Among other grounds for removal, Article 32.2 provides for the removal of CEAZ members and the secretary when the proposing electoral subject requests their substitution. This unrestricted right of electoral subjects extends to the removal of VCC members even on election day (Article 39.2). These provisions have repeatedly been criticised by OSCE/ODIHR and the Venice Commission as undermining the independence and efficiency of the election administration and as being incompatible with international and European standards.¹⁴ During the 2011 local elections, electoral subjects used this provision extensively.