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REPORT NO. 4 | Promo-LEX presented Report no. 3 of the Observation Mission for the Parliamentary Elections of 28 September

The Promo-LEX Association has presented today Report no. 4 of the Observation Mission for the parliamentary elections of 28 September, covering the period from 11 September to 24 September 2025. The report contains observations and findings regarding the end of the electoral campaign, the behaviour of competitors, and the transparency of campaign financing.

Summary

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.

The full report is available in Romanian here.

The Mission is financially supported by Sweden, the Government of the United Kingdom of Great Britain and Northern Ireland, the European Union, the French Embassy, and the Council of Europe, under the aegis of the Civic Coalition for Free and Fair Elections.

The opinions expressed in the public press releases of the Promo-LEX OM belong to the authors and do not necessarily reflect the point of view of financiers or partners. The content hereof may be subject to editorial revisions.

For more information:
Dumitrița Ciuvaga
Communication Officer
Promo-LEX Association
Tel: +373 68 800 827

(September 29, 2025)
Moldova

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