In order to further improve the compliance of the draft Law with international obligations, human rights standards and OSCE commitments, ODIHR and the Venice Commission make the following key recommendations:

A. Restrictions on freedom of expression should be drafted and interpreted in conformity with constitutional and international human rights law; in particular:
1. Prohibitions on participation in campaigning (“electioneering”) by non-government, trade unions, charity organisations, as well as during processions and/or religious services, as well as by media, including private ones, if they are maintained, should be reworded to give them a narrower application;
2. Provisions on hate speech and incitement to discrimination should be reworded in order to avoid overly broad application.
B. The provisions on (misuse of) administrative resources should be further refined, including introducing an effective enforcement mechanism to prevent these violations;
C. Draft amendments need to be re-considered to continue allowing observers to observe all stages of the electoral process;
D. Sanctions should respect the principles of proportionality and equality, in particular those related to election observers and the media and be subject to effective judicial review.