Further to this Resolution, the then-President of the PACE, Mr Theodoros Rousopoulos, by letter of 3 April 2024, invited the Venice Commission and the Council for Democratic Elections of the Council of Europe to consider preparing a preliminary study with a view to drafting a code of conduct for electoral candidates and the media, focusing on combating hate speech from the perspective of non-discrimination, particularly in relation to narratives on migration and asylum. At its 144th meeting, held on 9-10 October 2025, the Venice Commission, on the proposal of the Council for Democratic Elections, decided to prepare a report with a focus on freedom of expression and prohibition of hate speech in a pluralist society in the light of the case law of the European Court of Human Rights (hereinafter, the ECtHR or the Court) and the standards drawn up by Council of Europe bodies, notably Committee of Ministers recommendations.