Articles 32.1, 33.2 and 94.1 of the Draft law strictly prohibit campaigning by the initiative group, political parties and civil society organisations (CSOs) prior to their registration, setting up a campaign fund, and/or calling of the referendum. While campaigning entities can be required by law to set up and utilize campaign accounts as part of the framework for campaign finance reporting, broad bans on campaigning are not justifiable. Paragraph 24 of 1990 OSCE Copenhagen Document provides that: “The participating States will ensure that the exercise of all the human rights and fundamental freedoms set out above will not be subject to any restrictions except those which are provided by law and are consistent with their obligations under international law, in particular the International Covenant on Civil and Political Rights, and with their international commitments, in particular the Universal Declaration of Human Rights. These restrictions have the character of exceptions. The participating States will ensure that these restrictions are not abused and are not applied in an arbitrary manner, but in such a way that the effective exercise of these rights is ensured. Any restriction on rights and freedoms must, in a democratic society, relate to one of the objectives of the applicable law and be strictly proportionate to the aim of that law.” These bans on campaigning should therefore be removed from the Draft law.