The paper explores the potential for using capacitively-coupled electrodes in electrical resistance tomography. Such electrodes are less vulnerable to corrosion and electrochemical effects that plague conventional electrical resistance tomographs utilising electrodes that are in intimate contact with the material. A model is proposed that takes account of the complex impedance of the insulating layer. The performance of the resulting passive network of components has been simulated up to 1 MHz excitation frequency. 2D finite element modelling has been used to explore the measurements that might be expected from electrodes distributed around the boundary of a vessel. Except for the adjacent measurements the modelled impedances are within 1% of those for conventional electrodes.