The various concerns raised by international actors and domestic stakeholders in their 2020 reporting, particularly those raised by OPORA, are systematically presented in the Explanatory Note as the parliament’s rationale for the draft amendments. The rationale includes:

1. the lack of a transparent procedure and of clear criteria/conditions for making a reasonable assessment of the security situation in certain territories as the basis for decisions on the impossibility of holding national and local elections;


2. the lack of guarantees and mandatory mechanisms for interagency cooperation, public consultation with local communities, and involvement of experts in the determination of the impossibility of holding elections in certain territories;


3. the potential conflict of interest between the regional civil-military administrations and their leadership, who present their conclusions on the impossibility of holding elections in certain territories, and the concerned local communities;


4. the lack of competence and technical capacity of the CEC to verify the information provided by the civil-military administrations about public safety in certain territories that forms the basis of the latter’s conclusions on the impossibility of holding elections in those areas;


5. a need to shift the level of responsible bodies from regional to national authorities.