electoral Act 1993, Bill of Rights Act 1990, Treaty of Waitangi)
New Zealand
- 3 approvals
-
Highest bar 75%
- Referendum: On some routes
- Uncodified
- House of Representatives Simple majority for almost everything 50% One chamber, so no second house can delay a change.
- Entrenched provisions 75% of all MPs, or a majority in a referendum 75% Electoral Act 1993 s268: the three-year term, the Representation Commission, electorate boundaries, the voting age and the secret ballot.
- Governor-General Royal assent
The entrenchment in s268 is itself only singly entrenched: the section that protects it could in principle be repealed by a simple majority, but Parliament has always treated it as binding.
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Constitution (1978), Articles 167–168
Spain
- 3 approvals
-
Highest bar 60%
- Referendum: On some routes
- Congress of Deputies Three-fifths of members 60%
- Senate Three-fifths of members 60% If the chambers disagree, a joint committee drafts a text; failing that, an absolute majority of the Senate plus two-thirds of the Congress suffices.
- Voters Referendum if a tenth of either chamber asks within 15 days For a total revision, or changes to the Preliminary Title, fundamental rights (Title I, ch. 2, sec. 1) or the Crown: two-thirds of each chamber, immediate dissolution, ratification by two-thirds of the new Cortes, then a compulsory referendum (art. 168).
No reform may begin in wartime or during a state of alarm, exception or siege (art. 169). The Constitution has been amended in 1992, 2011, 2024 and 2026.
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No single codified constitution
United Kingdom
- 3 approvals
-
Highest bar 50%
- Referendum: Not required
- Uncodified
- House of Commons Simple majority 50%
- House of Lords Simple majority — or the Commons overrides it after about a year 50% Under the Parliament Acts 1911 and 1949.
- Monarch Royal Assent (by convention, never refused since 1708)
Parliamentary sovereignty means 'constitutional' statutes such as the Human Rights Act or devolution Acts change like any other law. Referendums (1975, 2011, 2014, 2016) have been held by political choice, not legal requirement.
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Basic Law (1949), Article 79
Germany
- 2 approvals
-
Highest bar 67%
- Referendum: Not required
- Some parts unamendable
- Bundestag Two-thirds of all members 67%
- Bundesrat Two-thirds of its votes 67%
Cannot be amended
The 'eternity clause' (Art. 79(3)): federalism, human dignity (Art. 1) and the democratic, social, federal state (Art. 20).
The text must be changed explicitly; the Basic Law has been amended dozens of times.
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Constitution (1958), Article 89
France
- 3 approvals
-
Highest bar 60%
- Referendum: On some routes
- Some parts unamendable
- National Assembly Adopts the text 50%
- Senate Adopts the identical text 50%
- Voters or Congress A referendum — or, for government bills, three-fifths of votes cast in both houses sitting together as Congress 60%
Cannot be amended
The republican form of government.
Almost every revision since 1958 has used the Congress route.
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Constitution (1988), Article 60
Brazil
- 2 approvals
-
Highest bar 60%
- Referendum: Not required
- Some parts unamendable
- Chamber of Deputies Three-fifths of members, in two rounds 60%
- Federal Senate Three-fifths of members, in two rounds 60%
Cannot be amended
'Stone clauses': the federal form, direct secret universal periodic voting, separation of powers, and individual rights.
No presidential veto applies. Brazil's constitution is long and detailed and is amended often.
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Constitution (1947), Article 96
Japan
- 4 approvals
-
Highest bar 67%
- Referendum: Always
- House of Representatives Two-thirds of all members 67%
- House of Councillors Two-thirds of all members 67%
- Voters Majority in a national referendum 50%
- Emperor Promulgates in the name of the people
Never amended since it took effect in 1947.
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Constitution (1948), Articles 138–139
Italy
- 3 approvals
-
Highest bar 50%
- Referendum: On some routes
- Some parts unamendable
- Chamber of Deputies and Senate, first reading Simple majority in each chamber 50%
- Both chambers again, at least three months later Absolute majority of members in each chamber 50% With two-thirds in both chambers at the second vote, the law is promulgated directly.
- Voters Referendum if a fifth of either chamber, 500,000 electors or five regional councils ask within three months No turnout quorum: the amendment stands if more valid votes say yes. Voters rejected reforms in 2006, 2016 and March 2026, and approved them in 2001 and 2020.
Cannot be amended
The republican form of government (art. 139)
Under the same procedure Parliament also passes other constitutional laws, such as the special statutes of five regions. The 2020 reform cut Parliament from 945 to 600 elected members.
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Constitution (1996), Section 74
South Africa
- 2 approvals
-
Highest bar 67%
- Referendum: Not required
- National Assembly Two-thirds of members (75% for the founding values in Section 1) 67%
- National Council of Provinces Six of nine provinces — for the Bill of Rights, Section 1, or provincial matters 67%
Ordinary amendments that don't touch provinces need only the National Assembly.
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Constitution (1901), Section 128
Australia
- 2 approvals
-
Highest bar 50%
- Referendum: Always
- Parliament Absolute majority of both houses (or one house twice) 50%
- Voters National majority and a majority in at least four of six states 50% The 'double majority'.
Only 8 of 45 proposals have passed; the most recent, the 2023 Voice referendum, failed.
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Constitution Act 1982, Part V
Canada
- 2 approvals
-
Highest bar 70%
- Referendum: Not required
- House of Commons & Senate Resolutions of both (the Senate can only delay for 180 days) 50%
- Provinces Seven of ten provinces with at least 50% of the population 70% The '7/50' general formula. Some matters, such as the monarchy, need all ten.
Canada's constitution is partly written (the 1867 and 1982 Acts) and partly convention. The 1992 Charlottetown Accord was put to a consultative referendum and rejected.
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Constitution (1917), Article 135
Mexico
- 2 approvals
-
Highest bar 67%
- Referendum: Not required
- Congress of the Union Two-thirds of members present in each chamber 67%
- State legislatures A majority of the 32 local legislatures (including Mexico City) 50%
Mexico's constitution has been amended hundreds of times.
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Constitution (1945), Article 37
Indonesia
- 3 approvals
-
Highest bar 67%
- Referendum: Not required
- Some parts unamendable
- People's Consultative Assembly (MPR) Proposal by at least one-third of members
- MPR At least two-thirds of members attend 67%
- MPR Fifty per cent plus one of all members approve 50%
Cannot be amended
The form of the unitary state.
Amended four times between 1999 and 2002 during the transition to democracy.
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Basic Laws (no single written constitution)
Israel
- 2 approvals
-
Highest bar 50%
- Referendum: Not required
- Uncodified
- Knesset Three readings; a simple majority of those voting, unless the Basic Law entrenches a clause 50% Entrenched clauses need a special majority at every reading (Basic Law: The Knesset s.46): 61 of 120 to change s.4, the electoral system; 80 to extend the Knesset's term (s.9A) or to change ss.44–45.
- President Signs the law; no veto
The Knesset, elected as a constituent assembly in 1949, never adopted a constitution; the 1950 Harari Decision chose to write it chapter by chapter as Basic Laws. The Supreme Court has treated them as having constitutional status since 1995 (Bank Mizrahi), and in January 2024 struck down a 2023 amendment to Basic Law: The Judiciary.
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