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The amendments to the Law on Financing of Political Activities (LFPA) were submitted to parliamentary procedure by MP Petrašinović - not by the government - as part of the reform of the electoral laws to implement ODIHR's recommendations. CRTA's analysis covers two versions of the text: the first draft (10 March 2026), on which ODIHR commented on 11 May 2026, and the revised draft (19 May 2026) that followed. The revised draft is now before parliament, where public hearings are scheduled; it was also sent to ODIHR, but that opinion has not yet been published. According to ODIHR, the draft addresses seven of its recommendations.
(Note: the Law on the Prevention of Corruption is a separate draft, prepared by the Agency for the Prevention of Corruption; its status is unknown and it is not covered here.)
CRTA assesses that, more than in past practice, the Draft incorporates ODIHR's recommendations and introduces genuine improvements in the transparency of political financing, the control of campaign costs, and the clarification of the Agency's procedures. Particularly significant are the new rules on third-party campaign financing, the reduced campaign-spending limits, and the limits on borrowing through loans and credits.
Nevertheless, the analysis shows that some recommendations are met only formally. Certain solutions remain insufficiently precise and leave room to circumvent the law or divert activity into a grey zone. The proposed changes are also unlikely to significantly affect large parties with stable public funding, while some restrictions could disproportionately burden smaller and extra-parliamentary entities, especially at the local level. ODIHR also stresses that any reform should be initiated in good time, through an inclusive consultative process based on broad political consensus and the participation of civil society - which has not been the case.
(Note: the Law on the Prevention of Corruption is a separate draft, prepared by the Agency for the Prevention of Corruption; its status is unknown and it is not covered here.)
CRTA assesses that, more than in past practice, the Draft incorporates ODIHR's recommendations and introduces genuine improvements in the transparency of political financing, the control of campaign costs, and the clarification of the Agency's procedures. Particularly significant are the new rules on third-party campaign financing, the reduced campaign-spending limits, and the limits on borrowing through loans and credits.
Nevertheless, the analysis shows that some recommendations are met only formally. Certain solutions remain insufficiently precise and leave room to circumvent the law or divert activity into a grey zone. The proposed changes are also unlikely to significantly affect large parties with stable public funding, while some restrictions could disproportionately burden smaller and extra-parliamentary entities, especially at the local level. ODIHR also stresses that any reform should be initiated in good time, through an inclusive consultative process based on broad political consensus and the participation of civil society - which has not been the case.
Key changes
For each proposal, the comparison shows what the draft does, what ODIHR said, and where CRTA stands - across both draft versions.
CRTA brief · political finance
Two drafts compared, article by article
For each proposal: what the draft does, what ODIHR said, and where CRTA stands - across the first draft (10 March 2026) and the revised draft (19 May 2026).
What the draft does
ODIHR
CRTA's view
First draft · 10 Mar 2026
What the draft does
Caps borrowing at 25% of the annual funds from the state budget, for both regular work and campaign costs. Campaign loans must be repaid by the final-report deadline; regular-work loans keep a three-year term.
ODIHR
No specific recommendation, but the 2020 ODIHR-Venice Commission guidelines call for transparency rules to cover loans and debts. ODIHR's opinion: tie the 25% to the funding of the year the loan is signed, explicitly bar regular-work loans from campaigns, and consider shortening the three-year term.
CRTA's view
The provisions leave room for ambiguity and abuse: the 25% cap is too high, the conditions for campaign borrowing are imprecise, and regular-work funds can indirectly finance campaigns. Loans should be purpose-bound to specific activities, and the percentage replaced with "average monthly salaries".
Revised draft · 19 May 2026
What the draft does
Follows ODIHR: the 25% is now calculated on the funding of the year the loan is signed, the regular-work repayment term is cut from three to two years, and using regular-work loans for the campaign is prohibited.
ODIHR
No further opinion.
CRTA's view
Summary: 25% of annual public funding is still too high, and it is not clear enough that borrowed funds cannot serve both campaign and regular work - so an entity could hypothetically take several maximum loans.
Explanation: the conjunction "or" leaves it unclear whether an entity may borrow for both purposes in one year, and whether it may borrow several times where multiple elections fall in a year. Each loan agreement should be purpose-bound, and it remains to be seen how the Agency will separate loan funds from other money once they reach the regular-work account.
First draft · 10 Mar 2026
What the draft does
Public bodies regulate the provision of services and goods to political entities by a special act, published online within eight days. They must answer a request within five days, or two working days during the campaign, and provide evidence where they cannot comply.
ODIHR
Recommendation 13 (2023): ensure all contestants can access and use public spaces on equal terms. Opinion: introduce general access criteria, clarify whether goods are free or charged at market value, set a deadline for the by-laws, and publish individual allocation decisions.
CRTA's view
The article could go further: specify that goods may be free but not above market value, and explicitly prohibit providing them without a published special act, since clear, non-discriminatory rules are currently missing.
Revised draft · 19 May 2026
What the draft does
Follows ODIHR: services and goods are provided on equal terms whether free or charged; individual allocation decisions are published on the provider's website; use is regulated by a special act, to be adopted within 60 days of the law entering force.
ODIHR
No further opinion.
CRTA's view
Summary: the recommendations are met. Equal terms for all entities and publication of every allocation decision are good solutions; institutions must adopt internal rules within 60 days. The full effect in practice remains to be seen.
Explanation: as the recommendation is fully followed and a misdemeanour is prescribed for breach, the solution can remove past obstacles, though a full assessment is only possible after the next elections. The role of the MPALSG contact centre remains unclear.
First draft · 10 Mar 2026
What the draft does
Cuts the maximum annual contribution a single legal person may give for regular work from 30 to 10 average monthly salaries.
ODIHR
Recommendations 15 (2012) and 18 (2020): lower the ceilings for private contributions. Opinion: consider an aggregate donation threshold to stop fragmentation across related entities, publish beneficial ownership, and lower thresholds for natural persons and during election years.
CRTA's view
The cut is a positive step, but "related legal persons" must be precisely defined, and situations where a person donates both personally and through companies they own must be clearly regulated to prevent circumvention.
Revised draft · 19 May 2026
What the draft does
Follows ODIHR: cuts contributions by natural persons to five average monthly salaries, introduces "related companies" and a limit on their donations, bars the same person from giving both personally and through a company they own, and halves campaign donations where a regular-work contribution was already made that year.
ODIHR
No further opinion.
CRTA's view
Summary: the changes largely follow ODIHR and remove key past weaknesses, but a full assessment is only possible after the next elections.
Concern: lower limits on contributions by natural persons may disproportionately hit extra-parliamentary and new actors, who have no public funds and rely on citizens' donations. It will be important to watch whether the changes preserve equal competition, not just prevent abuse.
First draft · 10 Mar 2026
What the draft does
Exempts parties and citizen groups not represented in the National Assembly, provincial or local assemblies from posting an election guarantee, and elaborates the rules on using the first portion of public funds and returning them if the result is not met.
ODIHR
Recommendation 15 (2023): consider abolishing the guarantee requirement for non-represented entities. Opinion: define clearly which entities qualify and the time frame for assessing representation, to avoid uncertainty and abuse.
CRTA's view
Partially fulfils the recommendation, but the guarantee rules remain complex and risk unequal treatment and "phantom" citizen groups. CRTA proposes redefining the guarantee through an alternative early-payment mechanism.
Revised draft · 19 May 2026
What the draft does
Entities that do not submit a preliminary report will not receive the second portion of public funds, and extra-parliamentary entities are not obliged to post a guarantee.
ODIHR
No further opinion.
CRTA's view
Summary: withholding the second portion from non-reporting entities is a good solution, but ODIHR's opinion was not followed - the conditions and time frame for the first portion without a guarantee are still not defined precisely.
Explanation: the risk of abuse through "phantom" citizen groups remains. The guarantee rules are complex and should be further specified or redefined through an alternative early-payment mechanism.
First draft · 10 Mar 2026
What the draft does
Bans business cooperation between entities and companies without a prior service agreement, prohibiting a company from promoting an entity on its premises, at its gatherings or through its communications. Media founders' public-information work is exempt. Entities may not repost third-party promotional activity on their sites and social media during the campaign.
ODIHR
Recommendation 16 (2023): close gaps and clearly regulate third-party campaigns; the Agency should proactively sanction unauthorised spending. Opinion: improve coherence, better linking the ban on reposting third-party content with other provisions on unlawful campaign activity.
CRTA's view
The term "company" is not aligned with the law and should also cover associations and sole traders. Part of paragraph 1 is vague and leaves the scope of the ban unclear. Paragraph 3 belongs in Article 23, though it does improve the framework.
Revised draft · 19 May 2026
What the draft does
The provision was not changed relative to the first draft.
ODIHR
No further opinion.
CRTA's view
CRTA's first-draft comment stands.
First draft · 10 Mar 2026
What the draft does
Regulates third-party campaigns: a paid activity above one average monthly salary, by an entity unconnected to a political entity, aimed at influencing the campaign. Bans state and state-owned bodies and foreign persons; caps third-party spending at 10 average salaries; exempts views on matters of public interest by NGOs, religious bodies, media or individuals. Requires a dedicated account, notice to the Agency, and reporting.
ODIHR
Recommendation 16 (2023). Opinion: define third parties and their activities more precisely, consider lowering the threshold, cover in-kind giving, clarify "non-connection", formulate the cap as a total, protect free expression by defining "public interest", route all funds through registered accounts, specify reporting periods, and extend oversight to all third parties.
CRTA's view
The article is normatively inconsistent and imprecise - the recommendation looks formally implemented but unaligned with the legal system. "Third parties" and the banned circle are not clearly defined. The public-interest exemption must be defined narrowly so the whole activity is not subsumed under free speech and escapes control. Agency records should be public and regularly updated.
Revised draft · 19 May 2026
What the draft does
Defines who counts as a third party (natural, legal and other persons); registration with the Agency is required above 50% of an average monthly salary; lists third-party activities; broadens the prohibitions; and caps third-party financing at 10 average monthly salaries.
ODIHR
No further opinion.
CRTA's view
Summary: a significant improvement, but it is unclear how far third parties will register, and the public-interest issue persists - the whole activity could be subsumed under free expression and escape control.
Explanation: the provisions should be further clarified and the preliminary third-party report (a good transparency feature, since dropped) restored. A broad public discussion is needed, and a careful balance struck between free speech and third-party campaigns.
First draft · 10 Mar 2026
What the draft does
Introduces campaign-spending limits for the various elections, set in euros - following an ODIHR recommendation repeated since 2016.
ODIHR
Recommendation 16 (2022): introduce spending limits and safeguards against misuse of public funds. Opinion: express limits as a number of average salaries, explicitly sanction overspending, lower the limits further, and clarify rules for simultaneous elections.
CRTA's view
Welcomes the limits but finds them set quite high; sanctions for overspending should be tightened without breaching ne bis in idem; "XY average monthly salaries" is the better way to express the amount; care is needed so entities do not slip into the grey zone.
Revised draft · 19 May 2026
What the draft does
Cuts the limits: presidential and parliamentary from EUR 8m to 6m, provincial from EUR 2m to 1.5m, two-round presidential from EUR 10m to 7m. Other provisions unchanged.
ODIHR
No further opinion.
CRTA's view
Summary: the cuts follow ODIHR, but sanctions for overspending still need work (only misdemeanour liability), and limits should be expressed in average salaries rather than euros.
Explanation: the level of the limits should still be reconsidered to balance real costs against costs that could spill into the grey zone of financing.
First draft · 10 Mar 2026
What the draft does
Removes the obligation to publish the Annual Financing Report (AFR) for entities lacking funds and expertise to lease a web domain; requires AFRs to be complete and accurate; adds electronic submission alongside written.
ODIHR
Opinion: oblige all entities to publish their reports, transferring this to the Agency where capacity is lacking; require a machine-readable format; and add proportionate, dissuasive sanctions for breaching the "accurate and complete" standard.
CRTA's view
The Agency already publishes all submitted reports, so transparency is ensured even for low-capacity entities. An electronically signed report should not also require a paper copy, and the Agency should publish regularly updated records of who has and has not reported.
Revised draft · 19 May 2026
What the draft does
Following ODIHR, the AFR may be published another way (social media or official gazette) where an entity lacks means and capacity, and AFR data must be in a searchable, analysable, downloadable format.
ODIHR
No further opinion.
CRTA's view
Summary: aligned with ODIHR, but the paper copy should still be dropped where the report is electronically signed, and the Agency should regularly publish updated records of submitted reports and initiated proceedings.
Explanation: the open-format requirement would oblige the Agency to upgrade its application (cost, staffing, training), but it lets the public engage with AFR content better. CRTA's earlier asks remain unresolved.
First draft · 10 Mar 2026
What the draft does
Extends the period covered by the preliminary report and adds electronic submission.
ODIHR
Recommendation 18 (2022): publish financial reports before election day. Opinion: extend the reporting period closer to the campaign's end, use a machine-readable format, align the second-instalment payment with reporting, and shorten publication deadlines.
CRTA's view
A good step, but the deadline could extend further since most activity falls at the campaign's end. An electronically signed report should not need a paper copy, and the Agency should publish updated records. Shorter publication deadlines greatly help transparency.
Revised draft · 19 May 2026
What the draft does
Moves the preliminary-report deadline closer to election day (to up to five days after voting), extends its coverage period, shortens publication deadlines (preliminary 3→2 days, final 7→5), requires an open data format, and adds data on the second portion of public funds to the final report.
ODIHR
No further opinion.
CRTA's view
Summary: the deadline changes are a positive step and follow ODIHR, but the wording on the form and manner of submission needs clarifying.
Explanation: paragraph 2's reference to the form "prescribed by the act in paragraph 6" is ambiguous given paragraph 1 already sets the form. The paper-copy and Agency-records issues from the earlier comment remain.
First draft · 10 Mar 2026
What the draft does
Adds a provision obliging banks to submit prescribed data to the Agency.
ODIHR
Opinion: the provision adds clarity on the Agency's powers, given past difficulties processing data due to banks' inconsistent formats.
CRTA's view
Redundant - the Agency can already request such data and banks must supply it. Collecting all this data serves no purpose unless proceedings are under way. The real issue is the readable format, best fixed by a by-law or agreement with banks.
Revised draft · 19 May 2026
What the draft does
Adds a new Article 32 listing the Agency's general competences; the old Article 32 becomes 32a, keeping the bank-data supplement.
ODIHR
No further opinion.
CRTA's view
Still redundant and potentially open to abuse. Listing general competences changes nothing substantive, since the Agency already performs these duties. The new term "verification" needs to be specified, and the bank-data concern (readable format, not submission) stands.
First draft · 10 Mar 2026
What the draft does
Slightly specifies the annual tax-control plan, with insufficiently clear criteria.
ODIHR
No direct recommendation; the 2022 final report noted the rules lack legal certainty. Opinion: clarify how the Agency's report drives selection, delineate the roles of tax bodies and the Agency, define risk indicators, and set deadlines and transparency mechanisms.
CRTA's view
Still too imprecise: specify criteria, cooperation and roles, set a deadline to conclude and inform the public. Replace "financial resources, goods and services" with "contributions", and consider extending control to service providers.
Revised draft · 19 May 2026
What the draft does
The Agency submits data on all providers of "financial resources, goods and services" to the tax administration after report control; the plan must include donors giving 50% of the maximum; and the Agency must report any irregularity at once.
ODIHR
No further opinion.
CRTA's view
Summary: needs substantial reworking - the terminology is unaligned (use "contributions"), control of service providers and deadlines are unregulated, and mandatory transfer of all donor data to the Tax Administration is not in line with ODIHR and does not aid transparency.
Explanation: the blanket donor-data transfer should be changed urgently. This provision is not an improvement and must be better defined.
First draft · 10 Mar 2026
What the draft does
Improves the procedure before the Agency: cuts the campaign complaint deadline from five to three days, adds a 30-day deadline for non-campaign complaints and 15 days for ex-officio campaign cases, requires publication of decisions next working day, and makes decisions final and subject to administrative dispute (Administrative Court to rule within 72 hours in campaign cases).
ODIHR
No direct recommendation; 2022 reports urged clearer Agency procedures. Opinion: set clear deadlines for all proceedings, short deadlines on remedies, an urgent appeal mechanism for campaign cases, and a deadline for publishing court decisions.
CRTA's view
An improvement, especially on campaign deadlines and the Administrative Court, but deadlines should cover other phases too. Consider publishing notice of initiated proceedings. Court deadlines should apply beyond campaign cases, and service between the Agency and entities should be faster.
Revised draft · 19 May 2026
What the draft does
Sets a 15-day deadline to notify an entity in an ex-officio campaign case; cuts the ex-officio campaign decision deadline to 8 days and the non-campaign complaint deadline to 15 days; the Agency files its response to the court within 24 hours and publishes court decisions within 8 days.
ODIHR
No further opinion.
CRTA's view
Summary: partly follows ODIHR but can be sharpened. No deadline for ex-officio non-campaign decisions; none for the court to forward the lawsuit; and the 8-day deadline to publish court decisions is unjustifiably long (could be 24 hours or 2-3 days).
Explanation: court deadlines should cover all proceedings, not just campaign complaints, and it should be explicit that a complainant may bring an administrative dispute against the Agency's decision.
First draft · 10 Mar 2026
What the draft does
Keeps the warning measure for remediable shortcomings and adds an obligation to file for misdemeanour proceedings if an entity repeats the same breach within one year of a warning.
ODIHR
Opinion: define more clearly the circumstances for issuing a warning, and consider timely publication of warnings on the Agency's website.
CRTA's view
Partly fulfils the recommendation. The warning should contain a concrete remediation deadline, ending the Agency's vague "in future" wording, and new provisions should align practice with the law and close gaps used to avoid penalising the ruling party.
Revised draft · 19 May 2026
What the draft does
Adds a criterion for issuing a warning where breaches "have not caused more serious harmful consequences", formally following ODIHR.
ODIHR
No further opinion.
CRTA's view
The "in future" practice remains unregulated: the law should require the warning to contain a deadline, or to put the entity on notice that the next breach triggers misdemeanour proceedings. There is still room to specify and improve the provision and align it with practice.
Proposal · 10 Mar 2026
What the draft does
Aligns the new provisions with the appropriate misdemeanours, specifies publication deadlines, and adds new misdemeanours for the responsible person in public-administration bodies.
ODIHR
Recommendation 21 (2020): prescribe a graduated, proportionate system of sanctions with a deterrent effect, and sanction irregularities.
CRTA's view
Tougher, proportionate fines require amending Article 39 of the Law on Misdemeanours. The measure "shall be confiscated" is inapplicable and should be aligned with the Law on Misdemeanours as the protective measure "confiscation of funds" (Articles 53-54).
Single proposal
Note
This proposal has a single version; no separate revised text.
First draft · 10 Mar 2026
What the draft does
Prescribes an obligation to publish the request to suspend the transfer of funds from public sources.
ODIHR
Opinion: the law could be improved by setting a clear, urgent deadline for that publication.
CRTA's view
No comment on the first draft.
Revised draft · 19 May 2026
What the draft does
Introduces a 15-day deadline for publishing the request.
ODIHR
No further opinion.
CRTA's view
The 15-day deadline is not urgent and should be shortened. There is also no obligation to publish the decisions on the request, which would add transparency. In practice this provision has never been applied since the Agency was founded.
Beyond the drafts: what CRTA additionally proposes
In addition to analysing the prepared drafts, CRTA proposes three further changes that neither draft addresses:
First, the bill should also prohibit certain campaign-type activities during the parties' regular work, since in practice the campaign begins well before elections are formally called (in line with ODIHR Recommendation 5/2023 on separating public office from campaigning).
Second, "Agency election campaign observers" should be introduced. Given the passivity of the Agency's current observation mission, a dedicated article should define the rights, obligations and powers of these observers, so that campaign costs and the misuse of public resources can be effectively monitored (echoing ODIHR Recommendation 17/2023, which positively highlighted field observers).
Third, for the sanction of "loss of the right to receive funds from public sources", a deadline should be set for the Administrative Court to decide in that administrative dispute, so that judicial protection is effective in real time.
First, the bill should also prohibit certain campaign-type activities during the parties' regular work, since in practice the campaign begins well before elections are formally called (in line with ODIHR Recommendation 5/2023 on separating public office from campaigning).
Second, "Agency election campaign observers" should be introduced. Given the passivity of the Agency's current observation mission, a dedicated article should define the rights, obligations and powers of these observers, so that campaign costs and the misuse of public resources can be effectively monitored (echoing ODIHR Recommendation 17/2023, which positively highlighted field observers).
Third, for the sanction of "loss of the right to receive funds from public sources", a deadline should be set for the Administrative Court to decide in that administrative dispute, so that judicial protection is effective in real time.
