The draft Code, among other provisions on liability, stipulates in Article 102 that if an observer violates the electoral regulatory framework, the electoral body that accredited the observer has the right to cancel the accreditation. According to Article 102, any propaganda action for or against a political party, other socio-political organisation or electoral competitor, initiative group, a participant in the referendum, referendum options or attempt to influence the voter’s option shall be qualified as violations. This provision is overreaching and could be contrary to the principles of freedom of expression unless it is meant to apply to the behaviour of election observers while observing. Namely, domestic electoral observers, as citizens, must have a status compatible with the status of being a voter, and the legal framework for elections should not put citizens at a disadvantage for expressing a political opinion, participating in campaign events, and discussing contestants and their platforms etc., outside of the duties of observers. In this regard, it is advisable to review this provision in order to apply sanctions for abusing the status of an observer (campaigning while observing, etc.). It is also recommended to apply gradual sanctions also to domestic observers and start with a warning rather than opt directly for revoking accreditation.