Overall assessment and context
The coming elections will be another in a series that Serbia enters without having carried out an audit of the voter register, despite the establishment of the Commission for the audit, verification and control of the accuracy and updating of the voter register and the launch of the audit process. As a result, notwithstanding the increased transparency of the voter register compared with earlier electoral cycles, one of the principal recommendations that ODIHR and domestic observers have been repeating and building on from one cycle to the next for more than ten years will not be fulfilled. The space for manipulation and unlawful handling of the voter register remains wide, and it threatens to undermine the integrity of the coming electoral process and citizens' confidence in it. Above all, not a single criminal offence connected with the voter register from previous elections has been sanctioned. On the eve of the coming elections, new information concerning the unauthorised registration of voters is shaking the public. In August 2026, CRTA Election Observation Mission documented that the Serbian Progressive Party is holding and collecting, without authorisation, the personal data of citizens of Bosnia and Herzegovina who hold Serbian citizenship, in order to register them to vote abroad outside the law and before any elections have been called.
The Unified Voter Register (UVR) remains one of the key questions of electoral integrity in Serbia and one of the principal sources of public distrust in elections. CRTA, public opinion survey, September 2024. The problem cannot, however, be reduced to the question of whether the UVR is accurate. The key question is whether there are sufficiently effective and independent mechanisms through which its accuracy, currency and integrity can be checked systematically, including checking the data against the records from which the UVR is updated.
Confidence in the UVR, already seriously damaged, was further eroded after the 2023 elections. By way of reminder, CRTA Election Observation Mission documented organised voter migration - that is, coordinated temporary changes of residence with the aim of influencing the results of local elections - as well as concentrations of voters at particular addresses and other patterns pointing to possible fictitious residence registrations. In its final report on the 2023 parliamentary elections, ODIHR likewise found that the limited possibilities for checking the UVR, the absence of detailed data on changes of residence, allegations of deceased persons remaining on the register and allegations of mass voter migration in connection with local elections had seriously undermined public confidence in the accuracy of this register. ODIHR report on the 2023 elections.
An important distinction needs to be drawn with respect to the expected snap parliamentary elections. Parliamentary elections are held under a proportional system in a single nationwide constituency, which means that moving a lawfully registered voter between municipalities does not in itself change the balance of votes at parliamentary elections. Even so, the experience of organised voter migration remains directly relevant to assessing the quality of the voter register, because it demonstrated the scope for manipulating residence data, weaknesses in the control of source records, and an insufficient institutional response to suspected abuse. A separate question is posed by new entries on the voter register of persons who acquire citizenship of the Republic of Serbia and register residence in Serbia while in fact living in one of the neighbouring countries.
It was precisely because of long-standing doubts about the quality of the UVR and the limited scope for checking it independently that a new audit mechanism was established at the end of 2025, and that the Commission for the audit, verification and control of the accuracy and updating of the voter register was formed at the beginning of 2026. Its first report, which is to show the extent to which the accuracy and integrity of the UVR can be verified, is required by law by 28 October 2026.
CRTA Election Observation Mission assesses that by that deadline a comprehensive and independently verifiable assessment of the accuracy, completeness and integrity of the voter register will not be possible, and that what can be expected instead are partial checks and findings on individual anomalies, weaknesses and risk patterns in the UVR. The key constraint is no longer access to the UVR data alone, but the possibility of systematically checking identified irregularities against the source records and linking them to the administrative procedures and information systems in which they originated. This assessment is consistent with the concern ODIHR recorded in July 2026, when its interlocutors - precisely because of impeded access to data and time lost - expressed doubt that the audit would be able to produce a comprehensive result before the elections. OSCE/ODIHR, Needs Assessment Mission Report 2026, section D, Voter Registration, pp. 10-11. https://crta.plus/sr/updates/odihrs-needs-assessment-confirms-what-crta-has-documented-and-what-citizens-already-sense/
The Unified Voter Register (UVR) remains one of the key questions of electoral integrity in Serbia and one of the principal sources of public distrust in elections. CRTA, public opinion survey, September 2024. The problem cannot, however, be reduced to the question of whether the UVR is accurate. The key question is whether there are sufficiently effective and independent mechanisms through which its accuracy, currency and integrity can be checked systematically, including checking the data against the records from which the UVR is updated.
Confidence in the UVR, already seriously damaged, was further eroded after the 2023 elections. By way of reminder, CRTA Election Observation Mission documented organised voter migration - that is, coordinated temporary changes of residence with the aim of influencing the results of local elections - as well as concentrations of voters at particular addresses and other patterns pointing to possible fictitious residence registrations. In its final report on the 2023 parliamentary elections, ODIHR likewise found that the limited possibilities for checking the UVR, the absence of detailed data on changes of residence, allegations of deceased persons remaining on the register and allegations of mass voter migration in connection with local elections had seriously undermined public confidence in the accuracy of this register. ODIHR report on the 2023 elections.
An important distinction needs to be drawn with respect to the expected snap parliamentary elections. Parliamentary elections are held under a proportional system in a single nationwide constituency, which means that moving a lawfully registered voter between municipalities does not in itself change the balance of votes at parliamentary elections. Even so, the experience of organised voter migration remains directly relevant to assessing the quality of the voter register, because it demonstrated the scope for manipulating residence data, weaknesses in the control of source records, and an insufficient institutional response to suspected abuse. A separate question is posed by new entries on the voter register of persons who acquire citizenship of the Republic of Serbia and register residence in Serbia while in fact living in one of the neighbouring countries.
It was precisely because of long-standing doubts about the quality of the UVR and the limited scope for checking it independently that a new audit mechanism was established at the end of 2025, and that the Commission for the audit, verification and control of the accuracy and updating of the voter register was formed at the beginning of 2026. Its first report, which is to show the extent to which the accuracy and integrity of the UVR can be verified, is required by law by 28 October 2026.
CRTA Election Observation Mission assesses that by that deadline a comprehensive and independently verifiable assessment of the accuracy, completeness and integrity of the voter register will not be possible, and that what can be expected instead are partial checks and findings on individual anomalies, weaknesses and risk patterns in the UVR. The key constraint is no longer access to the UVR data alone, but the possibility of systematically checking identified irregularities against the source records and linking them to the administrative procedures and information systems in which they originated. This assessment is consistent with the concern ODIHR recorded in July 2026, when its interlocutors - precisely because of impeded access to data and time lost - expressed doubt that the audit would be able to produce a comprehensive result before the elections. OSCE/ODIHR, Needs Assessment Mission Report 2026, section D, Voter Registration, pp. 10-11. https://crta.plus/sr/updates/odihrs-needs-assessment-confirms-what-crta-has-documented-and-what-citizens-already-sense/
ODIHR's long-standing recommendations
The question of auditing the voter register is not new. For several electoral cycles now ODIHR has repeated recommendations aimed at checking its accuracy and increasing transparency. In its final report on the 2022 presidential and parliamentary elections, ODIHR set out as its third priority recommendation that a full audit of the UVR and of the civil registry be carried out, with the participation of political parties and civil society.
2022: ODIHR, Republic of Serbia, Presidential and Early Parliamentary Elections, 3 April 2022, ODIHR Election Observation Mission Final Report, Warsaw, 19 August 2022, p. 32, Priority Recommendation 3.
After the 2023 elections ODIHR refined the recommendation further, calling for a review of laws, regulations and practices in order to enable access to the data necessary for a meaningful audit of the UVR, with the participation of relevant stakeholders and in compliance with personal data protection standards.
2023: ODIHR, Republic of Serbia, Early Parliamentary Elections, 17 December 2023, ODIHR Election Observation Mission Final Report, Warsaw, 28 February 2024, p. 11, Priority Recommendation 4.
Following the 2024 local elections, ODIHR called for: a full audit of the UVR and of the civil registry by independent experts, with the participation of the competent ministries, political parties and civil society; and the publication of sufficiently detailed voter data to make a genuine check of the accuracy of voter numbers possible.
2024: ODIHR, Republic of Serbia, Local Elections, 2 June 2024, ODIHR Election Observation Mission Final Report, Warsaw, 30 August 2024, pp. 10-11 and Priority Recommendations 3-4.
The common denominator of these recommendations is not merely the removal of individual errors from the register. ODIHR consistently links the accuracy of the register, the possibility of independent scrutiny, and public confidence.
Reform of the Law on the Unified Voter Register and the formation of the Commission
The amendments to the Law on the Unified Voter Register, adopted in November 2025, established the Commission for the audit, verification and control of the accuracy and updating of the voter register.
Law on Amendments to the Law on the Unified Voter Register, Official Gazette of the RS, no. 96/2025, in particular Articles 14, 22j-22l and Article 8 of the transitional provisions.
The rights of the public and of observers to access data were also expanded and additional transparency mechanisms were introduced.
The National Assembly appointed the Commission's first membership on 28 January 2026. National Assembly of the Republic of Serbia, Decision on the appointment of members and deputy members of the Commission for the audit, verification and control of the accuracy and updating of the voter register, 28 January 2026, Official Gazette of the RS, no. 8/2[...] The Commission began work during February, and is required to submit its first audit report to the National Assembly by 28 October 2026. The Commission is empowered to analyse data from the UVR and from other records relevant to its maintenance, to check updating processes and the legal grounds for changes, to analyse the functioning of the information system, and to initiate field checks.
The first two months of its work were needed for the accelerated constitution of the Commission and the adoption of its rules of procedure, plan and methodology, leaving around seven months for the audit itself. Four of the remaining seven months, however, were spent on efforts to secure access to basic voter data and to the history of changes in the UVR. Broader access to those data was granted at the beginning of July, after several months of talks between the Commission and the competent institutions, while establishing the technical conditions to process them required additional time.
This enabled the Commission to carry out considerably more serious analysis of the UVR itself, including statistical analysis, checks on data quality and internal consistency, and the identification of possible duplicates, unusual concentrations of voters and other patterns requiring further checking. The possibility of systematically checking such findings against the records from which the UVR is updated nonetheless remains significantly constrained. CRTA Plus, "ODIHR Needs Assessment Confirms What CRTA Has Documented".
Beyond the framework of the voter register data, the Commission was also granted a limited service for checking the data of individual voters against the civil registry, the citizenship records and the residence records. That access is, however, designed only for checking a specified individual, not for a systemic audit of the voter register, which makes any more comprehensive check of suspicious cases or patterns identified in the UVR particularly difficult.
The range of available data is also limited. In the case of residence, for example, the currently registered residence can be checked, but not the history of previous residences. In the case of citizenship, the check is largely reduced to whether a given personal identification number appears in the records, without the data needed to analyse the timing and legal basis of the acquisition of citizenship, the date of entry, any second citizenship, or the procedure and the authority that handled the case. In addition, every check is performed individually and requires a separate access procedure, which makes mass verification of large numbers of voters extremely slow.
A model of this kind allows selected individual cases to be checked, but does not allow the UVR to be cross-checked systemically against the source records. Consequently, the Commission is increasingly able to establish where anomalies or patterns requiring checking exist, while its scope for establishing how they arose - whether they result from administrative error, outdated data, weaknesses in the system or possible abuse - and who is responsible for them, is significantly constrained.
A further constraint is the absence of a full IT and information-security audit of the UVR system and of the systems that supply it with data. Without such a check it is not possible to assess independently whether access controls, user activity logs, database changes and other technical mechanisms allow a reliable reconstruction of all significant changes to voter data.
For that reason, as matters stood at the beginning of September, the Commission's first report can be expected to cover a range of useful partial audits and diagnostic findings, but not a comprehensive verification of the accuracy, completeness and integrity of the UVR as a whole. A significant part of the time allotted for the audit was spent securing the basic conditions for the work, while the remaining constraints on access to the source records and to the information system are being addressed in a period in which snap elections are simultaneously expected to be called. Without a rapid improvement in the conditions for the Commission's work, the risk remains that the audit process before the elections will neither answer the substance of ODIHR's long-standing recommendations nor dispel the long-standing public distrust of the voter register.
The National Assembly appointed the Commission's first membership on 28 January 2026. National Assembly of the Republic of Serbia, Decision on the appointment of members and deputy members of the Commission for the audit, verification and control of the accuracy and updating of the voter register, 28 January 2026, Official Gazette of the RS, no. 8/2[...] The Commission began work during February, and is required to submit its first audit report to the National Assembly by 28 October 2026. The Commission is empowered to analyse data from the UVR and from other records relevant to its maintenance, to check updating processes and the legal grounds for changes, to analyse the functioning of the information system, and to initiate field checks.
The first two months of its work were needed for the accelerated constitution of the Commission and the adoption of its rules of procedure, plan and methodology, leaving around seven months for the audit itself. Four of the remaining seven months, however, were spent on efforts to secure access to basic voter data and to the history of changes in the UVR. Broader access to those data was granted at the beginning of July, after several months of talks between the Commission and the competent institutions, while establishing the technical conditions to process them required additional time.
This enabled the Commission to carry out considerably more serious analysis of the UVR itself, including statistical analysis, checks on data quality and internal consistency, and the identification of possible duplicates, unusual concentrations of voters and other patterns requiring further checking. The possibility of systematically checking such findings against the records from which the UVR is updated nonetheless remains significantly constrained. CRTA Plus, "ODIHR Needs Assessment Confirms What CRTA Has Documented".
Beyond the framework of the voter register data, the Commission was also granted a limited service for checking the data of individual voters against the civil registry, the citizenship records and the residence records. That access is, however, designed only for checking a specified individual, not for a systemic audit of the voter register, which makes any more comprehensive check of suspicious cases or patterns identified in the UVR particularly difficult.
The range of available data is also limited. In the case of residence, for example, the currently registered residence can be checked, but not the history of previous residences. In the case of citizenship, the check is largely reduced to whether a given personal identification number appears in the records, without the data needed to analyse the timing and legal basis of the acquisition of citizenship, the date of entry, any second citizenship, or the procedure and the authority that handled the case. In addition, every check is performed individually and requires a separate access procedure, which makes mass verification of large numbers of voters extremely slow.
A model of this kind allows selected individual cases to be checked, but does not allow the UVR to be cross-checked systemically against the source records. Consequently, the Commission is increasingly able to establish where anomalies or patterns requiring checking exist, while its scope for establishing how they arose - whether they result from administrative error, outdated data, weaknesses in the system or possible abuse - and who is responsible for them, is significantly constrained.
A further constraint is the absence of a full IT and information-security audit of the UVR system and of the systems that supply it with data. Without such a check it is not possible to assess independently whether access controls, user activity logs, database changes and other technical mechanisms allow a reliable reconstruction of all significant changes to voter data.
For that reason, as matters stood at the beginning of September, the Commission's first report can be expected to cover a range of useful partial audits and diagnostic findings, but not a comprehensive verification of the accuracy, completeness and integrity of the UVR as a whole. A significant part of the time allotted for the audit was spent securing the basic conditions for the work, while the remaining constraints on access to the source records and to the information system are being addressed in a period in which snap elections are simultaneously expected to be called. Without a rapid improvement in the conditions for the Commission's work, the risk remains that the audit process before the elections will neither answer the substance of ODIHR's long-standing recommendations nor dispel the long-standing public distrust of the voter register.
Transparency of the voter register.
The 2025 amendments to the Law brought progress in the transparency of the UVR. The Ministry of Public Administration and Local Self-Government now publishes voters' names by polling station, data on the number of changes and their legal grounds, and data on the number of voters per address, that is, per household. Data on voters by polling station have been published since February 2026, and since 15 May a service has been available for viewing the number of voters per household or address. Checking at household level nonetheless remains limited: a flat number exists for only around 2 per cent of addresses in the UVR. In most cases the service shows the total number of voters at an address rather than the number of voters in a specific flat, which makes checking particularly difficult in multi-dwelling buildings. The amendments also expanded data access for accredited domestic observers.
Indications of abuse of the law in registering voters to vote in Bosnia and Herzegovina
During the last week of August and the beginning of September 2026, indications emerged of the organised collection of the personal data of Serbian citizens in Bosnia and Herzegovina in order to register them to vote abroad, even though elections had not yet been called. On 26 August CRTA published an audio recording of a conversation in which a woman, presenting herself as a representative of the "SNS branch office" in Banja Luka, offers to have a "mobile team" come to a citizen with dual citizenship and scan his Serbian identity card in order to register him to vote.
A second case, the recording of which was published on 2 September, points to a similar pattern in Višegrad: a woman who presents herself as "Verica from Novo Goražde" and says she works on dual citizenship matters states that she has been scanning Serbian identity cards in the field for more than a month, that more than 1,000 people have been covered in this way, that voting will take place in Višegrad, and that elections are expected at the end of October. Undocumented reports also reached observers of cases in which people presenting themselves as officials of the Diplomatic and Consular Mission of the Republic of Serbia in Banja Luka came to citizens' addresses on the same errand. The repetition of the same mechanism in different places, the involvement of people presenting themselves as party activists or officials, and the fact that they already hold contact details and information on dual citizenship, telephone numbers and other personal data, point to the possibility of a broader, coordinated voter mobilisation operation involving misuse of office and of public resources, unlawful processing of personal data and access to official records, and breaches of the procedures for registering voters to vote by place of temporary residence abroad. The significance of the case is all the greater because an application to vote abroad is submitted only after the elections have been called, through a diplomatic and consular mission, and must bear the applicant's own signature - while CRTA had already, after the 2023 elections, filed criminal complaints concerning cases in which citizens maintained that they had been registered to vote in Banja Luka without their knowledge. Those criminal complaints have to this day produced no outcome whatsoever.
A second case, the recording of which was published on 2 September, points to a similar pattern in Višegrad: a woman who presents herself as "Verica from Novo Goražde" and says she works on dual citizenship matters states that she has been scanning Serbian identity cards in the field for more than a month, that more than 1,000 people have been covered in this way, that voting will take place in Višegrad, and that elections are expected at the end of October. Undocumented reports also reached observers of cases in which people presenting themselves as officials of the Diplomatic and Consular Mission of the Republic of Serbia in Banja Luka came to citizens' addresses on the same errand. The repetition of the same mechanism in different places, the involvement of people presenting themselves as party activists or officials, and the fact that they already hold contact details and information on dual citizenship, telephone numbers and other personal data, point to the possibility of a broader, coordinated voter mobilisation operation involving misuse of office and of public resources, unlawful processing of personal data and access to official records, and breaches of the procedures for registering voters to vote by place of temporary residence abroad. The significance of the case is all the greater because an application to vote abroad is submitted only after the elections have been called, through a diplomatic and consular mission, and must bear the applicant's own signature - while CRTA had already, after the 2023 elections, filed criminal complaints concerning cases in which citizens maintained that they had been registered to vote in Banja Luka without their knowledge. Those criminal complaints have to this day produced no outcome whatsoever.
The voter register as a public issue
Between March and the beginning of September 2026, 97 citizens contacted CRTA to share information about possible irregularities in the voter register. Citizens submitted 82 reports directly, while 15 cases were identified in public posts on social media. Most commonly they concerned suspicions of illegitimately registered persons and unknown voters recorded at particular addresses. Some of the reports were forwarded to the Commission for the audit of the voter register.
Over the same period, the voter register remained a visible but markedly politicised media topic. Heavier media coverage was recorded around the formation of the Commission, the holding of local elections in March, the public dispute over access to data in May, and the debate about new citizens and their residences during July and August. Continuous coverage of the audit itself, of its methodology and of its concrete results was considerably rarer.
Media narratives were strongly polarised. Media that predominantly conveyed the position of representatives of the authorities emphasised the increased transparency of the UVR and claims that the Commission has full access to the data, while critical media devoted more attention to the constraints on access, to possible irregularities and to "phantom voters". CRTA's qualitative analysis of publicly available online media reporting on the UVR, February-August 2026, purposive sample. The analysis covered output of the public broadcaster, national and cable television, the daily press and news [...]
At the same time, during the first half of 2026 the question of the voter register was observed to have lost some of its earlier priority in the public messaging of EU officials as well. At the end of 2025 the adoption of the Law on the UVR was singled out as an important step towards free and fair elections, European Commission, Serbia Report 2025, Elections section, p. 22. whereas from the end of January 2026 European assessments of Serbia were dominated by the crisis caused by the adoption of five judicial laws without a transparent and inclusive procedure. The European Commission assessed these as a serious step backwards, and during April and May the question of their revision was linked even to the possible suspension of European funding. Venice Commission, Urgent Opinion on the 28 January 2026 Amendments to Laws Governing the Judiciary and the Prosecution, CDL-PI(2026)007, 24 April 2026. When the contested provisions were corrected in June, Commissioner Marta Kos welcomed this as "an important step in the right direction" contributing to the restoration of confidence. Marta Kos, statement following the revision of the judicial legislation, 26 June 2026. Electoral reform then reappears among the EU's subsequent demands, but largely within the broader framework of implementing ODIHR's recommendations, rather than through particular attention to the Commission's work and to the actual progress of the UVR audit.
In July too the EU welcomed the "positive steps" concerning the voter register and repeated its call for the remaining ODIHR recommendations to be implemented. European Union, EU Statement in Response to the Head of the OSCE Mission to Serbia, EEAS, August 2026. A comparison of public messaging nonetheless shows that over this period the specific question of the quality and audit of the UVR became less prominent than the broader questions of the judiciary, the media and overall democratic backsliding - despite the fact that the audit of the voter register has not yet produced results on the basis of which its accuracy and integrity could be confirmed.
Over the same period, the voter register remained a visible but markedly politicised media topic. Heavier media coverage was recorded around the formation of the Commission, the holding of local elections in March, the public dispute over access to data in May, and the debate about new citizens and their residences during July and August. Continuous coverage of the audit itself, of its methodology and of its concrete results was considerably rarer.
Media narratives were strongly polarised. Media that predominantly conveyed the position of representatives of the authorities emphasised the increased transparency of the UVR and claims that the Commission has full access to the data, while critical media devoted more attention to the constraints on access, to possible irregularities and to "phantom voters". CRTA's qualitative analysis of publicly available online media reporting on the UVR, February-August 2026, purposive sample. The analysis covered output of the public broadcaster, national and cable television, the daily press and news [...]
At the same time, during the first half of 2026 the question of the voter register was observed to have lost some of its earlier priority in the public messaging of EU officials as well. At the end of 2025 the adoption of the Law on the UVR was singled out as an important step towards free and fair elections, European Commission, Serbia Report 2025, Elections section, p. 22. whereas from the end of January 2026 European assessments of Serbia were dominated by the crisis caused by the adoption of five judicial laws without a transparent and inclusive procedure. The European Commission assessed these as a serious step backwards, and during April and May the question of their revision was linked even to the possible suspension of European funding. Venice Commission, Urgent Opinion on the 28 January 2026 Amendments to Laws Governing the Judiciary and the Prosecution, CDL-PI(2026)007, 24 April 2026. When the contested provisions were corrected in June, Commissioner Marta Kos welcomed this as "an important step in the right direction" contributing to the restoration of confidence. Marta Kos, statement following the revision of the judicial legislation, 26 June 2026. Electoral reform then reappears among the EU's subsequent demands, but largely within the broader framework of implementing ODIHR's recommendations, rather than through particular attention to the Commission's work and to the actual progress of the UVR audit.
In July too the EU welcomed the "positive steps" concerning the voter register and repeated its call for the remaining ODIHR recommendations to be implemented. European Union, EU Statement in Response to the Head of the OSCE Mission to Serbia, EEAS, August 2026. A comparison of public messaging nonetheless shows that over this period the specific question of the quality and audit of the UVR became less prominent than the broader questions of the judiciary, the media and overall democratic backsliding - despite the fact that the audit of the voter register has not yet produced results on the basis of which its accuracy and integrity could be confirmed.
