Political context. The regional elections of 15 November 2026 are taking place against the background
of an institutional crisis in ATU Gagauzia and complex relations between the authorities of the autonomy
and the central authorities. The conviction of Evghenia Guțul and the finding that the office of Governor
(Bashkan) was vacant, together with the repeated postponement of elections to the People’s Assembly,
whose mandate expired in November 2025, have deepened the difficulties in the functioning of the
regional institutions. Public perception reflects these difficulties: 39.2% of respondents to the PromoLEX survey of March 2026 consider the current People’s Assembly legitimate, while 38.9% consider it
illegitimate.

Electoral competition retains the features of a system in which candidates registered as independents
play an important role in shaping political power, favoured by local name recognition and by the nature
of single-member constituencies. In these circumstances, informal political ties between candidates
declared independent and certain political formations, including those associated with Ilan Șor, pose a
risk, to address which the legislator introduced the notion of a “camouflaged independent candidate”,
applied for the first time in these elections. At the same time, the experience of previous elections,
including the 2023 election of the Governor (Bashkan), points to risks associated with illegal financing
and voter bribery.

The regional context is also shaped by differences in geopolitical orientation compared to the rest of the
country, by the presence of Russian Federation influence in the media and political space, and by the
predominant consumption of political information through social networks, with TikTok being the main
source of information (61.4%). In these circumstances, monitoring of electoral financing, of possible
forms of voter bribery and of the information environment remains essential for assessing the integrity
of the electoral process.

Legal framework. The organisation of the regional elections of 15 November 2026 was marked by
institutional deadlocks, disputes over the competences of the authorities of Gagauzia, and amendments
to the regulatory framework shortly before the start of the electoral period. The elections to the People’s
Assembly were set after two previous failed attempts, about one year after the expiry of the members’
mandate. In the case of the election of the Governor (Bashkan), setting the date fell to the Central
Electoral Commission after the People’s Assembly failed to adopt a decision within the deadline.

The Constitutional Court Judgment of 9 July 2026 and the amendments introduced by Law No. 192/2026
reshaped the legal framework of the regional elections, consolidating their integration into the national
electoral system and delimiting the competences of the authorities involved. Although the principle of
stability of electoral legislation does not prevent the enforcement of constitutional court judgments, Law
No. 192/2026, which entered into force 81 days before the elections, was not limited to the interventions
needed to enforce the judgment, but also included amendments on the financing of electoral campaigns,
independent candidates, voting with a digital identity document and media coverage of the elections. The
harmonisation of the legislation on the special status of Gagauzia with the Electoral Code needs to
continue, in particular as regards Art. 8 and Art. 12 of Law No. 344/1994, in order to clarify the
competences and deadlines applicable to the authorities involved and to ensure a coherent and
predictable legal framework, compatible with international electoral standards.

Electoral bodies. The regional elections of 15 November 2026 are the first elections to the People’s
Assembly and for the office of Governor (Bashkan) organised within the unified national system of
electoral bodies. Following the legislative amendments adopted in August 2026, the Central Electoral
Commission (CEC) took over the role of assisting and supervising the electoral process, while the Central
Electoral Council of Gagauzia (CECG) is responsible for the direct administration of the elections. During
the reporting period, the CEC adopted 19 decisions for the elections to the People’s Assembly and 21 for
the election of the Governor, within the deadlines set by the calendar programmes.

The CECG was established with 15 members by applying the adjusted mechanism for forming electoral
bodies at national level, which allowed all parliamentary parties to appoint members. During the
monitored period, it acted in line with its legal competences, adopted 43 decisions on the organisation of
the elections, the registration of electoral competitors, the establishment of lower-level electoral bodies
and other aspects of the electoral process, and accredited 56 Promo-LEX observers. The three first-level
district electoral councils were established within the legal deadlines. Gender representation within them is unbalanced, with men accounting for only about 17% of all members. Monitoring also revealed
shortcomings in the accessibility of their premises. Moreover, data on the certification of electoral
officials are not publicly available disaggregated by administrative-territorial unit, which prevents
observers from assessing the number of certified persons in ATUG.

The use of the State Register of Voters (SRV) to generate voter lists is a major change compared to
previous regional elections, when the lists were drawn up by local authorities and the number of voters
included in them fell from 113,940 in 2021 to 92,563 in 2023. According to the SRV, 129,613 voters are
registered in ATU Gagauzia, unevenly distributed across the 35 single-member constituencies (from 402
in SMC 23 Carbalia to 6,847 in SMC 12 Baurci), which undermines the principle of equal voting power.
Nomination and registration of competitors. According to CEC decisions, only 38 of the 66 registered
political parties were entitled to take part in the regional elections of 15 November 2026. In the elections
of members of the PAG, a total of 138 candidates were nominated and 135 registered for the 35
constituencies established. Of these, 92 are independent candidates and 43 are candidates of political
parties (PSRM – 23; PPG – 9; PPAM – 7; PPȚ – 2; MAN – 2). Of all registered candidates, 23 are women
(17%) and 112 are men (83%). The electoral bodies adopted 3 decisions refusing the registration of
candidates, two of them on the grounds of the applicants’ party membership.

The largest number of candidates registered in SMC 26 Chirsova – 7, SMC 2 Comrat – 7 and SMC 30
Copceac – 6. At the other end, only one candidate was registered in constituency No. 33 Chioselia Rusă,
and two candidates each in SMC No. 10 Vulcănești, 13 Beșalma, 17 Cioc-Maidan and 19 Joltai. Compared
to the 2021 PAG elections, we find that about 10% more candidates registered in 2026, with an increasing
presence of parties in the regional elections.

For the election of the Governor of Gagauzia of 15 November 2026, eight candidates were nominated and
registered, three of them by political parties (PSRM, PPG, NOI) and five self-nominated. The initiative
groups collected the required signatures within 5–7 days, with validation rates ranging between 76.8%
and 94.6%.

Electoral complaints. During the monitored period, at least four petitions and complaints were
identified concerning electoral campaigning, the use of administrative resources, eligibility conditions
and the registration of candidates. They were resolved by rejection, by a finding of inadmissibility or by
examination as petitions, without confirmation of the alleged violations.

Upholding the refusal to register an independent candidate who had submitted a request to leave the
party before the 70-day deadline, but was still recorded by the PSA as a member of the party’s central
governing body, requires an assessment of the proportionality of the restriction on the right to be elected.
Moreover, petitions, complaints and the acts resolving them are not published fully and systematically,
which makes it difficult to follow electoral practice.

Potential electoral competitors. The period preceding the electoral campaign was marked by at least
293 activities with electoral character (260 in the context of the elections to the People’s Assembly and
33 in the context of the election of the Governor (Bashkan)), consisting mainly of signature collection and
online promotion. At the same time, the announcement of the intention to run and the individual promotion of certain potential candidates before the legal nomination deadline, including in the case of
a candidate for Governor who announced his candidacy almost a month before the vacancy of the office
was established, affect the principle of equal opportunities and facilitate the circumvention of the
provisions on the financing of electoral campaigns.

Fourteen cases that could potentially qualify as use of administrative resources were also documented,
including the redistribution across electoral constituencies of MDL 1.53 million from the reserve fund of
the People’s Assembly after the start of the electoral period, the involvement of some mayors who are
candidates in electoral activities during working hours, and claiming credit for public investments. At the
same time, the activity of certain third parties, including pages administered from abroad, through
sponsored advertisements, as well as coordinated inauthentic behaviour amplifying narratives that
discredit the electoral process and the institutions involved, point to the vulnerability of the regional
information space in the context of these elections.

Observation of the financing of electoral activities. The financing of the regional elections of 15
November 2026 takes place under a legal framework amended shortly before the start of the electoral period, including through the introduction of a financial reporting obligation for the pre-electoral period,
a recommendation previously made by Promo-LEX Association. The CEC budget for organising the
elections amounts to MDL 13,608,490, and the ceiling on financial means that may be transferred to the
“Electoral Fund” account for the election of the Governor is MDL 3,122,416.28.

Financial reporting by electoral competitors was marked by uneven application of the information
obligations. None of the five initiative groups for the office of Governor opened a bank account, only 14
of the 92 independent candidates for Member of the PAG opened an “Electoral Fund” account, and some
candidates, as well as one of the electoral councils, were unaware of the reporting obligations. By 13
October 2026, no electoral competitor had declared any expenditure, while the expenditures estimated
by Promo-LEX EOM amounted to at least MDL 52,978, including MDL 18,282 for the promotion of a
candidate for Governor before nomination. The discrepancy between the declarations of not opening
accounts and the activities observed, estimated at over MDL 6,000 each in the case of two initiative
groups, requires verification by the electoral bodies.

To the Parliament of the Republic of Moldova

1. Bringing Art. 12 para. (3) letter d) of Law No. 344/1994 into line with the Electoral Code by clarifying
   the scope of the competences of the People’s Assembly in relation to the powers of the electoral
   authorities regarding the organisation and conduct of regional elections.
2. Amending Art. 16 para. (3) of the Electoral Code to include an obligation for candidates to suspend
   their activity during the signature collection period.
3. Supplementing the legal framework applicable to the election of the Governor of Gagauzia by
   expressly establishing the moment when the vacancy of the office occurs, clarifying the relationship
   between the termination of the mandate by operation of law and the formal act by which the People’s
   Assembly establishes the vacancy, and establishing a deadline for adopting this act and a subsidiary
   mechanism applicable in the event of inaction by the competent authority.
4. Supplementing the legal framework on the accreditation of national observers for regional elections
   by granting the Central Electoral Commission the competence to accredit national observers for
   these elections, in order to ensure a clear and coherent mechanism applicable throughout the
   electoral period.
5. Simplifying the mechanism for acquiring and terminating membership of a political party, so as to
   guarantee the right to run where the intention to leave the political party was expressed outside the
   70-day period before election day provided for by the Electoral Code.
6. Harmonising the rules and conditions for registering candidates for Member of the PAG in Law
   344/1994 and in the Electoral Code as regards the candidate’s domicile/residence, and clarifying
   situations involving simultaneous domicile and residence in different constituencies.
7. Revising the regulatory framework on independent candidacy, so that delays in updating party
   records or in the registration of changes by the PSA do not constitute an absolute obstacle to
   exercising the right to be elected, where the person shows that, before the legal deadline, he or she
   took all the steps necessary to dissociate from the party and its governing bodies.
   To the Central Electoral Commission and lower-level electoral bodies:
8. Expressly including the date of issue of the signature lists in decisions on applications for the
   registration of independent candidates.
9. Monitoring both the online and offline space in order to identify third parties, coordinated
   inauthentic behaviour and their impact on the electoral process.
10. Ensuring the publication, on the webpage of the regional electoral bodies, in a publicly accessible
    section, of petitions and complaints, the acts resolving them and the correspondence related to their
    examination.
11. Verifying, together with the CECG and the first-level DECs, the correlation between the declarations
    of not opening the “Electoral Fund”/“For the Initiative Group” account and the campaign activities
    observed, and publishing the reports in a timely manner.
12. Proactively informing electoral competitors, including independent candidates, of their financial
    reporting obligations and continuing the field training, with a focus on notification and reporting
    obligations.
13. We recommend that the CEC, in cooperation with the CICDE, continue to monitor the availability and
    recruitment capacity of the electoral officials needed to establish and operate the precinct electoral
    bureaus in ATU Gagauzia and, where appropriate, identify measures to ensure the human resources
    needed for the conduct of the electoral process.

To the Parliament of the Republic of Moldova

1. Bringing Art. 12 para. (3) letter d) of Law No. 344/1994 into line with the Electoral Code by clarifying
   the scope of the competences of the People’s Assembly in relation to the powers of the electoral
   authorities regarding the organisation and conduct of regional elections.
2. Amending Art. 16 para. (3) of the Electoral Code to include an obligation for candidates to suspend
   their activity during the signature collection period.
3. Supplementing the legal framework applicable to the election of the Governor of Gagauzia by
   expressly establishing the moment when the vacancy of the office occurs, clarifying the relationship
   between the termination of the mandate by operation of law and the formal act by which the People’s
   Assembly establishes the vacancy, and establishing a deadline for adopting this act and a subsidiary
   mechanism applicable in the event of inaction by the competent authority.
4. Supplementing the legal framework on the accreditation of national observers for regional elections
   by granting the Central Electoral Commission the competence to accredit national observers for
   these elections, in order to ensure a clear and coherent mechanism applicable throughout the
   electoral period.
5. Simplifying the mechanism for acquiring and terminating membership of a political party, so as to
   guarantee the right to run where the intention to leave the political party was expressed outside the
   70-day period before election day provided for by the Electoral Code.
6. Harmonising the rules and conditions for registering candidates for Member of the PAG in Law
   344/1994 and in the Electoral Code as regards the candidate’s domicile/residence, and clarifying
   situations involving simultaneous domicile and residence in different constituencies.
7. Revising the regulatory framework on independent candidacy, so that delays in updating party
   records or in the registration of changes by the PSA do not constitute an absolute obstacle to
   exercising the right to be elected, where the person shows that, before the legal d

To the Parliament of the Republic of Moldova

1. Bringing Art. 12 para. (3) letter d) of Law No. 344/1994 into line with the Electoral Code by clarifying
the scope of the competences of the People’s Assembly in relation to the powers of the electoral
authorities regarding the organisation and conduct of regional elections.

2. Amending Art. 16 para. (3) of the Electoral Code to include an obligation for candidates to suspend
their activity during the signature collection period.

3. Supplementing the legal framework applicable to the election of the Governor of Gagauzia by
expressly establishing the moment when the vacancy of the office occurs, clarifying the relationship
between the termination of the mandate by operation of law and the formal act by which the People’s
Assembly establishes the vacancy, and establishing a deadline for adopting this act and a subsidiary
mechanism applicable in the event of inaction by the competent authority.

4. Supplementing the legal framework on the accreditation of national observers for regional elections
by granting the Central Electoral Commission the competence to accredit national observers for
these elections, in order to ensure a clear and coherent mechanism applicable throughout the
electoral period.

5. Simplifying the mechanism for acquiring and terminating membership of a political party, so as to
guarantee the right to run where the intention to leave the political party was expressed outside the
70-day period before election day provided for by the Electoral Code.

6. Harmonising the rules and conditions for registering candidates for Member of the PAG in Law
344/1994 and in the Electoral Code as regards the candidate’s domicile/residence, and clarifying
situations involving simultaneous domicile and residence in different constituencies.

7. Revising the regulatory framework on independent candidacy, so that delays in updating party
records or in the registration of changes by the PSA do not constitute an absolute obstacle to
exercising the right to be elected, where the person shows that, before the legal deadline, he or she
took all the steps necessary to dissociate from the party and its governing bodies.

To the Central Electoral Commission and lower-level electoral bodies:

8. Expressly including the date of issue of the signature lists in decisions on applications for the
registration of independent candidates.

9. Monitoring both the online and offline space in order to identify third parties, coordinated
inauthentic behaviour and their impact on the electoral process.

10. Ensuring the publication, on the webpage of the regional electoral bodies, in a publicly accessible
section, of petitions and complaints, the acts resolving them and the correspondence related to their
examination.

11. Verifying, together with the CECG and the first-level DECs, the correlation between the declarations
of not opening the “Electoral Fund”/“For the Initiative Group” account and the campaign activities
observed, and publishing the reports in a timely manner.

12. Proactively informing electoral competitors, including independent candidates, of their financial
reporting obligations and continuing the field training, with a focus on notification and reporting
obligations.

13. We recommend that the CEC, in cooperation with the CICDE, continue to monitor the availability and
recruitment capacity of the electoral officials needed to establish and operate the precinct electoral
bureaus in ATU Gagauzia and, where appropriate, identify measures to ensure the human resources
needed for the conduct of the electoral process.

To local public authorities:

14. Making public buildings that house electoral bodies accessible.

To political parties

15. We recommend that political parties strengthen their presence and activity in ATU Gagauzia,
including by developing territorial structures and engaging consistently in the public and electoral
life of the region, in order to ensure the conditions necessary for effective participation in the
elections to the People’s Assembly under the proportional system, scheduled for 2030.