The draft Code applies a rather restrictive approach toward actors participating in a referendum campaign. The definition of referendum participants does not extend beyond political parties and blocs and, in the case of a recall referendum, the President or a mayor. The right of initiative groups to conduct campaigns is not prescribed in Chapter VIII. Furthermore, participation of civic groups or civil society organisations in favour of or against the proposal is not in any way regulated. The ODIHR and Venice Commission recommend granting the status of a referendum campaign participant to a more exhaustive list of possible actors, including civic groups and organisations supporting or opposing the issue put to a referendum or otherwise enabling their participation in a referendum campaign.