EPDE proposes several calls to action to discourage the continued participation of fake observers, to protect the integrity of the institutions they represent in the Russian public, and to hold individuals accountable for undermining democratic processes:

1. EPDE calls on election management bodies to introduce / update transparency regulations and codes of conduct to prevent their staff members and experts from intentional or unintentional involvement in politically biased fake observation missions.
2. The institutions could assess career and financial disincentives for individuals intentionally participating in these activities, such as banning participation in international travel and missions or in international academic exchange.
3. To reinforce these measures, EPDE encourages peer election management bodies to apply institutional pressure and public censure against commissions found enabling or tolerating participation in fake observation missions, creating accountability within the professional network of CECs.
4. EPDE encourages media outlets globally to raise awareness and educate citizens about the dangers of fake election observation and the role certain individuals or organizations play in legitimizing fraudulent elections abroad to reduce their credibility and discourage others from participating.
5. EPDE urges election monitoring bodies and election commissions to adopt stricter transparency measures when holding elections and accrediting domestic and international observers. These should include publishing a complete, detailed list of all observers and their affiliations to simplify the identification and discreditation of biased election observers.

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.

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-pro!it 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.

The  election was effectively organized and voters’ fundamental rights were generally respected. However, the electoral competition was fundamentally affected by the results of the first round of the presidential elections. The process took place in a context of numerous disinformation or negative campaigns, which had a negative impact on the outcome of the parliamentary elections. The overlap of the elections and the decision of the Constitutional Court to recount the votes from the presidential elections distracted the public from the parliamentary elections and affected public confidence in the electoral process.

The transparency of the electoral process was reduced by the fact that the meetings of the Central Electoral Bureau (BEC) were not public. Its decisions (decizii/hotărâri) were generally published in due time, but, regrettably, the minutes of the meetings remained secret, and their publication was explicitly prohibited. Some of the decisions issued by the BEC, including the one related to the interpretation of the phrase parliamentary party, were contested, including by Vot Correct. The electoral administration generally managed the electoral process effectively.

The number of candidates increased compared to the previous elections. More than 50 lists were rejected by various constituency commissions because the candidates did not follow the administrative procedures or did not ensure the presence of both sexes on the candidate lists, as the law requires. The absence of some of the parties, including currently parliamentary ones, on the ballots in certain constituencies, as a result of the rejection of the candidacies, created confusion among some voters. The number of women on the lists increased compared to the previous elections, but few were placed in eligible positions. Data published by BEC about candidates is limited. The support signature verification process could not be observed, which limits transparency. The collection of signatures in electronic format was limited and only a few parties used this option. The lists of some parties, such as Noua Romania (for the out of country constituency), were rejected due to irregularities regarding the collected signatures. The integrity of the signature collection process remains in question, especially in the context where some competitors did not have any kind of visible signature collection campaign.

The overlapping of the two electoral campaigns and the results of the first round of voting significantly limited the visibility of the campaign for the parliamentary elections. This lacked visibility, and the conduct of the presidential elections confiscated the relevance of the debates for the parliamentary ones. Online campaigning continued to be intense and numerous cases where electoral propaganda was not declared as such were identified. The methods of outdoor promotion are very limited, which affects the voters’ right to information, and numerous violations of the legislation regarding the use of the electoral boards have been noted. Numerous actions to continue the electoral campaign were observed on the voting days and before the elections, including by candidates or their supporters with visibility, a fact that affected the integrity of the organization of the election day.

The transparency of campaign financing was reduced by the intermittent publication of data by the Permanent Electoral Authority (AEP), a fact criticized also in the case of the presidential elections. The lack of consistency in the publication of data denotes a lack of institutional transparency and limits the public’s understanding of how the electoral process was financed. Revenues of 250 million lei and expenses of 210 million lei were recorded, most of the funds (40%) being allocated for online promotion services. In addition to the officially declared expenses, indirect promotion through third parties was observed, such as Facebook pages close to parties that define themselves as publications. A small part of the parties’ contributions come from subsidies, i.e. 6.9 million lei, which indicates that they preferred to declare private funds that they can get reimbursed if they get 3% of the votes. It is unclear what the parties spend the subsidies on, which have reached a historic high this year, if they do not invest in political promotion in the middle of the election year. Between August and October, the parties spent 71 million lei on media and propaganda, which represents a third of the total campaign costs for the parliamentary elections. In fact, campaign costs are much higher than those formally declared for a campaign month, and political parties spend high sums of money in the months before the campaign on less transparent rules.

Election days were conducted in an orderly and calm manner, with few incidents reported by observers, and the turnout was 52.50%. The process was assessed positively by Vot Corect observers in almost 97% of the polling stations observed during the opening and voting and almost 95% of the polling stations observed during the vote counting. Observers reported a tense atmosphere during voting in 4.8% of cases and crowding in 15%. The polling station commissions did not understand well where voters can vote according to their domicile and residence in a worrying percentage of approximately 14%. When counting the votes, polling station commission presidents had difficulties filling in the protocols in 19.2% of the observed sections; in 14% the counting took place in a tense atmosphere. In a few cases observers were unjustifiably removed from polling stations, and some polling station commission took the abusive decision to allow observation only during voting and not during the counting of votes. The opening procedure was observed by Vot Corect in 183 precincts, the voting in 737, and the counting of votes in 204. Due to the fact that in some cases the observers did not answer all the questions on the forms, the statistical data do not always refer to the total number of sections observed.

In favor of the administrative-command management of the whole process is also the general rush: 1,725 people were allegedly nominated by parties, public associations, labor collectives and citizens in just one week in the number necessary to form virtually all commissions with the maximum number of members.

At the same time, the informing of citizens about the possibility of nomination, as in the previous campaign of 2024, was minimal, which allows us to conclude that the authorities were not interested in the active participation of voters in the formation of territorial election commissions and predetermined decisions on their composition.

Only minimal information is available to the public, both about the opportunities for nomination to the territorial election commissions and about the meetings of the bodies forming the commissions, as well as their results: the process of holding meetings remained non-transparent and non-competitive. The lists of names of members of the commissions have still not been published.

The four largest public associations (BRSM, Belaya Rus, Union of Women, Union of Veterans, Fund for Peace), which have legislatively established special relations with the state since 2023, and the trade unions, which are members of the FPB, remain the main source of the clerks, ensuring the conduct of elections* at the level of territorial election commissions (in addition to four political parties remaining after re-registration, all of which support the course of the current government). The percentage of “acceptability” of candidates from these pro-government parties and public associations imitating civil society, which together make up 63% of the composition of all commissions, tends to 100%.

Thus, given the general atmosphere of intimidation, the lack of effective information and the extremely tight deadlines, it can be said that active citizens did not really have the opportunity to nominate their representatives to the TECs. The goal of the TEC formation phase was rather the opposite: to conduct it as quickly and quietly as possible.

In the context of fake observers coming to legitimize elections in Azerbaijan, EPDE proposes several calls to action to discourage the participation of fake observers, increase transparency, and hold individuals and organizations accountable for undermining democratic processes and discrediting the integrity of the democratic institutions and democratic governments they represent:

1. EPDE calls on international organizations, political parties, and media outlets to regularly check EPDE’s list of fake observers at fakeobservers.org. Our database aims to deter participation by those who, for whatever reason or gain – blackmail, financial, or pure naivety – legitimize undemocratic elections.

2. EPDE calls on key democratic institutions, such as the European Union, U.S. Congress, or the Council of Europe, to publicly denounce and condemn participation in fake observation missions as harmful to global democratic standards. EPDE calls on democratic governments and international organizations to strengthen the diplomatic and political pressure on Azerbaijan to ensure they only invite credible and impartial election observers from organizations complying with international standards of election observation, such as OSCE/ ODIHR, OSCE PA, or the PACE.

3. The EU and other democratic countries should impose targeted sanctions or legal measures against third-country nationals participating in fake observation missions. Such measures could include travel bans, asset freezes, or bans on representing their countries in bilateral and multilateral engagements. This includes exclusion from conferences, academic exchanges, and any form of international cooperation based in the EU or other democratic na- tions.

4. EPDE encourages media outlets globally to raise awareness and educate citizens about the dangers of fake election observation and the role certain individuals play in legitimizing fraudulent elections abroad to reduce their credibility and discourage others from par- ticipating.

5. EPDE urges election monitoring bodies and domestic election commissions globally to adopt stricter transparency measures. These should include publishing a complete, detailed list of all observers, their affiliations, and their observation experience to simplify the identification and discreditation of election observers.

6. Additionally, EPDE calls on institutions and national and regional parliaments to establish and implement laws and clear ethical guidelines for individuals, particularly elected officials, participating in election observation missions. These guidelines should emphasize impartiality and non-alignment with authoritarian regimes. EPDE stresses that violating these guidelines should lead to exclusion from future international democratic election observation missions.

7. Finally, EPDE calls on democratic countries and institutions to introduce career and financial disincentives for individuals participating in these activities, such as barring them from holding positions in publicly funded democratic organizations, NGOs, or international bodies.

By suddenly calling elections* six months before the expected date and leaving 95 days for the entire procedure, the authorities once again instrumentalized electoral procedures, adjusting the election date to political objectives, thereby violating electoral legislation from the point of view of equality of opportunity for candidates and the principle of election predictability stipulated by international electoral standards.

Conducting a free and open election campaign is impossible in a situation of ongoing political terror: the list of political prisoners is updated weekly and there are consistently more than 1,300 people in it. The information space has been entirely purged; nearly all independent media outlets have been forced out of the country, and the distribution of their materials from abroad is severely hindered by politically motivated misuse of anti-extremist legislation. The “state ideology” serves the cult of authoritarian rule of A. Lukashenka. There is no recognition of the importance of political pluralism in the public field.

The incredible pressure on civil society organizations, especially human rights organizations, and their widespread liquidation exclude civilian control over the conduct of elections. There is no independent civilian monitoring of the elections within the country; at the moment, only the politically biased international election observers are invited.

In such conditions, it can be ascertained that it is impossible for citizens to exercise their electoral rights freely. 

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.

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.

Legal framework. In the observation process, OM noted concerns regarding the application of legal rules on passive and active electoral corruption. However, based on the announcement by the authorities of more than 100 minutes reports on passive electoral bribery, OM finds that there is no information on the initiation of criminal proceedings, including for electoral corruption. Promo-LEX recommends that the prosecution body takes all the necessary steps to eradicate the phenomenon of electoral corruption as a whole and not only in part.

Promo-LEX has also laid down several legal arguments showing that the electoral activity of PB Victorie (Victory) cannot be disguised under paid service and volunteer contracts, as allegedly claimed.

Performance of electoral competitors. During the monitored period, Promo-LEX observers identified 1,799 activities carried out by candidates and referendum participants, with a significant number of events organized by PAS and Maia Sandu (615 activities), while other candidates – Alexandr Stoianoglo (PSRM) and Renato Usatii (PN) – reported 329 and 223 activities, respectively. Electoral campaigning activities included distribution of information materials, meetings with voters and electoral debates.

As regards electoral advertising, Promo-LEX reported 5,073 cases of various forms of advertising, the most common being printed materials (30%) and sponsored advertising (24%).

As for the activities carried out by PR/PB Victorie (Victory), it should be recalled that only PR is registered as a referendum participant. However, it was found that the organizers of the electoral events belong to all the component parties of PB Victorie (Victory), and the promotional materials used (bags, t-shirts, LED billboards with the inscription ‘Victorie’) come mainly from PB Victorie (Victory). Thus, the electoral promotion of the referendum is de facto carried out by the same bloc whose registration was refused by the CEC.

Misuse of administrative resources was found in 114 cases, most of them related to the Action and Solidarity Party (PAS) and Maia Sandu (105 cases). Several public officials were involved in the campaign activities, in particular by the Action and Solidarity Party (PAS). Prime Minister Dorin Recean held meetings with voters, where he discussed European integration projects and encouraged support for Maia Sandu. Several ministers were also involved in the electoral campaign, distributing promotional materials in support of Maia Sandu and the ‚YES’ option in the referendum.

Also, cases of using state institutions to accumulate electoral capital, involvement of civil servants in electoral activities during working hours, as well as crediting candidates for public works carried out with public funds were observed.

Involvement of religious denominations in electoral campaigns. Promo-LEX reported 5 other cases in which members of religious denominations were involved in electoral campaigning activities, supporting candidates and using the image of religious buildings in electoral promotional materials. As a reminder, church involvement in electoral processes is forbidden.

Activities with potential for corruption. During the monitored period a number of activities was identified, including the offering of money and goods to influence voting. In several cases PB Victorie (Victory) is involved, which organized events announcing certain benefits for Moldovan citizens living in Russia, as well as electoral meetings with rewards. Victoria Furtună has also been involved in cases of coordinated electoral meetings, which raise suspicions that voters were paid to participate in them.

Electoral competitors’ revenues and expenditures: Between 20 September and 13 October, the total revenues reported by the 11 presidential competitors amounted to approximately 27.8 million MDL, which came mostly from donations from individuals and transfers from party accounts. As for expenditures, they amounted to about 24.7 million MDL, most of which were spent on advertising and promotional materials.

Expenditures estimated by Promo-LEX. The civic monitoring of electoral campaign financing was conducted from 20 September to 13 October 2024 by estimating the expenditures of electoral competitors and comparing them with the amounts declared to the Central Electoral Commission (CEC). Estimates for unreported expenditures include rewards for volunteers and campaigners, promotional materials, social media advertising and event organization. In the presidential elections, unreported expenditures amounted to at least 4,066,387 MDL, the majority of which were related to promotional materials (81%). For the referendum, unreported expenditures of 4,675,512 MDL were estimated, with a similar focus on promotional materials (64%) and social media advertising (16%).

Hate speech and incitement to discrimination. Between 23 September and 6 October 2024, 23 cases of hate speech were identified, 19 of them in an electoral context. These occurred predominantly via mobile apps and at public events, most often based on criteria such as ‘sexual orientation/gender identity’ and ‚health’.

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-pro!it 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.

Within the framework of ISFED’s observation mission, during the pre-election campaign, from August 27 to September 30, 2024, the following main tendencies were revealed:

• Since the start of the official pre-election campaign, the anti-Western campaign, inclusive of Euroscepticism and efforts to discredit Georgia’s strategic partners, remains active. Additionally, there was a campaign to exploit the tragedy of the Ukrainian people affected by the war for electoral purposes;
• In parallel with the enforcement of the law “On Transparency of Foreign Influence”, aimed at undermining civil society, discrediting messages against civil society have now increased in the ruling party’s election campaign. In particular, the ruling party’s campaign materials featured images of non-governmental organizations’ representatives in an offensive and humiliating context.
• A decision made by the Anti-Corruption Bureau on September 24, 2024, designated Transparency International – Georgia and its Executive Director, Eka Gigauri, as well as the organization Choose Europe, its Director, Khatuna Lagazidze, and the co-founders of the same organization, as individuals with declared electoral goals. According to ISFED’s assessment, this decision involved an unlawful and unjustifiably broad interpretation of the legalstandards, with the Bureau relying on an unfounded ruling from the Tbilisi Court of Appeal just days earlier. The ruling in question had determined that Choose Europe’s activities fell within the scope of declared electoral goals. However, the Bureau later revoked its decision following an appeal by the Prime Minister of Georgia, raising further concerns about the agency’s independence.
• After the date was set for elections, the recruitment process for district and precinct election commissions began. The selection of temporary members in district election commissions took place in an environment with little competition. At the same time, out of 219 vacant positions, only 10 members were selected with a high quorum (⅔ of the CEC composition), while 209 members were selected by a majority of the full CEC composition, thus excluding the election of district election commission members on the basis of a consensus decision. According to ISFED’s observation, a significant part of the members of the district election commissions elected by the CEC are primarily individuals employed by budgetary organizations;
• The selection process for professional members of precinct election commissions also took place in a low-competition environment. According to ISFED’s observation, in some cases, the members appointed by opposition parties to the district election commissions were not fully provided with the documentation of candidates participating in the selection process for professional members of precinct election commissions;
• Members of district election commissions were also not given sufficient time to properly review the competition applications submitted by the candidates for precinct election commissions. In order to select professional members, the district election commissions did not conduct interviews with any candidates, despite some commission members expressing a desire to do so. The deadlines set by the law allowed for this possibility;
• Heads and members of precinct election commissions were, in most cases, elected by an unqualified majority of the full district election commission composition, as they did not secure the support of ⅔ of the full composition of the commissions in the first vote. Some of the candidates elected as members and heads of precinct election commissions had been subject to disciplinary responsibilities during the general elections held in 2020 and/or 2021. A significant portion of precinct election commission members selected by district election commissions are individuals employed by budgetary organizations. Some of the members of precinct election commissions are also affiliated with the ruling party;
• Representatives of ISFED observed 98 training sessions held for heads of precinct election commissions across 41 election constituencies. The trainings were generally well organized. Participants received information related to the voting process. Two instances were recorded where members of the Lagodekhi and Isani district election commissions were prevented from attending the training sessions for the heads of their respective precinct election commissions;
• As a result of ISFED’s observation of mock polling procedures conducted using electronic technologies, a tendency revealed that a notable part of civil servants and individuals employed in budgetary organizations participated in the process, often organized and grouped based on their place of employment to participate in mock elections. In 10 districts, the involvement of coordinators of the “Georgian Dream – Democratic Georgia” party was noted, who facilitated transportation and mobilization of groups participating in the mock elections. Cases of registration of citizens were also recorded.
• According to the CEC decree of August 27, different remuneration was determined for the professional members of the precinct election commission and the members appointed by the party. The election administration is a collegial body where each member of the commission enjoys equal rights. According to ISFED’s assessment, this discriminatory approach harms the effective functioning of the precinct electioncommission and is also inconsistent with the principle of equality guaranteed by basic human rights and freedoms. In addition, over the years, the differentiation introduced and revealed in the activities of party-appointed and professional members of the precinct election commission—through election legislation or by-laws, particularly in terms of the division of duties or functional redistribution—undermines the core principle of staffing in the election administration and the equality of commission members;
• The issue of citizens living outside the borders of Georgia actively exercising their electoral rights remains a significant challenge. Despite numerous requests from voters and several lawsuits filed by involved stakeholders (including two lawsuits from ISFED) calling for the creation of additional precincts abroad, the court did not satisfy these requests. According to ISFED’s assessment, the Central Election Commission and the Ministry of Foreign Affairs did not demonstrate the necessary will and did not take all measures to establish more polling stations abroad, including in cities where Georgia does not have diplomatic representation, even though over 50 Georgian citizens reside in those areas;
• Compared to the previous reporting period, there was a significant increase in donations to some opposition parties after the start of the official pre-election period, bringing the financial capabilities of the election campaigns of three political subjects closer to each other. According to data from the Anti-Corruption Bureau, during the first month of the official pre-election period, from August 27 to September 26, the political union “Coalition for Change – Gvaramia Melia Girchi Droa” received 3,792,338 GEL in donations, “Georgian Dream – Democratic Georgia” received 3,327,960 GEL, and the union “Strong Georgia – Lelo, for the people, for freedom!” received 2,115,360 GEL. The sum of donations received by other political parties during the period amounted to only 344,072 GEL. This tendency is significantly different from the distribution of election campaign donations in the earlier period, which was marked by a sharp dominant advantage of the ruling party;
• Along with donations, budget financing is an additional source of income for some political parties. Based on the results of the last parliamentary elections, during the month, “Georgian Dream” received 428,335 GEL, “Unity – National Movement” received 183,302.91 GEL, “European Georgia” received 93,700.75 GEL, “Alliance of Patriots of Georgia” received 86,926.66 GEL, “Yes to Europe – Strategy Agmashenebeli” received 78,327.11 GEL, and other political parties were financed with a total of 191,319.34 GEL;
• According to the tendency observed by ISFED, in contrast to previous years, while sharing facts, individuals are now noticeably more reluctant to disclose their personal histories or identifying information.
• During the reporting period, political parties across the country conducted election campaigns, including direct engagement with voters. According to ISFED’s observers, various incidents and violations were recorded that hindered election candidates’ ability to freely conduct these campaigns. Specifically, separate cases of physical violence, disruptions to campaign events, threats and intimidation, a break-in and attempt to damage party offices, arrests of individuals affiliated with political parties, and an alleged voter bribery were documented;
• The misuse of administrative resources for electoral purposes continues to pose a significant challenge. In this regard, it is important to highlight that there were instances where employees of public institutions were mobilized and required to attend Georgian Dream – Democratic Georgia election events, including during working hours. Additionally, ruling party candidates used events funded by local self-government for campaign purposes, and campaign materials were distributed on social media under the name of municipal institutions.
• The politicization of the education system remains a significant issue for the 2024 parliamentary elections. In the pre-election period, several cases of politically motivated selection and discrimination against individuals employed in educational resource centers and public schools were observed.
• 19 political unions submitted their electoral lists to the CEC. In the context of the abolition of the mandatory gender quota, the representation of women on some registered party lists has declined. Additionally, in some instances, a significant proportion of women are placed in non-advanced positions on the list. However, it is important to note that despite the removal of the gender quota, some political unions have upheld a minimum 25% representation of women on their full lists;

During the reporting period, according to the CEC, 60 complaints were submitted to the election administration, along with 8 lawsuits filed in court. Of these, 53 complaints and 4 lawsuits were submitted by election candidates, while 7 complaints and 4 lawsuits were submitted by monitoring organizations. Among the reviewed cases, 1 lawsuit remains unreviewed, 2 complaints are still under consideration, and the rest were dismissed. ISFED submitted complaints to the Central Election Commission and relevant District Election Commissions concerning six violations of campaign rules and improper use of administrative resources during the pre-election period. Of these, five complaints were dismissed, and one is still under consideration.

Legal Framework. Promo-LEX OM highlights the lack of a clear legal framework concerning the consolidation of elections, the unique aspects of running electoral campaigns for two simultaneous elections, and the participation of unregistered entities in the campaign for one of these elections. As a result, independent candidates in the presidential elections and initiative groups find themselves at a disadvantage, as the legislation does not provide them with the same rights as political parties or electoral blocs that are registered as competitors in both elections.

Furthermore, while legal regulations have been established to penalize the involvement of religious denominations in the electoral campaign, instances of electoral agitation by their representatives have also been noted in this election. In 2016, the Constitutional Court made it clear that the participation of religious denominations in elections constitutes a violation of the Constitution.

Promo-LEX OM advises representatives of religious denominations to refrain from participating in electoral agitation activities. Additionally, the Police should thoroughly investigate and penalize instances of involvement by religious denominations in such activities.

Electoral Bodies and Public Administration During the monitoring period, the Central Electoral Commission (CEC) made 106 decisions and accredited a total of 527 observers, including 425 national and 102 international observers. At the local level, the district electoral councils (DECs) operated effectively, although there were a few exceptions. Changes to the nominal composition of members were made in three DECs, and several instances of intimidation directed at DEC officials were reported.

A specific issue arose within DEC no. 38, which was responsible for only two of the five electoral bureaus for polling stations established by CEC in the Russian Federation. Note that CEC is the sole authority that can determine the number of polling stations set up abroad in coordination with the Ministry of Foreign Affairs (MFA). Promo-LEX OM emphasizes that MFA and DEC no. 38 must adhere to legal requirements and CEC decisions to ensure timely organization of elections abroad.

Electoral Litigation. The section on electoral litigation outlines the complaints lodged with the Central Electoral Commission (CEC) and district electoral councils (DECs) concerning legal violations, including the misuse of administrative resources, donations, the involvement of minors in the campaign, and inappropriate electoral agitation. CEC adhered to the established deadlines for addressing these complaints.

A total of eight lawsuits were filed in court, addressing issues such as the exclusion of political parties from the list of eligible candidates, the establishment of polling stations, and refusals to register individuals as trusted representatives. These cases were adjudicated by the courts within a timeframe of 2 to 10 days, although the legal deadline was exceeded in two instances.

Designation and Registration of Electoral Competitors After verifying signatures, 11 candidates were registered, of whom five were independent, five supported by parties, and one by an electoral bloc. Igor Munteanu was rejected due to the lack of valid signatures. Overall, 14% of the signatures were invalidated, a lower percentage compared to the previous election. Compared to the 2020 presidential election, the total number of candidates increased, and the proportion of female candidates reached 36%.

In the constitutional referendum, 15 participants were registered, most supporting the “YES” option.  Three requests for registration as a participant were rejected on procedural grounds.

Performance of Electoral Competitors In the first ten days of the campaign, Promo-LEX observed at least 792 promotional activities by electoral competitors and for the constitutional referendum. Most of these activities were organized by PAS and Maia Sandu, followed by Alexandr Stoianoglo (PSRM) and Renato Usatîi. Chisinau hosted the highest number of events, accounting for 16%, followed by Balti and other regions. RP/PB Victory organized electoral meetings through private channels and encouraged anti-referendum and anti-EU protests by compensating participants.

Electoral advertising was identified in at least 1,404 instances, with the predominant formats being visibility materials and printed informational brochures. PAS and Maia Sandu led in the use of electoral advertising as well. Additionally, 32 instances of administrative resource abuse were reported, primarily targeting PAS and Maia Sandu (PAS). Other issues included the organized transportation of voters to electoral events, the involvement of religious groups, and acts of voter bribery.

During the monitoring period, reports emerged of goods and food being offered in exchange for voter attendance at electoral events, specifically targeting PB Victory.

Allegations of intimidation against competitors were also noted. Two representatives from PCRM were apprehended while handing out flyers advocating for the “NO” option in the referendum, which were confiscated without adequate explanations. Additionally, candidate Irina Vlah was denied access to a campaign venue by law enforcement officials.

Election and Campaign Financing. The candidates for presidential elections reported a total revenue of nearly 13 million lei during 20 and 30 September 2024, with the majority coming from political party funds. Maia Sandu, Alexandr Stoianoglo, and Renato Usatîi accounted for 89% of the total revenues reported. For the referendum, only PAS disclosed revenues, which were sourced from state budget allocations and donations.

Total reported expenditures surpassed 8.3 million lei, with 90% attributed to three candidates: Maia Sandu, Renato Usatîi, and Alexandr Stoianoglo. The largest expenses were mainly for promotional materials, as well as the production and airing of advertising spots. For the referendum, PAS reported expenditures exceeding 1.2 million lei, primarily for promotional materials and the organization of electoral activities.

Civic monitoring conducted by Promo-LEX identified inconsistencies between the estimated and declared expenses of electoral competitors. Observers calculated costs for various activities, including volunteer compensation, promotional materials, and online advertising, based on minimum market prices.

In the presidential campaign, undeclared expenses were estimated to exceed 2.2 million lei, with the majority (88%) allocated to promotional materials. Additionally, discrepancies were noted regarding the compensation of agitators, event organization, and transportation. Candidates with the highest undeclared expenses were Alexandr Stoianoglo (PSRM), Vasile Tarlev (FMP), and Irina Vlah (IC).

In the context of the constitutional referendum, undeclared expenses reached over 1.1 million lei. These expenses primarily targeted promotional materials (50%), social media advertising (23%), and other related costs. The participants in the referendum for whom these expenses were assessed included RP/PB Victory, PCRM, PAS, and MAN.

Hate Speech and Incitement to Discrimination. Between 9 and 22 September 2024, at least 14 instances of hate speech were documented, with the majority occurring in political and electoral contexts. Among these, six cases were directly linked to the elections, garnering over 134,000 views and 368 shares. Discriminatory incidents were also noted, including negative associations made between politicians and mental health issues, as well as sexist and homophobic messages.

Legal framework. The Observation Mission (OM) report highlighted an important aspect related to the participation of the incumbent President in the 20 October election. The Constitutional Court had previously emphasized that the President must be apolitical, and the nomination of Maia Sandu by PAS raised questions about her neutrality. Given the impossibility of suspending the incumbent President from office for the period of the electoral campaign, Promo-LEX OM recommends that the President should refrain from participating in official public events that could be perceived as electoral campaigning activities and should minimize the use of administrative resources during the electoral campaign.

Promo-LEX OM also raised concerns over the refusal of the Central Electoral Commission (CEC) to register some initiative groups, citing reasons such as political affiliation of candidates. Although CEC claims that political independence is a prerequisite for running as an independent candidate, the legislation does not expressly regulate such a ground for refusing registration of initiative groups. Promo-LEX recommends clarifying these issues in order to ensure transparency and predictability of the electoral process.

Electoral bodies. The electoral councils were set up within the deadline provided for by the legislation. For the majority of councils (95%), 11 members were appointed. The gender equality is uneven, with the majority of members being women (71%). According to the findings, only 17 out of 37 councils are accessible to people from vulnerable groups. Moreover, three councils (ECEC no. 36 ATUG, no. 37 – for localities on the left bank of the Dniester and no. 38 – for polling stations constituted abroad) did not have adequate premises for carrying out their activities one week after their establishment.

In total, 2,221 polling stations were set up for the autumn election, including 30 polling stations for voters from the left bank of the Dniester and 234 polling stations for voters from abroad set up by CEC in accordance with the provisions of the Electoral Code. Promo-LEX OM observers found that most polling stations (81%) were located in houses of culture and educational institutions, including pre-schools.

The organisation of polling stations abroad was carried out according to a legal framework established by the Electoral Code and CEC regulations. The main criterion for establishing polling stations is voter turnout in the last three elections, with other complementary criteria such as pre-registration and information provided by the Ministry of Foreign Affairs. A novelty in the electoral legislation for diaspora voting is the introduction of postal voting, with 1,994 citizens registered for this type of voting. CEC approved three polling stations for postal voting.

Promo-LEX has noted some differences between its estimates for the distribution of polling stations abroad and those established by CEC, in particular for Italy and the UK.

As regards the organisation of polling stations for the left bank of the Dniester, even if the number of polling stations has been reduced from 41 (2021) to 30, we believe that access to voting will generally not be affected. One issue remains the freedom to vote, as previous observation experience has shown that one of the main challenges is to counter and sanction organized transportation of voters, as well as possible cases of corruption.

Electoral disputes. During the observation period, Promo-LEX noted that at least eight complaints were submitted to the CEC, most of which were declared inadmissible. A number of complaints concerned allegations of use of administrative resources, electoral campaigning and others. Promo-LEX warns that it is necessary that the resolution of complaints should be carried out within the deadline stipulated by the Electoral Code (3 days, with the possibility of extension by 2 days) and that the complainants should be informed about the remedies available.

During the monitored period, four complaints were filed in court against CEC decisions. Three of them were rejected and in one case the court obliged CEC to issue a reasoned decision.

Nomination and registration of electoral competitors. Between 21-31 August 2024, the Central Electoral Commission received 23 applications for the registration of initiative groups (IGs) in support of 19 presidential candidates, of which 13 were accepted. Three applications were rejected and two did not receive the required number of votes.

Out of the 13 IGs to which subscription lists were issued, 9 candidates submitted their subscription lists and registration files to the CEC, out of which 4 were registered as electoral competitors. CEC received 14 applications for registration as participants in the Constitutional Referendum, registering 10 participants, out of which 8 chose YES and 2 NO.

Performance of electoral competitors. Promo-LEX observed that 12 out of 13 registered IGs carried out 475 activities to collect signatures in support of presidential candidates, with the highest activity in the case of Ion Chicu (PDCM), Renato Usatii (NP (OP)) and Maia Sandu (PAS) – who cumulatively carried out 71% of the total observed activities. No signature collection activities were observed for IG Victoria Furtună (IC).

The activities took place predominantly in Chisinau, but also in other cities (Balti, Dondușeni, Ialoveni, Causeni), and the collection period ranged from 3 to 24 days. Promo-LEX observers found that in the case of at least three candidates, signatures were collected by unauthorized persons.

In the context of the constitutional referendum, the electoral campaign seems to have started ahead of schedule, in violation of the legal provisions, with multiple promotional activities with electoral overtones, including sponsored postings and distribution of information materials. Moreover, violations were identified, such as the lack of complete information on advertising materials.

Misuse of administrative resources. Promo-LEX identified 13 cases of misuse of administrative resources by various political groups and local authorities. Among them, PAS was targeted in 8 cases related to signature collection and EU promotion, BE Împreună (EB Together) and BP Victorie (PB Victory) were involved in using educational resources and organising events serving political purposes, as well as presenting donations as being made by the party. PDCM and LPA were also cited for misuse of administrative resources in the process of collecting signatures and promoting political speeches, respectively.

Activities with voter corruption potential. During the monitored period, activities with voter corruption potential involving PB Victory and PVM (Party for Moldova’s Future) were observed. PB Victory distributed school bags and school supplies to students from socially vulnerable families and provided wheelchairs to some individuals, with reported cases of promises of money against signatures. The PVM was also involved in collecting signatures through unauthorized persons who were allegedly paid for these services.

Election and electoral campaign financing. Most of the IGs have appointed treasurers and reported the opening of the „Electoral Fund” accounts, with the exception of IGs Alexandru Arseni (IC) and Alexandr Stoianoglo (PSRM). Some IGs encountered difficulties in opening accounts thus affecting their activity. In terms of financial reporting, most of the IGs submitted information on financing, albeit with some errors, meeting deadlines. However, irregularities were found in the reporting of expenses. 12 out of 13 registered IGs reported revenues totalling 2,009,727 MDL, of which 292,076 MDL – from material donations (15% of total declared revenues).

For the signature collection activities carried out by 11 IGs, Promo-LEX estimated unreported expenses of at least 580,321 MDL. The highest unreported expenses were in the case of IG Irina Vlah (IC) – 43%, followed by IG Maia Sandu (PAS) – 23%. The most frequent unreported expenses were for promotional materials (52%).

Hate speech. Between 20 August and 8 September 2024, at least 40 cases of hate speech and other expressions of intolerance were identified. Most cases were spread via social media (19 cases) and mobile apps (10 cases). Most often, hate speech was based on political affiliation (12 cases), sexual orientation/gender identity (8 cases) and sex/gender (6 cases).

All 40 cases of hate speech had over 3 million views and more than 23 thousand shares.

Krzysztof Izdebski is a legal and political expert specializing in public administration, access to public information, and the impact of technology on democracy. He is a Member of the Board at the Stefan Batory Foundation, co-leads the Open Spending EU Coalition, and is a member of the OECD network for innovative civic participation. A recognized authority on corruption prevention and government transparency, Krzysztof has authored numerous publications on these topics. In 2020, he was named one of Poland’s 50 most influential lawyers by Dziennik Gazeta Prawna.