In its 2019 report concerning the inclusion of a not internationally recognised territory into a nationwide constituency, the Venice Commission recalled that “the right to participate in universal, free and fair elections is also one of the most important political human rights, which is enshrined in all major human rights instruments”.  At the same time, the Venice Commission recalled that the right to elections was “not an absolute right.Although Article 3 of Protocol 1 does not contain an express limitation clause, the ECtHR has repeatedly held that there is room for ‘implied limitations’. Generally speaking, all ‘implied’ limitations to the fundamental right to participate actively or passively (by voting or standing as a candidate) in elections must satisfy a three-prong test: The measure must pursue a legitimate objective, it must not be disproportionate, and it may not impair the essence of the right. The Court also made clear that any interference with the right to vote: a) must meet the criteria of non-arbitrariness and proportionality; and b) must not interfere with the free expression of the opinion of the people.”