The legal framework was marked by changes made by the CEC to the Regulation on the status of observers and the accreditation procedure. The new requirements imposed on observers, such as the demonstration of technical, financial capabilities and experience in the field, are not clearly defined and may generate arbitrary interpretations. Also, the expansion of the grounds for withdrawing accreditation by vague terms such as “hampering” and “jeopardizing” of the voting process raises risks of disproportionate penalties. Promo-LEX and the Ministry of Justice came up with several recommendations, but they have been largely ignored.

Other amendments to the regulatory framework refer to the mobile ballot box and voters lists, argued by the need to increase the fairness of the electoral process, transparency and efficiency, including through digitization. However, these amendments were adopted too close to voting day, contrary to the principle of stability of electoral legislation.

CEC activity. During the electoral period, the CEC functioned, in general, transparently, having organized 21 meetings and adopted over 200 decisions. We shall point out that, during this period, some members of the institution faced pressures that are at the limit of intimidation, which can affect the CEC’s independence.

The number of accredited observers has increased significantly, with 65% representing Promo-LEX. Regrettably, during this period there were some cases of obstruction of the observers’ activity. A serious incident took place on 24 August, when a Promo-LEX observer was insulted and verbally assaulted by politician Alexei Lungu. In two other cases, PSA and CEC delayed or conditioned access to electoral information, thus reducing the transparency of the electoral process.

Establishment of polling stations. The district electoral councils constituted 1,961 polling stations on the territory of Moldova, without those dedicated for voting abroad (301) and for the left bank of the Dniester (12). Compared to the 2024 presidential election, the number of polling stations has increased slightly.

Promo-LEX found that about 91% of the polling stations operate in public buildings, most being open in community centers and schools, implying the responsibility of the authorities to ensure appropriate conditions. In particular, the Promo-LEX OM points out that they must be accessible for people with disabilities.

Organization of polling stations abroad. For the parliamentary elections, the CEC approved 301 stations abroad (about 70 more than in 2024), including four for postal voting, based mainly on 2024 data, without clarifying the weight of the criteria used to determine the number of stations. Promo-LEX supports efforts to make voting abroad accessible; at the same time, the legislation provides for other mechanisms to make voting abroad accessible, such as two-day voting, but also postal voting that could be extended globally. For this election, the accessibility of postal voting increased, being expanded from 6 to 10 countries, within 4 polling stations.

Organization of polling stations for the left bank of the Dniester. The organization of polling stations for voters from the left bank of the Dniester should be treated in a broader context of the need for democratization and reintegration of the uncontrolled region. The current geopolitical environment must be used by the constitutional authorities to make the so-called Tiraspol authorities accept some demands, which in the future would ensure conditions for democratization of the Transnistrian region.

For voters residing on the left bank of the Dniester, polling stations were reduced from 30 to 12, which, according to the Promo-LEX OM, might reduce electoral participation. Promo-LEX estimates that 28 stations would ensure a balance between safety and democratic access.

Nomination and registration of electoral competitors. Between 20 June and 19 August, the CEC registered for the elections the lists of candidates from 4 electoral blocs (Patriotic EB, Alternative EB, Together EB, BUN EB), 13 political parties (PAS, PPDA, CUB, ALDE, PPNM, PSDE, MRM, LOC, AUR, PAM, PL, UCSM, PN) and 4 independent candidates (Andrei Năstase, Olesea Stamate, Victoria Sanduța, Tatiana Crețu). Some applications from parties and potential independent candidates were rejected on the basis of legal non-compliance.

Performance of potential electoral competitors. Although the official electoral campaign starts on 29 August, promotion activities of electoral nature started much earlier. During the monitored period alone, Promo-LEX observers reported at least 2,339 promotional activities, mostly in the form of distribution of information materials, dissemination of street advertising and meetings with voters. Most were organized by the Patriotic EB and PAS. The situation described suggests that the actual expenses for electoral promotion will significantly exceed the amounts to be declared by the electoral competitors in the next 30 days of the campaign.

The Promo-LEX OM also highlighted in the report at least 40 cases of misuse of administrative resources, most of them by PAS (30), involving public employees during working hours and local authorities involved in electoral activities. PAS candidates who are currently ministers promoted the party through official trips to the territory, affecting the fairness of the electoral process and the separation between party and state.

Also, there were reported cases of potential corruption of voters (in two cases by PPDA and in one case each by the Patriotic EB, Victory PB and PSDE) and of the involvement of “third parties” in campaigns to promote or denigrate political subjects, which had an electoral nature, without clear regulations on expenses.

Financing of the elections and the electoral campaign. For the parliamentary elections of 28 September, only 3 of the 21 competitors formed initiative groups, and only Andrei Năstase appointed a treasurer. All competitors complied with reporting requirements. In the case of Andrei Năstase, he exceeded the legal ceiling and was obliged to transfer MDL 115,577 to the state budget, a large part of which had been intended for the voluntary activity of the members of the initiative group.

Hate speech and incitement to discrimination. Between 21 July and 19 August, 233 cases of hate speech were documented, 162 in electoral context, targeting politicians, women and LGBT people, based on political, professional or sexual orientation criteria, a phenomenon more serious than in 2021.

The speeches were propagated by Igor Dodon, Victoria Furtună and Vasile Costiuc, including incitement to violence, discrimination and direct threats.