Tamara Sartania is an independent international consultant, specializing in democratic elections, civil society development, parliamentary and political party strengthening, and women’s political participation. Her work assignments included working as an Election Adviser for OSCE’s Office for Democratic Institutions and Human Rights (ODIHR), where her portfolio included coordinating needs assessment missions and ODIHR’s electoral activities in nine OSCE participating states. In addition, she served as a core team member for several ODIHR election observation missions. As a Deputy Chief of Party for the National Democratic Institute (NDI) Georgia office, Tamara supervised initiatives to support political pluralism in Georgia through capacity building on national and regional levels. She has also worked as a thematic analyst for NDI’s election observation missions to Ethiopia, Ukraine, and Lebanon. Tamara holds a Master of Arts Degree in Law and Diplomacy from The Fletcher School, Tufts University, and a Postgraduate Certificate in Strategic Communications (with Distinction) from King’s College London.

Legal framework. On 25 September, the Central Court of Appeal ordered the restriction of the activity of the PRIM party at the request of the Ministry of Justice. This decision came after the CEC raised suspicions about the party’s illegal financing. Limiting PRIM’s activity has direct consequences for the Patriotic EB, of which it is a part, including the risk of violating the gender quota rule of the Electoral Code if the list of candidates were changed. Since the legislation allows adjustments to the lists only at least 10 days before the elections, the bloc no longer has the legal possibility to correct any defects.

The Promo-LEX OM points out that the unlawful actions of a constituent party should not automatically lead to the cancellation of registration of the entire electoral bloc and recommends applying equal treatment, similar to the one the CEC applied to PPDA. Then, the CEC excluded some persons from the party and obliged the electoral competitor to repair, within 24 hours, the non-conformities related to the mandatory criteria of meeting the gender quota, reserving the right to cancel its registration otherwise. At the same time, Promo-LEX recommends that the future Parliament amend the legislation so that the lists of candidates can be adjusted even closer to the voting day, in justified situations.

Performance of electoral competitors. The electoral campaign for the 2025 parliamentary elections was more intense than the ones for previous elections, being marked by tensions related to Moldova’s status as an EU candidate country and the involvement of the Russian Federation in the electoral process. Electoral competitors carried out 1,984 campaign activities, 50% more than at the beginning of the campaign, mainly distributing informative materials (68%) and meeting with voters (22%). The most active actors were PAS and the Patriotic EB, each with about 26% of the monitored events.

Regarding electoral advertising, Promo-LEX documented 1,754 cases, the most common being the use of visibility materials (vests, hats, bags) and street advertising. Most of such publicity came from PAS, the Patriotic EB, and PN. At the same time, 37 cases of advertising placed in prohibited places were registered, especially on fences and buildings, most of them by PAS and PN. Faults such as the lack of printing data and the use of campaign materials from previous elections were also reported.

Use of administrative resources. Promo-LEX found at least 84 cases of misuse of administrative resources (in 66 cases by PAS, in 8 cases by the Patriotic EB, in 5 cases by the Alternative EB, in 3 cases by CUB, in 1 case each by LOC and PNM). They include taking credit for projects financed with public money, the use of state institutions’ premises for electoral activities, the involvement of mayors and civil servants in the campaign during working hours, as well as the organization of electoral meetings with public sector employees.

The involvement of religious faiths in the electoral campaign was documented in at least six cases, although the law expressly prohibits electoral activism and the use of religious symbols for electoral purposes. Examples include the distribution of messages on Telegram channels calling to vote based on faith, the participation of some candidates in religious services, or the use of images of places of worship in campaign materials. Although the Metropolis of Moldova officially disavowed such practices, journalistic investigations have shown that at the local level the clerics are involved in electoral activities.

During the monitored period, at least three cases of intimidation and provocation with the potential to affect the electoral process were identified. They include the attempt of the authorities of Ceadir Lunga to dismantle a display board critical of the Russian Federation, an incident in Edinet involving a PAS candidate, and the distribution on social networks of messages regarding alleged payments for the vote.

Another phenomenon we found is the involvement of third parties in promoting narratives with an electoral impact. During the monitored period, at least 15 entities carried out such activities, including networks coordinated from the Russian Federation, NGOs, social media pages, and religious channels. They disseminated sponsored or free content, often with a pro-Russian or anti-EU tint, but also messages of support for European integration.

Promo-LEX also observed coordinated inauthentic behaviour on social networks, consisting in the creation of fake accounts, clone websites that artificially amplified narratives meant to compromise the electoral process. Examples are campaigns on TikTok with AI-generated videos, pages that distributed fake messages about polling stations or falsified ballot papers.

Financing of the electoral campaign. Between 8 and 21 September 2025, the declared income totalled about MDL 23.8 million, coming mainly from donations of individuals (67%), legal entities (16%), and material donations (10%). The most income was declared by PAS, Patriotic EB, PN, and Alternative EB, which together accounted for 80% of the total. Material donations came mostly from services and works, Patriotic EB being a leader in this chapter.

The expenses declared in the same period amounted to about MDL 23 million, with 78% concentrated in four competitors (PAS, Patriotic EB, Alternative EB, and PN). The main destination was electoral advertising: TV and radio spots (44%), promotional materials (22%), online advertising (10%), and advertising on social networks (7%).

Civic monitoring carried out by Promo-LEX identified unreported expenses of at least MDL 693,243, especially for advertising on social networks (72%), transportation (14%), trips abroad (7%), and rewards for activists (4%). The largest discrepancies were estimated for PAS (43% of the total), followed by PPDA (12%), LOC (10%), and UCSM (7%).

Electoral bodies. During the monitoring period, the Central Electoral Commission held 10 meetings and adopted 126 decisions concerning the parliamentary elections. However, the last-minute decision on the relocation of five polling stations for voters from the left bank of the Dniester raised concerns about the limitation of access to voting. Although the CEC invoked the security risks reported by the General Police Inspectorate, the Security and Intelligence Service, and the Bureau for Reintegration Policies, the Promo-LEX OM found this decision extraordinary, having an impact on the exercise of constitutional rights. Reserve locations were preliminarily established for six other polling stations.

The process of accreditation of observers and journalists has seen a significant increase compared to previous elections, with nearly 3,000 observers and 111 journalists confirmed. In parallel, 16 opinion polls were authorized, but the phenomenon of unauthorized polls remained present, with examples such as the one attributed to AtlasIntel. At the level of electoral councils and bureaus, Promo-LEX observers found both compliance with working hours and significant deficiencies, such as lack of members in PEBs, non-compliance with incompatibilities by certain members, and cases of electoral corruption. In addition, only 35% of the visited polling stations were accessible to people with special needs.

Hate speech. Between 5 and 18 September 2025, at least 72 cases of hate speech were documented, 62 of them in an electoral context, viewed by more than 2.6 million people. They were based on criteria such as political affiliation, opinion, sexual orientation, gender identity, ethnicity, health, sex, and gender. Hate speech was generated by politicians and electoral competitors, as well as by supporters and opinion leaders. Identified hate speech took the form of incitement to discrimination and violence against LGBT people, Roma, women, or politicians, as well as sexist, xenophobic, and racist messages that reinforced stereotypes and prejudice.

Homophobic speeches were generated by candidates Constantin Cojocari and Ion Ceban, messages that promoted prejudices and stereotypes regarding Roma people were launched by Renato Usatîi, and sexist and xenophobic messages were generated by Victoria Furtună. During the monitoring period, we also identified messages of incitement to violence against politicians, electoral candidates, and their supporters generated by opinion leaders and activists. The stigmatization of some groups of people based on political opinion was further used for electoral mobilization. Hate speech has harmed the dignity and rights of many social groups and damaged social cohesion.

Petru Culeac is the co-founder and Executive Director of the Moldova Development Institute, a newly established organization dedicated to improving the social, political, and economic landscape in Moldova. With over 15 years of experience in Moldova’s non-pro!it sector, Petru has an in-depth understanding of the country’s context and its development agenda as well as extensive organizational management experience. Until 2023, Petru served as Executive Director of Soros Foundation Moldova, a renowned non-profit foundation, part of the Open Society Foundations network, recognized as a key civil society actor in the Republic of Moldova. Under Petru’s leadership, the foundation expanded its portfolio and successfully implemented numerous technical assistance projects, including for Moldovan authorities in areas such as anti-corruption, justice reform, elections, and education, as well as emergency response projects at the onset of the COVID-19 pandemic. Previously, Petru worked in areas of democracy promotion, free and fair elections, local development, citizen engagement, and youth activism, successfully cooperating with local and international organizations, such as USAID, Chemonics, East Europe Foundation, and IFC. Petru’s academic background includes degrees in Business Management, and European and International Studies from institutions in Moldova, France, and the United States.

Performance of electoral competitors. The electoral campaign for the parliamentary elections of 28 September 2025 is apparently more dynamic than the one for the 2021 elections, with 1,487 electoral campaign activities being observed for a similar reporting period, most of them consisting of the distribution of informative materials (71%) and meetings with voters (18%), compared to 1,111 events observed for the previous elections. The most active were PAS (509), Patriotic EB (380), and Alternative EB (251).

Also, 3,214 cases of electoral advertising were documented, mostly printed materials (41%) and visibility objects (30%). In this context, some violations were also identified, such as the placement of materials in prohibited places, the lack of full printing data, or the use of political advertising materials for purposes of electoral campaigning before the actual start of campaign. Most cases of improper use concerned the Patriotic EB, followed by MRM, LOC, PAS, Alternative EB, and CUB.

The Promo-LEX OM recorded 52 cases of abuse of administrative resources, most of which concerned PAS, through the use of public institutions and the involvement of officials in electoral campaigning. Two cases of potential voter corruption (Victory PB and PPN) and the involvement of religious denominations in the campaign, with at least four documented incidents, were also reported.

During the observed period, acts of intimidation were reported: PL candidate Vladimir Meleca was illegally detained in the Transnistrian region, and a conflict occurred in Causeni between the veterans of the war on the Dniester and the Patriotic EB, which required the intervention of the police.

Promo-LEX also monitored the involvement of “third parties”. At least 13 cases were identified, including online networks coordinated by the Russian Federation to promote Ilan Șor and the Victory PB, Facebook pages and YouTube channels that propagate pro-East or pro-EU messages, as well as civic initiatives such as EUROPE 2028.

Financing of the electoral campaign. By 8 September, 21 out of the 23 competitors opened bank accounts and 19 filed financial reports. The declared income totaled about MDL 28.4 million, mostly from donations of individuals (47%) and transfers from the current accounts of parties (37%). The most income was reported by PAS, Alternative EB, Patriotic EB, and PN, which cumulated 78% of the total. The declared expenses amounted to over MDL 21.5 million, with the largest part directed to promotional materials (51%) and advertising (35%).

The civic monitoring of electoral campaign financing revealed discrepancies between official reports and actual expenditures estimated by the Promo-LEX OM, which identified unreported amounts of over MDL 1.3 million in 14 competitors, especially in CUB, MRM, and Patriotic EB.

Hate speech and incitement to discrimination. Between 20 August and 4 September, at least 78 cases of hate speech, incitement to discrimination, or other forms of manifestation of intolerance were identified, which were viewed more than 830 thousand times. About 53% of these (41 cases) were spread through mobile apps. Most often, hate speech was based on criteria of political affiliation, professional activity, opinion, sexual orientation, gender identity, health, sex, or gender.

Further, hate speech with a high level of gravity was identified that took the form of incitement to violence and incitement to discrimination. Dehumanization rhetoric used by various actors was also used during this period. These types of messages justified violence and made people in targeted groups an easier target of physical and verbal attack.

Xenophobic, homophobic, and sexist messages also kept appearing in public and electoral speeches. Hate speech was directed against various social groups such as Muslims, Romanians/Romanian speakers, journalists, men, etc. Politicians, members and/or supporters of political parties, women and LGBT people continue to be targeted by hate speech in greater numbers.

Electoral bodies and public administration. The CEC conducted its activity transparently, having organized 12 meetings and adopted 71 decisions. The number of accredited observers increased compared to the 2024 ballots, with more than 2,100 national and international observers registered. Promo-LEX draws attention to the risk of the appearance of “false observers” and calls for the intervention of the authorities to stop these practices. At the same time, the Promo-LEX OM reminds that access to polling stations is allowed only to observers accredited by the CEC, through qualified organizations.

The CEC confirmed representatives and trusted persons for 16 electoral competitors and extended the certification of electoral officials, having validated over 26,000 people. The number of ballot papers increased by more than 42,000 in electoral districts 1-36, especially in Chisinau and Balti, but decreased fourfold in the Transnistrian region, which, according to the Promo-LEX OM, can limit access to vote and generate large queues.

District electoral councils (DECs) generally worked according to the legislation, but there were cases of limiting observers’ access to electoral information and difficulties in setting up precinct electoral bureaus. The unofficial application of a mechanism for checking the integrity of potential electoral officials was also reported, which requires clarity and transparency.

Legal framework. The suspension of activity of Chisinau Mayor Ion Ceban, candidate for the position of MP, highlighted shortcomings in the application of rules on the separation of public office from electoral campaign. Although he said he had suspended his work, the CEC found the opposite and issued him a warning.

Some town halls have also allocated public halls for meetings with voters without the approval of the local council, raising suspicions of illegal use of public property and discrimination against competitors.

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.

Petru Culeac is the co-founder and Executive Director of the Moldova Development Institute, a newly established organization dedicated to improving the social, political, and economic landscape in Moldova. With over 15 years of experience in Moldova’s non-pro!it sector, Petru has an in-depth understanding of the country’s context and its development agenda as well as extensive organizational management experience. Until 2023, Petru served as Executive Director of Soros Foundation Moldova, a renowned non-profit foundation, part of the Open Society Foundations network, recognized as a key civil society actor in the Republic of Moldova. Under Petru’s leadership, the foundation expanded its portfolio and successfully implemented numerous technical assistance projects, including for Moldovan authorities in areas such as anti-corruption, justice reform, elections, and education, as well as emergency response projects at the onset of the COVID-19 pandemic. Previously, Petru worked in areas of democracy promotion, free and fair elections, local development, citizen engagement, and youth activism, successfully cooperating with local and international organizations, such as USAID, Chemonics, East Europe Foundation, and IFC. Petru’s academic background includes degrees in Business Management, and European and International Studies from institutions in Moldova, France, and the United States.

Petru Culeac is the co-founder and Executive Director of the Moldova Development Institute, a newly established organization dedicated to improving the social, political, and economic landscape in Moldova. With over 15 years of experience in Moldova’s non-pro!it sector, Petru has an in-depth understanding of the country’s context and its development agenda as well as extensive organizational management experience. Until 2023, Petru served as Executive Director of Soros Foundation Moldova, a renowned non-profit foundation, part of the Open Society Foundations network, recognized as a key civil society actor in the Republic of Moldova. Under Petru’s leadership, the foundation expanded its portfolio and successfully implemented numerous technical assistance projects, including for Moldovan authorities in areas such as anti-corruption, justice reform, elections, and education, as well as emergency response projects at the onset of the COVID-19 pandemic. Previously, Petru worked in areas of democracy promotion, free and fair elections, local development, citizen engagement, and youth activism, successfully cooperating with local and international organizations, such as USAID, Chemonics, East Europe Foundation, and IFC. Petru’s academic background includes degrees in Business Management, and European and International Studies from institutions in Moldova, France, and the United States.

Legal Framework. On 17 April, the Parliament of the Republic of Moldova set the date for the 2025 parliamentary elections as 28 September. Selecting a date more than five months in advance makes the electoral process more predictable.

Of the 22 recommendations that Promo-LEX made after the 2021 parliamentary elections, 20 were partially or fully implemented and two were ignored. Recommendations that were implemented include the regulation of organized voter transportation, the prohibition of religious groups’ involvement in the campaign, and improved access to voting for the diaspora.

Three major changes were made in 2024–2025, including changes to the registration of electoral competitors and toughen sanctions for electoral corruption.

Nomination of Candidates. Nominations for the parliamentary elections on 28 September 2025, began on 20 July and will end 40 days before the election. The Central Electoral Commission (CEC) announced that only 39 of the 66 registered political parties meet the conditions for participation and 14 parties are awaiting decisions from the Public Services Agency (PSA) or the courts. Parties that did not submit a complete list of their leadership to the PSA, as required by the recent amendments to the Law on Political Parties, have had their right to participate in the campaign restricted. This rule could affect the competitiveness of the parliamentary elections. During the first two days, the PAS and the PPDA submitted applications to register their lists, and seven potential independent candidates requested to begin collecting signatures.

Promotional, Election-oriented Activities. During the pre-election period, Promo-LEX observed several parties and potential electoral competitors holding such activities, even though the official campaign does not begin until 29 August 2025. According to the law, an electoral campaign is only permitted after candidate registration and no earlier than 30 days before the election. This means that the parties’ current actions can be considered political promotional activities if they are not held in the context of initiative group activities and/or the promotion of potential designated candidates.

Active parties include PAS, which launched a national information campaign on its achievements and plans for EU accession, and PSRM, which promotes “sovereign politics” through the distribution of materials and collection of signatures. Other parties, including PPMM, PRIM, PPVM, MRM, BE “Alternativa”, and BP “Împreună”, are holding online campaigns, meetings with citizens, protests, and presentations of political programs.

Use of Administrative Resources. Promo-LEX warns against using administrative resources for political purposes during or outside the election period, as this contravenes international standards on the separation of state and political parties.

Before the parliamentary elections, state institutions used public resources and funds to gain political capital. After the election date was set, Parliament amended the state budget and reallocated funds for various projects. The government then launched the “Moldova Poate” campaign, which PAS took up and promoted. Promo-LEX points out that these initiatives could be mistaken for election promises.

The Mayor’s Office of Chisinau ran information campaigns with personalized messages for Mayor Ion Ceban, and MAN sponsored the campaigns’ promotion on online platforms. According to Promo-LEX, President Maia Sandu was also involved in supporting the PAS list of candidates. This raises questions about the neutrality of the presidential office.

Financing of Elections and Electoral Campaigns. The CEC budget for the 28 September 2025 parliamentary elections is approximately 152.86 million MDL, of which over 10 million are intended for postal voting.

Electoral campaign financing is strictly regulated, with ceilings set by the CEC representing 0.1% of state budget revenues relative to the number of voters. For initiative groups (IGs), this ceiling is multiplied by the maximum number of signatures required to support a candidate for elective office. Candidates may use their own resources, accept donations, and receive interest-free loans from the state. However, funding from foreign companies, non-governmental organizations, religious groups, or citizens with no declared income is prohibited.

All parties must open a dedicated bank account and appoint a responsible treasurer. Financial reports must be submitted to the CEC weekly and published within 24 hours. Failure to comply with these rules may result in sanctions from the CEC ranging from warnings and withdrawal of budget allocations to cancellation of an electoral competitor’s registration or deregistration of a party.

Central Electoral Commission (CEC) activity. Elections are organized according to the Calendar Program approved by the CEC. Although the CEC is operating at full capacity, the staff was not complete at the beginning of the election period.

For the 2025 parliamentary elections, the CEC plans to increase the number of polling stations abroad. Postal voting is now available in Japan, South Korea, Australia, and New Zealand, in addition to the countries where it was previously implemented.

During the monitoring period, the CEC received at least six complaints regarding the use of campaign materials outside the legal period, the use of administrative resources, and undeclared donations. Most of these complaints were filed by MAN and PAS.

Hate Speech and Incitement to Discrimination. The parliamentary elections of 28 September 2025 represent the third election held since the introduction of sanctions for hate speech and incitement to discrimination or violence based on prejudice in 2022. According to Promo-LEX monitoring, the frequency of such cases has decreased: the daily average was 1.1 cases in the 2023 local elections and 2.6 cases in the 2024 presidential elections, compared to the 3.9 cases recorded in the 2021 parliamentary elections. Additionally, the number of complaints filed with the General Police Inspectorate has decreased considerably.

Finally, the Monitoring Report provides several recommendations to the institutions involved in the electoral process. These recommendations are addressed to Parliament, the Central Electoral Commission, the Government of the Republic of Moldova, local public authorities, and political parties, and aim to clearly define and sanction the use of administrative resources; ensure the predictability of the electoral process; increase transparency in decision-making and publish information on the CEC’s budget and regulations; prohibit the use of administrative resources during the election period; and conduct election campaign in strict accordance with the law.

An important finding of the monitoring is that political parties have apparently taken responsibility, as several parties have submitted to the CEC financial reports for 2024 – 95% (compared to 75% for 2023). However, although the number of reports submitted has increased, their quality remains questionable. Thus, we find that some parties, especially BP Victorie and its constituents (FASM, PR, PPV and ŞANSĂ), with costly political activities, reported “zero” income and expenses.

The report also shows that the electronic reporting module SSI “Financial Control” continued to function with deficiencies, which led to the extension of reporting deadlines. In this context, Promo-LEX recommends that the Central Electoral Commission (CEC) consider a possible rewrite of the entire reporting module.

The main source of party income remains state budget allocations, which in 2024 constituted 75% of total reported income (2023: 84%). In contrast, income from donations increased significantly, reaching 13.5 million lei – three times more than in 2023. The most donations were received by PAS (35%), PN (27%) and PSRM (18%).

On the other hand, membership fees have decreased, being collected by only 17 parties, and in the case of 11 of them, not even the leaders of the parties have paid their contributions. The monitoring also highlighted the fact that the number of members declared by the parties is still decreasing. Only three parties (PAS, PSRM and PL) reported over 10,000 members, and 28% of the parties declared under 1,000 members, the minimum legal threshold for registration.

In this context, Promo-LEX recommends that Parliament identify a solution that ensures a balance between political financing from public and private sources. At the same time, recommendations were formulated for parties, including: active involvement of members by collecting dues and diversifying funding sources, in order to reduce dependence on public funds .

In terms of expenses, 39 parties declared 71 million lei, with the most reported by PAS (47%), PSRM (17%) and PN (11%).

Promo-LEX estimated unreported expenditures of at least 20 million lei for 20 political parties, which represents 28% of the 71 million officially reported. The most unreported expenditures were estimated for BP Victorie (81%), followed by PSRM (8%), and PN, PAS, PSDE and PPVM at 2% each. The most common types of unreported expenditures concerned advertising on social networks (37%), political events (21%) and headquarters (12%).

The Promo-LEX report also highlights the multiple legislative amendments made recently or during 2024, targeting the activity and financing of political parties, including: the regulation of political blocs, the ban on successor parties, tougher sanctions for voter corruption and illegal financing, as well as the ban on promoting political leaders through philanthropic activities. Failure to comply with the new legal provisions may lead to the limitation of the party’s activity or the ban on participation in elections. However, the legislation still does not include rules on political and electoral financing by third parties, although this has been recommended by international institutions and national observers.

During the period under review, the CEC sanctioned several parties and donors, initiating 33 contravention proceedings for non-compliant financial reporting and notifying the Court of Accounts for verifications. The Ministry of Justice was notified in the case of eight parties, and the activity of six of them was limited. In the case of five other political parties, the CEC requested their dissolution. Also during the monitored period, the Anti-Corruption Prosecutor’s Office prosecuted 12 criminal cases, and in March 2025, two deputies and a close associate of them were convicted for illegal financing and violation of the way in which the parties’ financial resources were managed, who are now being prosecuted.

The election administration followed the electoral calendar and efficiently organized the technical aspects of the elections. The fact that Central Electoral Bureau (CEB) meetings were not public reduced the transparency of the process. The very high number of online campaign complaints received by the CEB created a considerable workload, and in some cases, the filing of complaints indicated a coordinated effort to load the CEB’s agenda.

In the electoral campaign, the right to association was respected and candidates were able to organize their campaign activities generally without restrictions. The right to freedom of expression, although generally respected, was affected in several cases by decisions of electoral bureaus to remove unlabeled political advertising, even when it expressed the political views of journalists or ordinary citizens. Candidates presented the choices the citizens have to make differently: George Simion urged them to choose between the system and the anti-system, and Nicușor Dan between the pro-EU, pro-Western orientation and alignment with the Russian Federation’s policy. Both candidates took part in a televised debate; George Simion’s non-participation in the ensuing debates limited voters’ access to information about his political program. Alarmist rumors and speculation increased in the run-off campaign; the authorities published denials of several intentional misinformation by the AUR to maintain calm and restore confidence in the electoral process. Regrettably, the campaign was marked by verbal violence and discriminatory attacks.

In the second round of elections, several online monitoring initiatives warned of coordinated inauthentic content. As for the online campaign, Expert Forum monitored more than 1,000 public Facebook groups, identifying 194 pages with potentially coordinated behavior. EFOR also identified a network of inauthentic accounts promoted with the hashtag #ankaversace on Tik Tok, which was only partially removed by the platform.  A disinformation campaign via Telegram aimed at swaying the vote in favor of a candidate was labeled by the MFA as Russian interference. Monitoring by a civic group, detailed in the Cheile Împărăției report, confirmed the existence of well-organized networks operating with significant influence capacity, on a hub-and-spoke model, with several dozen key accounts and thousands of satellite accounts.

The first round of the presidential elections recorded the highest costs for a presidential election: income of 172 million lei and expenses of 165 lei, and the overall limits for income and expenditure remain very high. Positively, the PEA published datasets with income and expenditure for the second round on 16 and 17 May on the finantarepartide.ro portal. Nicușor Dan has declared income of 40.4 million lei and expenditure of 31.5 million lei as of 16 May, much of the income originating from loans. George Simion has so far not declared any income or expenditure for the second round. Although the candidate would still have had time to declare these funds, the failure to do so significantly reduced the transparency of the electoral process and goes against the spirit of the law. The fact that the identity of several Facebook accounts that are not attributable to a candidate, which promoted negative campaigning prior to the first round, has not been identified so far, despite complaints lodged to the PEA, is a limitation of the transparency and integrity of the process.

The number of observers accredited by Vot Corect in the country and abroad increased after the first round to 1276. They submitted information from around 1,850 polling stations during the three days of observation through the Vote Monitor app. After the first round, voters submitted over 3,500 complaints about the electoral process via the votcorect.ro portal, most of them related to voters who posted their stamped ballot papers online in violation of the law.

The CEB has adopted numerous decisions regarding complaints about online political advertising. Meta has challenged some of the CEB decisions at the Bucharest Court of Appeal, but these have been rejected and some are currently under appeal. Rădăuțiul Civic and Expert Forum have submitted a request to the Bucharest Court of Appeal to demand that the CEB allow the observation of voting with a special ballot box.

Election day was generally orderly, despite some attempts to disrupt the process and manipulate voters. The opening and voting procedures were positively assessed in more than 98% of observed polling stations. During voting, observers reported cases of voter influence, including pressure and vote buying. Vote counting was positively assessed in 95.7% of polling stations. Observers reported no attempts to compromise the fairness of the results, with one exception, but noted a number of procedural omissions.

The presidential election offered voters a variety of choices and fundamental rights were generally respected. The election administration organized efficiently the technical aspects of the process and election day was orderly, without significant incidents. The fact that the decision to annul the November elections was insufficiently explained to the voters, combined with the lack of a full account of the failed election and the measures that should have been taken to ensure the integrity of the process negatively affected public confidence in the process and cast doubt on the state institutions’ resilience against hybrid attacks. The elections were held against a backdrop of distrust in the ruling political parties and polarization brought on by the annulled election.

The election legislation is generally adequate for organising democratic elections; however, changes by government emergency ordinance 1/2025 were adopted non-transparently, in violation of procedures and far too soon before the elections. Moreover, some of the amendments, including those related to the marking of political advertisements, changes in the composition of election commissions and shorter hours for some polling stations abroad affected stakeholders’ rights. The elections were organized taking into account several decisions of the Constitutional Court and recommendations of the Venice Commission related to the 2024 electoral process, which were not, however, transposed into law for greater clarity.

The election administration respected the election calendar and took the necessary measures for the good conduct of the elections, but the election commission composition clearly favoured two of the candidates, while in most commissions eight others were not represented at all. Election commission sessions are not public at any level, which reduced transparency.

A total of 17,988,031 voters were registered on the permanent lists in the country; the voter register also includes 1,016,350 voters residing abroad. The electronic verification of voter identity and marking in real time those who have voted through the SIMPV allows the identification of multiple voting attempts. Voters who cannot reach polling stations can opt for postal voting, if abroad, or for mobile voting in the country.

Out of 25 nominees, the Central Election Bureau registered 12 candidates and rejected 13; 11 candidates remained on the ballot after one withdrew. The high number of supporting signatures required to file a candidacy limits access to the electoral competition, and the lack of visibility of the signature collection campaigns, combined with the non-transparent verification process, raised questions about their veracity. The signature verification process could not be observed, and although the BEC regulated the methodology in a decision, the regulation is not part of the law and does not have an effect on future elections. Although the Constitutional Court issued several rulings after the 2024 annulled election, the law has not been amended to clearly define eligibility criteria and standards related to observing constitutional principles. The short deadlines for vetting, unclear legislation, lack of investigative tools in case of suspicions and the very long timeframes for the resolution of criminal cases reduce the efficiency of this system, which needs significant reform to increase public confidence.

During the campaign the right to free speech and freedom of association were generally respected and candidates were able to organize their campaign and deliver their message to voters without restrictions. Restrictive outdoor campaigning regulations, which reduce campaign visibility, prompted several candidates to start campaigning during support signature collection in order to be able to use large billboards and banners, which are banned during the campaign. Most of the campaign was conducted online and the overall tone of the campaign was rather aggressive and dominated by attacks between candidates. Several candidates took on a conservative and nationalist rhetoric, partly continuing the narratives launched by Călin Georgescu in 2024. The presidential debates added vitality to the campaign and attracted public interest. The CEB and the Ilfov county election commission noted the illegality of an extensive campaign carried out by the AUR party in violation of personal data protection regulations.

Online campaigning, especially on Tik Tok, continued to be contaminated by coordinated inauthentic behavior, which was noted by several electoral competitors. Expert Forum social media monitoring identified a significant increase in coordinated, politically motivated content, disguised as organic content and generated by networks of inauthentic accounts. In the absence of regulatory mechanisms adapted for digital content, third-party campaign financing continues to have a significant impact. Expert Forum identified two strategies to promote inauthentic content, both predominantly found on TikTok. In addition to internal inauthentic behavior, the campaign was also affected by foreign interference attempts associated with Russian Federation interests. On election day, the National Cyber Security Directorate (DNSC) reported that numerous websites of public interest had been the target of cyber-attacks claimed by a pro-Russian group; all affected websites were functional during the same day.

Competitors did not have equitable access to resources, with the Romania Forward coalition candidate enjoying a visible financial advantage. Limits on income and expenditure are high and this presidential election campaign was the most expensive so far. Political financing relies primarily on public resources, subsidies and reimbursements from public funds, which reduces the parties’ independence from the state. The campaign was mostly financed by loans and private funding declared by the parties, and spending most prominently included costs for online and media promotion. Campaign finance transparency remains limited even if revenues and expenditures are disclosed during the campaign, as the donors are not disclosed. Pre-campaigning is not effectively regulated. Although the PEA initiated more checks during the campaign, staff shortage limits the institution’s ability to act at short notice. Auditing financial sources beyond the submitted reports is limited and not within AEP’s attributions, which significantly limits transparency and allows illegally obtained funds to be reimbursed from public money.

The legal framework allows stakeholders to file complaints and appeals, and the deadlines for both the election administration and the courts are mostly reasonable. BEC decisions can be appealed to the High Court or the Court of Appeal, but the election law does not define the procedures for appealing decisions to the courts, with certain exceptions, contrary to international standards. Although Vot Corect has not observed the resolution of complaints in a systematic manner, we consider that in general the deadlines given by the courts were short, at least for appeals related to BEC decisions. The BEC received a significant number of complaints related to online political advertising; of more than 1,700 decisions, few were challenged, and were upheld by the court in most cases. Some of the BEC decisions were criticized, including for considering criteria beyond the legal definitions and for unfair penalties. Since January, almost 150 cases related to the annulment or suspension of the Constitutional Court decision to annul the November election were registered with the courts, eventually finding one judge to decide in favour of the petitioner, even though Constitutional Court decisions are final and binding. While the right of petitioners to lodge complaints is essential and should not be limited, such rulings undermine the integrity and credibility of the process and the appeal mechanisms.

Election day was generally calm and orderly. Opening and voting were assessed positively in the overwhelming majority of observed polling stations, but observers also noted cases where the mobile ballot box procedures were not respected and cases where voters residing in another locality were not allowed to vote. Although several procedural omissions were observed during the vote count, observers also assessed the counting generally positively and noted that in almost all observed polling stations results were correctly recorded. Voting abroad was efficiently organized with multiple options for exercising the right to vote.

Vot Corect is a civil society coalition formed by Expert Forum, the Civic Resource Centre, Civica, the Center for the Study of Democracy, the Civic Rădăuți Association, the Electoral Observatory, the Federation of Law Students’ Associations of Romania and Code for Romania. For election observation in the Republic of Moldova we cooperate with the Promo-Lex Association.

• For the 2024 local and European elections, the manner in which commissions were setup has been modified for the merger of elections, through GEO 21/2024. The Venice Commission confirmed in an opinion on the merger of elections, published on 18 March and quoting EFOR/the Vot Corect coalition, that the use of the GEOs “undermines legislative quality, legal certainty, and democratic principles, including the principle of the separation of powers.”, and “Contrary to international standards, the adoption of GEO 21/2024 was neither consensual nor the result of adequate public consultation.

• Ahead of the 2020 local and parliamentary elections, the manner in which electoral commissions are formed has changed, just a few months before election day. For example, changes were introduced for local elections regarding the manner in which representatives of parliamentary parties fill in the commissions, favoring parties that had representation in both chambers.

• For this year’s elections, the rule was amended by art. 3 (4) of GEO 1/2025, an ordinance approved without any public consultation. The GEO amends the method of filling out county/sector/foreign commissions and those for polling stations with representatives of political parties.

• EFOR requested on January 17 the Government and Parliament to repeal these regulations, without receiving any response. The draft law, debated in committees in the Senate, but not voted on in plenary, did not introduce any changes in this regard. The draft was sent to the Chamber of Deputies, by tacit adoption. EFOR and other organizations also criticized the way in which the GEO was approved, without any consultations and transparency. For example, the GEO draft was put into public debate after its approval.

• Law 370/2004 refers in its original form to political parties participating in the elections or having proposed candidates; the original law is not necessarily clearer either, using various formulations. According to the new regulations, in the first phase, the commissions at the intermediate level and those at the polling station level are filled with one representative of each parliamentary political party, regardless of whether it has registered candidates or not. In the second phase, the commissions are filled, by drawing lots, with representatives of political parties that are not represented in Parliament and have proposed a candidate.

• This procedure of filling in the commissions with representatives of political parties gives an unjustified advantage to parliamentary political parties, especially since two of them, POT and SOS Romania, do not have candidates. It is not clear why some parties who are not associated and did not support with any registered candidate have representatives in the electoral commissions. On the other hand, non-parliamentary parties that propose candidates have very little chance of getting seats in the commissions. At the county level or at the polling station level, the commission is filled with 7 representatives, exactly as many parliamentary parties there are. It is worth mentioning that parties that do not have representatives can nominate delegates – but these are similar to observers and to not participate in the decision making process.

• Another problem is that independents cannot appoint representatives to electoral offices or delegates.

• The ODIHR report for the 2019 presidential elections recommended that “Political parties and independent candidates should have equal opportunity for representation on election bodies. Preferential rules that put parliamentary parties at an advantage should be reconsidered.” The current rules further limit fair representation.

• Although this change is not explained by the initiators, we can deduce that it will create imbalances of representation in the electoral commissions. Even if according to the law and the regulation on the organization and functioning of electoral commissions, members exercise a state function and must be neutral in their activity and decision-making, we know that in practice the situation is more complex, and objectivity is not always at the level we would expect. In practice, most likely three parties will have a closer interest in the candidate Crin Antonescu (PSD, PNL, UDMR), and another three in the candidate George Simion (AUR, POT and SOS Romania). Such majorities can distort the balance in the decision-making process.

• In conclusion, this amendment may affect several principles regarding the formation of electoral bureaus, as well as the transparency of the process, as follows:
  – It was approved non-transparently, without any consultation.
  – It was approved by GEO, without justifying the urgency, just a few months before the elections.
  – The draft GEO has not been approved by law up to this point.
  – It only applies to these elections – again, it is not clear where the need for fixed amendments to this regulation came from. EFOR has also criticized in the past the use of GEOs that modify significant aspects related to the organization of elections and that are applied punctually for one election, without a solid justification.
  – The way electoral bureaus are formed favors certain candidates.
  – It continues to limit the representation of independents.

Mariam Chikhladze is an independent international consultant specializing in democratic elections, civil society development, and parliamentary and political party strengthening. She has extensive experience with USAID’s governance programs in Georgia, managing the parliamentary support portfolios. She has also contributed to UNDP’s key legislative strengthening project. Previously, Mariam worked with the International Republican Institute (IRI) on programs in Georgia and Armenia and on behalf of the Alliance of Democracies Foundation, facilitated the political parties’ pledge for election integrity in the 2020 parliamentary elections in Georgia. Earlier in her career, she managed the grassroots empowerment program of the Netherlands Institute for Multiparty Democracy (NIMD) in four regions of Georgia. Mariam Chikhladze holds a Master’s in Public Policy Analysis from the Bush School of Public Service and Government at Texas A&M University, awarded through the Fulbright Graduate Student Program. She also completed the Edmund Muskie Professional Fellowship at the Hudson Institute, in Washington, DC.