It should be noted that a long-standing ODIHR recommendation, reiterated in the April 2021 Joint Opinion, to stipulate in the legislation clear and objective grounds on which recounts and annulments can be requested by electoral stakeholders and the grounds under which they must be granted has not been addressed by the draft law.49 This represents a significant gap in the election legislation. In addition, based on observations of shortcomings in the automatic recount process during the 2021 local elections, ODIHR recommended to establish clear and comprehensive criteria for the conduct of recounts. This recommendation remains to be implemented. Some interlocutors also raised this concern, noting that the law should explicitly provide those recounts follow the same procedural steps as the initial counts.