II. Comments on the test of the law

C. Some specific comments on the concrete articles on the new law on referendum.

7. Participation on non-citizens in the referendum process.

The Law adopts a quite restrictive approach as to participation of non-citizens in the referendum process. An absolute prohibition for foreigners and stateless persons and entities to participate in any of the aspects of the referendum process is questionable. Such restriction might be logical with regard to participation in the initiative group (limited to Ukrainian citizens); but it seems excessive when referred even to economic contributions (64.3.1) or acts of campaigning, including “involvement in journalist activities or participation in concerts, exhibitions, sports events and other public events organized during the referendum process” (Article 76.1.1), up to the point of foreseeing the suspension of broadcasting national or international channels (Article 76.10).