Article 3 of Protocol 1 to the ECHR relating to the right to free elections provides that “[t]he High Contracting Parties undertake to hold free elections at reasonable intervals by secret ballot, under conditions which will ensure the free expression of the opinion of the people in the choice of the legislature.” As far as Council of Europe members are concerned, Article 3 of Protocol 1 provides only for a right to participate in elections to the “legislature. Nor does it entail, even impliedly, a right for the population to be represented in an international organisation. The right to participate in elections is 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. Importantly, the Court also emphasised that any state measure in the context of democratic elections “must reflect, or not run counter to, the concern to maintain the integrity and effectiveness of an electoral procedure aimed at identifying the will of the people through universal suffrage“.