Conduct of the elections: electoral institutions and actors

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The Republic Electoral Commission (REC) carried out the electoral activities relating to the preparation and organisation of the elections and to decisions on candidate lists in a timely manner and within the statutory deadlines, publishing its decisions and data promptly. In most cases in which there was doubt about the regularity of certified voter support signatures, additional checks were carried out, on the basis of which the number of legally valid signatures was subsequently reduced. At the same time, the application of the rules on the status of minority lists raised questions about the criteria for confirming such lists and about the possibility of circumventing the statutory conditions. On the other hand, the REC's decision that voting at all polling stations abroad be held from 07:00 to 20:00 Serbian time not only departs from the practice the REC applied consistently in earlier electoral cycles, but also has no basis either in domestic law or in international standards and directly undermines the principle of equal suffrage.

The capacity of the oversight institutions to exercise their powers in full during the election campaign remained limited. In the case of the Agency for Prevention of Corruption (ACAS), this was reflected above all in insufficient preparedness for the application of its expanded powers, in limited capacity and in a manner of reporting that did not allow full insight into the oversight carried out. In the case of the Regulatory Authority for Electronic Media (REM), limited institutional capacity and the consequences of the earlier blockage affected its ability to set up monitoring in a timely manner and to extend it subsequently, with the result that some relevant outlets were not covered by oversight. These findings indicate that the formal expansion of powers and the restoration of the institutions' functioning are not in themselves sufficient for effective oversight of the election campaign, and that the quality of that oversight depends on their ability to act proactively and in good time, with adequate capacity and resources.

The Republic Electoral Commission

In the first three weeks of the electoral process, the Republic Electoral Commission (REC) carried out electoral activities within the statutory deadlines, promptly publishing its decisions, rulings and data on confirmed candidate lists. At the proposal of the Ministry of Foreign Affairs, the REC decided that, in the parliamentary elections of 25 October 2026, voting at all polling stations abroad would be held from 07:00 to 20:00 Serbian time. This departs from the practice the REC applied consistently in all elections since 2016, and a large number of voters in the diaspora will be forced to vote at night or in the early hours of the morning. CRTA assesses that this decision was taken on the basis of an incorrect interpretation of Article 91 of the Law on the Election of MPs, that its reasoning has no basis either in domestic law or in international standards and that it directly undermines the principle of equal suffrage.

As regards the transparency of its work, the REC published relevant documentation and information about the process in a timely manner, in line with the statutory deadlines.

The Republic Electoral Commission safeguards the legality of the electoral process - it performs organisational and educational functions, oversees the work of the election bodies (primarily the local election commissions), decides on candidate lists and complaints, sets deadlines in accordance with the law, establishes and publishes the election results and adopts various pieces of secondary legislation. Operational and technical tasks are carried out by the REC's professional service, headed by the Secretary of the REC. The REC is defined by law as an autonomous and independent body for the conduct of elections. However, the REC is not a professional, permanent body. Its members are appointed by the parliamentary groups and by the submitters of candidate lists, and its composition, which is expanded during elections, is tied to the balance of forces in the parliamentary term. REC members are employed elsewhere, and the REC's work is tied to the act of conducting elections itself, while between elections it is barely active. The term of office of the REC's permanent members is tied to the term of the National Assembly. Every confirmed list has the right to nominate one member and one deputy member of the REC in its extended composition. Members and deputies in the extended composition have the same rights as members and deputies in the permanent composition.

The REC consists of a permanent and an extended composition.

The permanent composition was appointed after the 2023 elections. Its members were nominated by the parliamentary groups, in proportion to the number of MPs they hold in the National Assembly. It consists of a chairperson and 16 members, together with their deputies, making 34 people in total. Of these, 22 come from the parliamentary majority and 12 from the opposition.

Chart 3.1. Ratio of the ruling majority to the opposition in the REC's permanent composition

Balance between the ruling majority and the opposition in the permanent composition of the REC

Nominated by the ruling majorityNominated by the opposition

Source: Republic Electoral Commission.

The extended composition is made up of representatives of the candidate lists: each confirmed list receives one member and one deputy. At the time of writing of this report, the extended composition consists of 18 members and 15 deputies.

As of the cut-off date of this report, the REC's permanent and extended compositions together comprise 67 members and deputies. Decisions are voted on by members, and by deputies only when they stand in for an absent member. Nineteen votes are currently required to adopt a decision.

The Secretary, the Deputy Secretary and two representatives responsible for statistics also take part in the REC's work, but they have no voting rights.

Sessions and decisions of the REC

Between the calling of the elections in September 2026 and the cut-off date of this report, 24 sessions of the Republic Electoral Commission (REC) were held, at which decisions and other matters of relevance to the conduct of the electoral process were considered.

Preparation of the voting

Preparations for the conduct of the voting took place within the statutory deadlines, with several decisions taken later than in earlier practice or immediately before the deadlines for carrying out particular electoral activities.

The most significant decisions relating to the preparation of the voting are the decision to introduce voting booths, taken before the elections were officially called, the decision to amend the form for establishing the results of the voting, so as to provide for the number of “unused ballot papers” to be entered in the polling board record, and the decision on establishing the order of places in which parliamentary groups nominate members and deputy members of polling boards in their permanent composition.

At the REC's 12th session, held on 19 and 24 August 2026, it was decided to introduce voting booths as an alternative to the existing screens, on the grounds that this implemented an ODIHR recommendation from 2024. The decision was supported by 12 of the 17 REC members present. The decision raised questions about the legal basis for introducing the booths and about the scope of the ODIHR recommendation.

Following the decision, a negotiated procedure without publication of a public call was conducted, in which five bidders took part, and the contract for the procurement of around 30,000 booths, worth more than 830 million dinars, was concluded with the company KLIMA PLUS DOO BEOGRAD. The procurement was carried out under the urgent procedure, although the elections had not yet been called at that point, with the approval of the Public Procurement Office, which contained no specific reasoning as to the grounds for the urgent procedure.

The instruction on the layout of the polling station was amended on 24 September, so that, in the one-way flow of voters, the screens are placed before the voting booths. The introduction of the booths raised questions about the legal basis in Article 52 of the Law on the Election of MPs, about the scope of the ODIHR recommendation and about the possible consequences of the new arrangement for the conditions of voting.

Additionally, the amendment to the form for establishing the results of the voting, adopted on the initiative of REC members appointed at the proposal of opposition parliamentary groups and lists, is significant. In Chapter IV (Other facts) of the polling board record, a new item 12 was added, in which the number of unused ballot papers is entered. The other items remain the same, with only their numbering changing.

The Decision establishing the order of places in which parliamentary groups nominate members and deputy members of polling boards in their permanent composition was adopted in a timely manner, at the same time as the Decision designating polling stations in institutions for the enforcement of criminal sanctions, which designated 29 polling stations with special status. However, by the end of the observation period no single Decision designating polling stations for the territory of the country had been adopted.

As regards other elements of the preparation of the voting, the decisions on the forms for submitting candidate lists were not adopted on the day the elections were called, as had been the earlier practice. On that occasion, amendments to certain forms were also adopted, as were the forms for the accreditation of domestic and international observers and the decisions on the colour of the ballot paper (lilac) and of the control sheet (white).

The plan for conducting training for the election administration was adopted only on 29 September 2026, after which the REC held three online training sessions, devoted to the powers and composition of the bodies conducting the elections, the operational preparation of local election commissions and the publication of documents. A repeat session of the first training was also set for 8 October. Two further training sessions were scheduled for 9 October, one a repeat (preparation of local election commissions) and the other concerning the layout of polling stations. No meeting of the working group on education was held by the end of the observation period, a point raised by some REC members. At the same time, a section entitled “Training of the election administration” was opened on the REC's website, with an eLearning course on work in polling boards available.

In addition, in order to specify the form and manner of keeping records of applications for voting outside the polling station, a group of REC members appointed at the proposal of opposition parliamentary groups drafted an instruction. The draft also provides for contact details to be collected from third parties who register voters for voting, while local election commissions and polling boards would be obliged to contact the voter by telephone and check whether he or she had in fact submitted an application to vote outside the polling station. A separate record is envisaged for the collection of these data.

The draft was considered at two meetings of the REC's Working Group on Normative Affairs. At the meeting held on 29 September, agreement was reached that a final version of the instruction would be prepared, which should be presented at one of the REC's forthcoming sessions.

Work of the REC's working group on voting abroad

Within the Working Group on Voting Abroad, six meetings were held, attended by representatives of the Ministry of Foreign Affairs and of the Ministry of Public Administration and Local Self-Government. The working group asked the Ministry of Foreign Affairs for a map of the polling stations expected to be opened, as well as for data on the locations with the largest numbers of registered voters, so that the possibility of opening additional polling stations could be considered. Despite insistence by the chair of the working group and by REC members that the Ministry of Foreign Affairs submit a list of the cities in which close to or more than 100 voters had registered, the Ministry did not do so, stating that it lacked sufficient capacity to process such data and that processing them would require too much time. As the key challenges in organising voting abroad, the Ministry cited the distances between individual cities and the logistical difficulties of transporting the new voting booths and screens to the most remote locations. Working group members asked the Ministry for data on the number of registered voters broken down by city and country, for the letters by which the Ministry had approached host states with a view to opening polling stations, and for the criteria by which voters from particular cities had been assigned to distant polling stations. None of these data were provided. Representatives of the Ministry did not attend the meeting scheduled for 4 October - the day on which the REC had to decide on polling stations.

At the working group's request, a new meeting was held on 7 October with representatives of the Ministry of Foreign Affairs and a representative of the Ministry of Public Administration and Local Self-Government. Working group members asked the Ministry representatives present for specific data on the number of voters registered to vote abroad in each country and city, as well as for the reasoning behind the opening or non-opening of polling stations in each of the countries in which voters had registered to vote. The Ministry representatives did not present these data, but instead presented a proposed amendment to the Proposal for designating polling stations abroad, containing an unchanged 93 polling stations, but with precisely defined areas covered by each polling station (for example, polling station 1 Australia, Multicultural Centre, where voters from the following areas vote: Melbourne, Perth, Adelaide). The representative of the Ministry of Public Administration and Local Self-Government informed the working group that the number of first-instance rulings issued on applications to vote abroad was slightly more than 103,000, meaning that this many voters had initially registered to vote abroad.

Protection of electoral rights

Since the start of the election campaign, 24 proceedings for the protection of electoral rights have been initiated. The REC upheld two complaints, while 13 complaints were rejected as unfounded and four were dismissed as out of time or for lack of standing to submit them. Ten appeals were lodged with the Administrative Court, of which one was dismissed and nine rejected, thereby upholding the REC's decisions.

Of the total number of complaints, 15 concerned the candidate registration stage, while nine concerned the appointment of members of local election commissions and REC decisions relating to voting abroad. Among the complaints at the candidate registration stage, four stood out as pointing to a possible breach of the law in the confirmation of the national minority candidate lists “Rasim Ljajić - Ljudski (SDP - CDP)” and “Russian Party - Serbia in BRICS - Slobodan Nikolić”. The submitters pointed out that the candidates included persons recognised as active members of political parties that are not national minority parties, which they linked to Article 138 of the Law on the Election of MPs. The Administrative Court did not accept the arguments and evidence presented, but upheld the REC's decisions.

In relation to voting abroad, “Student List - Students Are Winning” submitted two complaints on 7 October 2026 against REC decisions - the decision designating polling stations abroad and the decision setting the opening and closing times of voting at those polling stations.

Complaints and appeals at the candidate registration stage

Against the rulings confirming candidate lists, 15 complaints were submitted - seven against the list “Aleksandar Vučić - United Serbia”, three against the list “Rasim Ljajić - Ljudski (SDP - CDP)”, one against the list “Russian Party - Serbia in BRICS - Slobodan Nikolić”, two against the list “Dad, This Is for You - Petar Đurić - Prime Minister of Serbia”, one against the list “Party of Russian-Serbian Unity - Russians and Serbs Brothers Forever” and one against the list “I Choose Justice - I Choose the Future - Coalition SNAGA - Prof. Dr Ferid Bulić - Vasilios Proveleggios - Stranka budućnosti i razvoja/Građanska stranka Grka Srbije”.

The complaints against the list “Aleksandar Vučić - United Serbia” essentially challenged the candidacy of the incumbent President of the Republic as the list holder and first candidate, pointing to possible misuse of public office. The REC rejected them, among other things on the grounds that it is not competent for matters relating to the position and conduct of public officials. Appeals were lodged against five of the rulings, and the Administrative Court rejected them.

Three complaints against the list “Rasim Ljajić - Ljudski (SDP - CDP)” concerned candidates who, according to the submitters, are publicly recognisable as officials or members of the Social Democratic Party of Serbia (SDPS), which was linked to Article 138 of the Law on the Election of MPs. The complaints did not receive the required majority of votes of REC members.

The most significant proceedings concerned an appeal against the ruling by which the REC rejected a complaint about the confirmation of the list “Rasim Ljajić - Ljudski (SDP - CDP)”. The appeal pointed to an incorrect application of Article 138 of the Law on the Election of MPs in the case of the candidate at number 3, Edis Durgutović, an MP elected at the proposal of the SDPS, a member of that party's parliamentary group and a councillor in Kragujevac. In the National Assembly in May 2026, Durgutović stated that he had been elected not as a representative of a minority list but “as a proud member of the Social Democratic Party of Serbia”. The appeal also pointed to a breach of Article 137, paragraph 2 of the Law on the Election of MPs, since the REC first assessed the minority list status as a preliminary question in the ruling on confirmation and only then issued a separate ruling. By judgment 14 Už 10/26 of 23 September 2026, the Administrative Court rejected the appeal.

The reasoning of the judgment raises a number of questions concerning the interpretation of Article 138 and the assessment of the evidence submitted. As indicators of “party activism”, the court cited fieldwork, the distribution of materials, party meetings, public debates and activity on social media, but did not specifically address the candidate's appearances in the National Assembly on behalf of the SDPS and of that party's parliamentary group. Nor were Durgutović's statement of May 2026 about his membership of the SDPS and his participation in the session on the no-confidence motion against the Government in July 2026 as a representative of that party specifically assessed. The court also cited no evidence that Durgutović's membership of the SDPS or of the parliamentary group had ceased, nor, according to the available reasoning, did it consider the need for the party itself to state a position on his status.

In addition, the court accepted the REC's interpretation that the purpose of Article 138 is to enable members of national minorities to “shift the focus” of their political engagement, although no such exception is expressly provided for by the statutory provision. This left open the question whether the prohibition under Article 138 can be applied to a member of a national minority who is at the same time an active member of a party that is not a national minority party.

Taken as a whole, the reasoning of the judgment leaves open questions concerning the criteria for establishing the “public recognisability” of a candidate as an active member of a non-minority party, the assessment of specific evidence of party engagement and the procedure for establishing minority list status.

In addition, two complaints submitted against the list “Dad, This Is for You - Petar Đurić - Prime Minister of Serbia” are also of relevance. They challenged the legal validity of the signatures collected. The complaints submitted against the ruling confirming the candidate list were upheld, since they were found to be well-founded during the subsequent check of voter signatures. On the first complaint, the confirmation of the candidate list was annulled and the submitter was ordered by a conclusion to supplement its documentation, while on the second complaint it was noted that the ruling had been annulled. The list acted on the conclusion and supplemented its documentation, after which it was confirmed on 2 October.

Local election commissions

Local election commissions (LECs) have an operational role in conducting the parliamentary elections within local self-government units (municipalities and cities).

The competences of local election commissions include preparations for the conduct of the elections, the designation of polling stations, the appointment and dismissal of polling boards, following the course of the voting and the handover of election material. After election day, LECs adopt consolidated reports on the results of the voting and decide on requests for the annulment of voting at polling stations.

Since the calling of the elections, local election commissions (LECs) have been authorised to designate polling stations and to appoint LEC members in their permanent and extended compositions. In most local self-government units, the LECs designated polling stations in a timely manner. However, there were frequent changes in the composition of LECs, including dismissals and appointments of chairpersons and secretaries immediately before and after the calling of the elections. This gives rise to concern about the stability of their composition and about the motives behind particular appointments.

In the meantime, six complaints about the composition of local election commissions were also submitted. One was lodged against the ruling appointing a member and a deputy member of the Mladenovac LEC, because the person appointed as chairperson of the commission holds the post of secretary of the Municipal Assembly. A second claimed that the members and deputy members of LECs appointed at the proposal of the minority list “Rasim Ljajić - Ljudski (SDP - CDP)” do not hold certificates of completed training. Both complaints were rejected. The remaining complaints concerned the failure of local election commissions to adopt a decision, or the decision itself, on members in the extended composition, in Kovin, Aranđelovac, Bojnik and Novi Kneževac. Two complaints were rejected, while no decision has yet been taken on the other two.

Registration of candidate lists and the conditions for collecting support

The integrity of the candidate registration process has been undermined by weak transparency and by serious allegations of unlawful acts - such as recorded cases of certification of signatures without the voter's identity being established, and suspicions of forgery of signatures. Cases of pressure on voters and on institutions to favour the list of the ruling Serbian Progressive Party (SNS), or to make it more difficult for opposition actors to collect support, also contribute to this. The fact that a record-fast candidate registration process, with a reportedly mass turnout, also served the ruling Serbian Progressive Party to deepen propaganda in its own favour in the most influential media further fuels doubt about the authenticity, and also the credibility, of the signatures collected.

Confirmed candidate lists

By the publication of this report, a total of 18 candidate lists had been confirmed. Half of that number, nine candidate lists, are national minority lists - three Bosniak, two Russian, one Hungarian, one Greek, one Albanian and one Slovak.

The number of confirmed candidate lists is the same as in the 2023 early parliamentary elections, despite the fact that most of the traditional parliamentary opposition parties are not taking part in these elections.

In the first stage, the following lists were confirmed: “United Serbia”, the list of Ivica Dačić, the Student List, SDP-CDP, SVM, SPP, Russian Party, “Authentic Right”, “European Serbia”, SDA Sandžaka and Pokret Snaga Srbije. The list “Dad, This Is for You” was initially confirmed on 26 September; after the ruling was annulled and the documentation supplemented, it was confirmed again on 2 October.

On 1 October, Liberalno zelena stranka, Koalicija Snaga and Stranka rusko-srpskog jedinstva were confirmed, and on 2 October the coalition “Vladimir Gajić - Alternative for Serbia”.

The coalition “The People's Choice - Miroslav Miki Aleksić - Miloš Parandilović - Aleksandar Jovanović Ćuta”, submitted by the People's Serbia coalition, was lodged with the REC on 15 September 2026 with 10,421 support signatures. The list was confirmed on 18 September. On 22 September, the coalition notified the REC of its withdrawal, which the REC noted in a ruling of 24 September.

Certification of signatures by type of certifying authority

The distribution shows differing reliance on certification channels. Among the lists for which these data are available, certification in administrations or courts predominates in seven out of eleven, while in four the majority is accounted for by certification before notaries public.

The Student List has the highest share of certification before notaries public - 77.9 per cent. This channel also predominates for SDA Sandžaka, “European Serbia” (61.3 per cent) and Pokret Snaga Srbije (58.86 per cent). By contrast, administrations and courts account for 96.7 per cent of certification for Russian Party, 91.1 per cent for the SVM, 88.8 per cent for the list of Rasim Ljajić and 81.3 per cent for “United Serbia”. The difference between the Student List and “United Serbia” in the share of certification before notaries public is 59.2 percentage points.

Certification of support signatures by type of certifying body

The third segment is the remainder to 100 per cent (courts and unallocated) and is calculated from the first two columns. The values are to be confirmed before layout.

Municipal administrationNotaries publicCourts and other

Source: CRTA analysis based on data on certified support signatures, September 2026.

Data on certification were not available at the time of publication of this report for the lists submitted between 25 September and 4 October. The list “Dad, This Is for You - Petar Đurić - Prime Minister of Serbia” was submitted twice, on 25 and 30 September. On the first submission, 10,007 signatures were accepted, only seven more than the statutory threshold. The largest number of accepted signatures belongs to the list “Vladimir Gajić - Alternative for Serbia” (12,489). It is followed by Liberalno zelena stranka (10,580, with a high share of rejected signatures, 8.3%) and by the second submission of the list “Dad, This Is for You” (10,398). Four minority lists had between 5,000 and 6,000 accepted signatures. These are Albanian Coalition (5,988), Stranka rusko-srpskog jedinstva (5,778), “Mother Serbia - Gruda” (5,237) and the coalition “Snaga” (5,069). All the lists passed the threshold applicable to them.

Geographical distribution of signature certification for the lists with the largest numbers of submitted signatures

United Serbia (223,933 signatures) and the Student List (69,947 signatures), which submitted the largest numbers of voter support signatures, differ in the territorial coverage of certification. For United Serbia, certification was recorded in 161 municipalities, and for the Student List in 76. The data show the places of certification, not necessarily the permanent residence of the voters who gave their support.

Chart 3.3. Coverage of certification for the two lists with the largest numbers of submitted voter support signatures

Geographic coverage of certification for the two lists with the most support signatures submitted

Source: CRTA analysis based on data on certified support signatures, September 2026.

For the Student List, the largest share of a single location in the total number of certified signatures is 5.2 per cent.

Chart 3.4. Fifteen places with the most certified signatures for “United Serbia”

Fifteen places with the most certified support signatures for “United Serbia”

Source: CRTA analysis based on data on certified support signatures, September 2026.

Chart 3.5. Fifteen places with the most certified signatures for the Student List

Fifteen places with the most certified support signatures for the Student List

Source: CRTA analysis based on data on certified support signatures, September 2026.

Jagodina stands out as the only place in which all voter support signatures for “United Serbia” were certified before notaries public. In this city, 2,608 signatures were certified for the list of Ivica Dačić, the largest number among the places of certification for that list. For the Student List, 1,872 signatures were certified, placing Jagodina among the ten places with the most certified signatures for this list. That is almost three times more than for “United Serbia”, for which 633 signatures were certified in Jagodina.

In addition to these two lists, the geographical concentration of certification for the list “Rasim Ljajić - Ljudski (SDP - CDP)” stands out. Certification was recorded in 13 cities and municipalities. In Novi Pazar, 3,473 signatures were certified, or 43.1 per cent of the total submitted, while 85.8 per cent were certified in five places. With 1,096 signatures, or 13.6 per cent, Kragujevac is the third location by number of certified signatures, behind Novi Pazar and Tutin. All the signatures recorded in Kragujevac were certified at the City Administration. The observer in Kragujevac stated that he had not recorded any announcement of the collection in the media or on social media and that, in conversations, he had been unable to establish when and where the collection had been organised.

Availability of certifying officers and the organisation of certification

The collection of signatures was accompanied by uneven availability of certifying officers and changes of appointment times, along with difficulties in organising certification.

Difficulties in scheduling and carrying out certification were recorded in at least 12 cities and municipalities. They included delays to the start, a limited number of certifying officers, temporary interruptions and longer waiting times for citizens. Most of the findings collected relate to the Student List, but difficulties were also recorded in the cases of the coalitions “Izbor naroda”, “European Serbia” and “Authentic Right”.

Certifying officers of municipal and city administrations

In municipal and city administrations, the difficulties concerned the approval of appointment times, the number of officials available and the duration of certification. In Čačak, the start of the Student List's signature collection was postponed after the City Administration assessed its request as incomplete. Certification was organised the following day, with a temporary interruption because old forms were being used. Citizens waited for more than two and a half hours.

In Zaječar, CRTA Election Observation Mission recorded a limited number of certifying officers for the Student List. It was publicly claimed that an extension of working hours had not been approved even though citizens were queuing to give their signatures.

In Niš, on 12 September students organised a protest in front of the City Assembly after, according to their statement, certifying officers of the City Administration refused to work the following day, a Sunday. They stated that on 10 September they had submitted a request for certification from Friday to Monday. According to a field report, certification continued on 13 September at three locations. In Alibunar, a representative of “European Serbia” publicly pointed to the refusal of a requested appointment.

Notaries public

In the case of notaries public, the cancellation of previously agreed appointments and difficulties in securing on-site certification stand out. According to an allegation submitted, a notary public in Velika Plana cancelled previously agreed appointments for the Student List because she had not yet completed the certification of signatures for the SNS. That reason for the cancellation has not been independently confirmed. Citizens who wished to give a support signature to the Student List then travelled to Smederevska Palanka for certification.

In Vršac, the cancellation of an agreed appointment and the postponement of collection to Monday were recorded for “Izbor naroda”. The available material states that, for “European Serbia”, certification was organised on the same day from 09:00 to 17:00, but the reasons for the different conditions were not established. Ivana Rokvić, a representative of the People's Movement of Serbia (NPS), spoke publicly about the unavailability of notaries and about difficulties in organising certification.

NPS representatives showed an observer messages about cancellations or the limited availability of certifying officers in Beočin, Vršac, Bački Petrovac, Kikinda, Vrbas, Novi Bečej and Bačka Topola. “Authentic Right” made similar allegations publicly; in Kruševac, it was recorded that certifying officers did not come on the first day, while two were engaged the following day.

Not all cancellations had the same reason or outcome. In Ruma, both notaries, having first said they were unavailable, offered Sunday appointments. In Zemun, information received subsequently linked the cancellations to illness, family circumstances and previously booked appointments. In Novi Sad, there were differing explanations for the delayed start: public allegations of the unavailability of notaries and an explanation by a representative of the citizens' assembly that the Student List's request had been submitted after the requests of other actors.

In Sombor, representatives of five opposition parties stated that over the weekend three notaries public had turned them down on the grounds that they were busy. According to the material collected, one of them certified signatures for the SVM on 14 September from 09:00 to 17:00.

In Smederevska Palanka, according to a field report, an administration official worked until 15:00, while a notary public who had previously cancelled his attendance continued certification from 17:00 to 21:00. In Kragujevac, a delay of around 45 minutes was recorded, after which certification continued. In Vračar, the waiting was linked to a high turnout and to technical problems, while in Knjaževac citizens went to the notary's office after their documentation had been prepared at the collection point. In some places, working hours were extended because of the high turnout.

Cases of potential criminal offences in the candidate submission process: certification of signatures without citizens present and the use of pre-scanned identity documents

Allegations were recorded of support being processed without citizens present, using identity cards collected or scanned earlier.

In Mladenovac and Paraćin, allegations were recorded that raise questions about the authenticity of the signatures and about the possible unlawful use of personal data. The accounts described the preparation and processing of data before the signatories arrived, including suspicions that some citizens were not present when support was given to “United Serbia”.

The prior scanning of an identity card and the preparation of the form are not in themselves evidence of inauthentic support. Such preparation was recorded both for “United Serbia” and for the Student List. The key questions are whether the voter appeared in person for certification, whether his or her identity was established and whether support was given of his or her own free will.

The contested circumstances also included the manner in which signatures were secured for other lists. In Niš, an observer recorded an offer of 1,500 dinars for a support signature for the citizens' group Uglješa Grgur. In Novi Sad, an allegation of the purchase of signatures for the list of Bogoljub Karić was recorded.

In Požarevac, during the collection of signatures for the list “Dad, This Is for You”, the presence and, according to sources, the involvement of SNS activists were recorded.

From observers' field reports

“The coordinator said that citizens whose identity cards are brought in do not have to appear in person to give a signature; it is enough for their scanned identity card to be brought in.”

“All activists were given the task of collecting the identity cards of people who would not be able to come in person.”

“We have 230 in the books and 250 in identity cards... Ours are in the party, and the rest, whom they hold as identity cards, they “transfer onto paper”.

“To a colleague who is on a fixed-term contract she said: 'Tomorrow you are signing your contract, think carefully about what you are going to do.'”

“The whole of Vodovod is here today.”

“The people looked as if they were being brought in and taken away in an organised manner and as if they were mostly workers of public enterprises.”

Use of public resources in the collection and certification of signatures

The collection of support for the ruling list was also organised on the premises of organisations and institutions.

At some collection points, the arrival of groups of employees in the presence of their managers was recorded. In Zaječar, an observer noted groups of workers from public enterprises and institutions led by their directors. In Smederevska Palanka, after information about an organised arrival of employees of the local health centre, an observer found the director with staff at the collection point.

Separate accounts concerned calls on employees of EPS and EDS to give their support and workers of “Kolubara usluge” in Lazarevac who, according to a source, were offered paid hours for attending. An account was also recorded of the giving of support being linked to the renewal of fixed-term contracts.

The organised arrival of employees and the presence of managers do not in themselves confirm pressure. Accounts of support being made conditional on employment status or benefits, however, raise the question of employees' freedom of decision.

Doubts about the authenticity of certain candidate lists

Doubts about authenticity arise in the case of at least five candidate lists. The doubts relate above all to whether these are genuine actors or actors fabricated for the purpose of taking part in the elections.

In the case of the list “Dad, This Is for You - Petar Đurić - Prime Minister of Serbia”, limited visibility of signature collection, a strikingly small number of candidates and repeated allegations of contested securing of support overlap. The list has nine candidates, while the activities observed were primarily linked to Petar Đurić. According to allegations from three independent sources, SNS activists collected signatures for this list in Požarevac, and support was given by employees of public enterprises. These allegations are an indicator of possible organisational dependence in securing candidacy. In the 2023 Belgrade elections, too, the movement was accompanied by allegations of forgery of signatures, including public denials by individuals that they had given their support.

In these elections, the REC took a number of actions because of irregularities in voter support signatures. After it established 125 invalid signatures on 30 September and annulled the original ruling confirming the list, the number of valid signatures fell below the statutory minimum. The submitter was ordered by a conclusion to submit the missing voter support signatures, following which it submitted 533 signatures the very next day. The REC established that 516 of them were legally valid, and the list was confirmed again on 2 October, with a total of 10,007 support signatures. In the vote on the renewed confirmation, seven REC members abstained.

At the same time, a number of REC members carried out an additional review of the signatures submitted earlier and established a further 133 invalid signatures, which had not been covered by the original check. It was proposed that the REC's professional service request reports on the certification procedure for those signatures from the city and municipal administrations in 20 places. The proposal, however, was not placed on the agenda of a session, so the REC did not decide on it. In the meantime, voters submitted two complaints about the confirmation of the list, citing publicly available information about the contested signatures. Both complaints were unanimously upheld, and on the first the ruling confirming the list was annulled.

In the case of the list “Liberal Green Party - For a Free and Cleaner Serbia”, the history of electoral participation linked to Dejan Žujović is relevant. Lists with similar names but different formal submitters, including citizens' groups, Evropska zelena partija and the party Nova - Da se struka pita, appeared in several places and electoral cycles. In this way a political brand was repeated while the formal submitter changed. In several documented cases, those lists won many times fewer votes than the number of support signatures they had submitted. After the 2024 elections, councillors from some lists linked to Žujović supported the SNS, including support that made it possible to form the local authority in Savski venac.

In the case of “Russian Party - Serbia in BRICS - Slobodan Nikolić”, its earlier post-election action alongside the ruling majority and the limited visibility of the securing of its current candidacy are important. The Russian Party seat was decisive for the formation of SNS rule in Niš in 2024, and the holder of that seat, Tihomir Perić, is placed high on the current list. This shows a continuity of personnel linked to earlier post-election support for those in power. No visible signature collection was recorded in the material monitored, while the first recorded field activity was published on 26 September; the list has 25 candidates. The continuity of political activity and the seats won point more to a possible so-called satellite role than to an organisation that exists only in appearance.

In the case of “I Choose Justice - I Choose the Future - Coalition SNAGA - Prof. Dr Ferid Bulić - Vasilios Proveleggios”, data are available on earlier coalition participation by Građanska stranka Grka Srbije and on the current list being nine per cent full, which points to two indicators: the continuity of a single formal list holder across different coalitions and a small number of candidates. In addition, no signature collection activity for this list was recorded in the material gathered during observation, which is a further indicator to be followed.

In the case of “Party of Russian-Serbian Unity - Russians and Serbs Brothers Forever”, its registration immediately before the elections and the list being six per cent full are relevant. Short organisational continuity and a small number of candidates are initial indicators for checking and monitoring. For this list, as for the Snaga coalition, data on the organisers of signature collection, on financing and on actual political activity that would allow a firmer conclusion are lacking.

Clarifying these doubts requires transparency in the candidate registration procedure and the availability of data on the organisers, the financing and the manner in which support for candidate lists was secured. CRTA's observation mission will continue to follow their actual activity, the possible use of shared personnel and resources and the conduct of their representatives in the election bodies. These findings will be considered as part of the assessment of the conditions for voters' free choice and of the transparency of the electoral offer.

Case: The personnel “multiplication” of the SDPS through other parties' lists

In line with the complaints submitted against the candidate list “Rasim Ljajić - Ljudski (SDP - CDP)”, this list is an example of an observed new pattern of manipulation in candidate registration. A review of the candidate lists for the parliamentary elections called for 25 October 2026 shows that active members and officials of the Social Democratic Party of Serbia (SDPS) are standing as candidates of other political parties, above all of parties registered as national minority parties. Formally, new electoral actors thus appear, while their personnel composition remains essentially the same.

This practice, as is also set out in the content of the complaints and appeals submitted to the Administrative Court, raises the question of the application of Article 138 of the Law on the Election of MPs, which provides that the REC will refuse to grant a candidate list the status of a national minority list if the list holder or any candidate is a person who is publicly recognisable as an active member of a party that is not a national minority party. According to ODIHR's Supplementary Opinion of March 2026, that provision was extended to all candidates on a list precisely in order to prevent the misuse of minority status. More broadly, the phenomenon also calls into question the credibility of minority representation itself: an institution that exists to protect the political representation of national minorities is being used as a channel for the entry of personnel of a party that is not one, which at the same time reduces the transparency of the electoral offer for voters.

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- The most pronounced example is the candidate list Rasim Ljajić - Ljudski (SDP - CDP), submitted by the Sandžak Democratic Party (registered as a Bosniak national minority party) and the Montenegrin Democratic Party (newly registered as a Montenegrin national minority party in September this year), to which the REC, by a ruling of 15 September 2026, granted the status of a national minority candidate list - a status that carries privileged conditions for winning seats (the natural threshold instead of the 3% electoral threshold). -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

That list includes a number of persons whose affiliation with the SDPS is publicly documented, including in statements and posts by that party itself:

Edis Durgutović (number 3, nominated by the SDP) - an MP elected at the proposal of the SDPS from the list “Aleksandar Vučić - Serbia Must Not Stop”, head of the SDPS parliamentary group in the National Assembly, a councillor and head of the SDPS councillors' group in the Kragujevac City Assembly, Vice-President of the SDPS Executive Board;

Tatjana Majstorović (number 220, as a CDP candidate) - listed on the SDPS website as a member of the Executive Board of SDPS Beograd;

Filip Brusnić Renaud and Jasmina Bukvić (numbers 42 and 195, CDP candidates) - presented in a news item on the SDPS website as new members of that party;

Dragana Vukoslavović (number 119, CDP) - listed on the SDPS website as the elected vice-president of the SDPS Vranje Women's Forum;

Slađan Kitanović (number 16, CDP) - a former councillor in the Vranje Municipal Assembly elected from the SNS list, whom Minister Husein Memić, in a post from 2024, refers to as an “SDPS councillor”.

The above is supported by evidence - extracts from the candidate list, data from the websites of the National Assembly and of local self-government units, instruments on the allocation and termination of mandates, and public posts and statements by the SDPS itself, media reports and recorded parliamentary appearances by the candidate.

Case: Additional check of voter support signatures and the candidate list Bogoljub Karić - Movement Strength of Serbia - BK

On 23 September 2026, Pokret snaga Srbije - BK submitted the candidate list “Bogoljub Karić - Movement Strength of Serbia - BK” with 11,366 voter support signatures. The basic check established that 70 signatures were not legally valid because an old form had been used or because the voter's signature or the certifying officer's stamp or signature was missing, while 244 persons were not entered in the Unified Voter Register. After this check, 11,052 legally valid signatures were established.

Because of doubts about the validity of the certification of a larger number of signatures, at an urgent session on 23 September the REC decided to check the data additionally, directly with the certifying officers. On 24 September, letters were sent to 65 addresses - 25 municipal and city administrations and 40 notaries public. The check revealed various discrepancies between the data submitted to the REC and the certifying officers' records: in 24 cases the data matched completely, while in 22 cases the certifying officers had recorded a higher, and in six cases a lower, number of certified signatures than the number submitted to the REC. In 13 cases the number of signatures submitted to the REC was higher than the number of voters entered in the voter register. On the basis of the additional check, the number of legally valid signatures was reduced by 449 and finally established at 10,603.

It was additionally established that the candidate at number 219, Danijela Sinadinović, was not entered in the Unified Voter Register. By a conclusion, the REC ordered the submitter to remedy this deficiency within 48 hours, by submitting a certificate of the candidate's electoral right or by withdrawing her and nominating another candidate. The submitter acted on the conclusion and replaced the candidate, after which the list was confirmed on 26 September 2026.

The Agency for Prevention of Corruption (ACAS): expanded powers, limited capacity and transparency of oversight

The work of the Agency for Prevention of Corruption was marked by a restrictive reading of the statutory provisions and by the absence of transparent implementation of its duty to monitor the President of the Republic, members of the Government and officials during the election campaign, as well as to supervise the promotional activities of the authorities. The published findings on the monitoring of officials offered little information about specific activities, while for the President of the Republic and members of the Government they were not published at all.

At the same time, the Agency proactively initiated proceedings only in relation to breaches of Article 50(3) of the Law on Prevention of Corruption, which concern the use of public officials' social media accounts, while, according to publicly available data, it did not act on other, more serious forms of possible breaches of the law. The Agency also engaged additional observers only after the campaign had begun. These findings indicate a mismatch between the Agency's expanded powers and the capacity, the reporting practices and the conduct through which that mandate was exercised in this electoral cycle.

The Agency's capacity: between new powers and available resources

The Agency's expanded powers in this electoral cycle also raised the question of securing in good time the capacity needed to exercise them. During 2026, in the context of the expansion of its statutory powers and of the recommendations of international organisations, the Agency advertised vacancies for a total of 11 new posts. The need to strengthen the Agency's capacity was also recognised by ODIHR.

However, the planned increase in staff numbers did not amount to a dedicated staffing reinforcement for the needs of this electoral cycle, nor could the new staff be made fully operational during the elections. The effects of the planned strengthening of capacity cannot therefore be expected in full in the current electoral process, but primarily in subsequent cycles.

The question of capacity was also raised by the engagement of election campaign observers. The Agency published the public call for the selection of observers on 28 August, shortly before the early parliamentary elections were called. By a decision of 14 September, a further nine observers were selected, filling the vacant places in relation to the 74 observers selected by an earlier decision from 2023.

Their task is the direct monitoring of election campaign spending and the collection of data on the activities of political entities and third parties in the field. However, according to a statement by the Agency's director of 22 September, the observers were engaged only on 21 September, that is, after the campaign had begun. The late engagement limited the scope for this mechanism to be used in full from the very start of the electoral process. In this electoral cycle, too, this points to a mismatch between the Agency's expanded powers and the time and capacity made available to it to exercise them.

In addition, on 30 September an incident occurred in which a field observer of the Agency was physically attacked while carrying out an assignment in Novi Beograd. According to publicly available information, the observer was photographing material connected with the election campaign, after which unknown persons approached him, demanded that he delete the photographs and physically assaulted him, following which he was taken to the Military Medical Academy.

The Agency responded only on 2 October, and in its statement it specifically stressed that the person was not its employee but was engaged under a contract for temporary and occasional work. His formal employment status was thus placed in the foreground, even though at the time of the incident the person was engaged precisely as a field observer of the Agency and was carrying out an assignment in that capacity.

The Agency also stated that the police had not confirmed the incident on the available footage, that the observer had not filed a complaint and that, according to his own statement, he had photographed a banner on an overpass rather than a political party stand, as had previously been reported. These circumstances point to inconsistencies in the publicly available information about the incident, while the Agency's belated response and its emphasis on the formal status of the engaged person play down the significance of the incident and its connection with the work of observing the election campaign. The Agency did not publicly condemn the violence, nor did it clearly stand up in defence of its observer, even though he was attacked while carrying out assignments as part of his engagement by the Agency. Such a response leaves the impression that the Agency did not adequately protect its observer or condemn the violence committed against him.

Monitoring of the officials' campaign: a new mechanism, incomplete findings

The amendments to the Law on Prevention of Corruption introduced two mechanisms for monitoring public officials during the election campaign - that is, for monitoring the officials' campaign, campaign activity carried out by public office-holders in their official capacity. The first is the monitoring of a random sample of at least 60 officials in parliamentary and presidential elections; the second is the mandatory monitoring of the President of the Republic and members of the Government, independently of the random sample. Although the Agency has put this mechanism in place, its implementation has so far been largely formal: the published findings on the officials in the random sample amount for the most part to a list of the officials monitored and the number of proceedings initiated, without information on the specific activities monitored, while for the President of the Republic and members of the Government no weekly finding has been published.

In this electoral cycle the Agency monitored the media appearances, social media activity and public appearances of more than 90 public officials. That number includes the officials selected into the random sample, which is drawn using a software tool together with a risk assessment based on the Agency's earlier decisions and on complaints from previous election campaigns, as well as the officials the Agency is required by law to monitor - the President of the Republic and members of the Government.

In accordance with the law, the Agency's director adopted a monitoring plan, which the law did not require to be published. On the basis of that plan, the first report, for the period from 15 to 22 September, was published on the officials in the random sample. The report contains a list of the officials monitored and the information that the Agency had initiated, of its own motion, 13 proceedings on suspicion of a breach of Article 50 of the Law on Prevention of Corruption. The report does not, however, state against whom or on what grounds the proceedings were initiated and it does not contain data on the types of activities and public appearances monitored, even though the law prescribes these as mandatory elements of the weekly reporting.

The second report on the findings of the monitoring of public officials was published on 2 October and covers the period from 23 September to 1 October. Like the first report, this one is incomplete, and in addition it contains no information on whether any new proceedings were initiated of the Agency's own motion during that period.

When only the number of proceedings initiated is published, without any further information, it is difficult to check on the basis of which specific activities the proceedings were initiated and how the Agency applied the new statutory provisions. A review of the Agency's subsequently published decisions established that, on the basis of the monitoring findings, 12 decisions were issued of its own motion for breaches of Article 50(3) of the Law on Prevention of Corruption, which concerns the new obligation for a public official to label the account used in the capacity of a public official.

At the same time, the published decisions contain no data on proceedings initiated over other forms of possible misuse, including the use of public resources in the election campaign. This makes it difficult to assess the extent to which the monitoring covers the various risks envisaged by the law and whether the new monitoring mechanism is being applied comprehensively.

Finally, the Agency failed altogether to publish a report on the findings of the monitoring of the officials it is required by law to monitor, namely the President of the Republic and members of the Government.

Promotional activities of public authorities: limited coverage and the absence of checks

The amendments to Article 50 of the Law on Prevention of Corruption introduced an obligation for public authorities to notify the Agency of planned promotional activities taking place after the deadline for candidate registration and before the end of the campaign. The notification is to be submitted within seven days of the calling of the elections, while the Agency is required to publish a list of the activities notified. In practice, the data were not submitted consistently, while the Agency publishes the notified activities without checking whether they meet the statutory criteria, which limits the scope for monitoring how this provision is applied.

For this electoral cycle the Agency set up a dedicated page, “Planned promotional activities”, giving the public insight into the activities notified by public authorities. By the time this report was drawn up, notifications had been submitted by a total of 31 public authorities: the General Secretariat of the President of the Republic; the Office of the Prime Minister; various ministries (of culture, of the economy, of agriculture, forestry and water management, of finance and of defence, among others); various municipalities, cultural centres, the Post of Serbia and others.

Although the establishment of a publicly available register of notified activities is a step towards greater transparency, the effectiveness of this mechanism will also depend on whether the Agency checks compliance with the notification obligation and acts in cases where unnotified activities are held.

Informing and educating participants in the electoral process

During the election campaign the Agency published educational statements on the rules governing the financing and conduct of the campaign. These covered the campaign spending cap and the limits on donations, the obligations of donors, the opening of a dedicated account, the submission of reports, the labelling of advertising and other campaign material, as well as the ban on using public resources for political promotion and on organising charitable activities during the election campaign.

The Agency also opened a dedicated page on third parties, publishing information on who is considered a third party, who cannot hold that status and what obligations follow from it. These activities are a positive contribution to informing participants in the electoral process and to the accessibility of the rules. Educational communication cannot, however, replace active oversight, verification of compliance with the rules and timely action on complaints.

Campaign financing: new rules and the risk of unequal positions for participants

The application of the Law on Financing of Political Activities continues to raise practical questions in relation to certain statutory limits. The application of the new rules on donations by natural persons is particularly significant. The law caps donations for regular activity at five average monthly salaries and donations for election campaign financing at two and a half average monthly salaries, and it requires a donor, before making a donation, to declare that any company of which the donor is the owner or co-owner, or in which the donor holds a stake or shares, has not made donations to political entities in the 2026 calendar year, and, after making the donation, to submit a new declaration that the maximum value of donations has not been exceeded.

In practice, these rules may represent an additional burden on campaign financing, particularly for new political actors that have no funds for regular activity which they could channel into financing the campaign. For them, donations by natural persons may be an important source of campaign financing, so additional limits and administrative obligations may make it harder to raise the funds they need.

With regard to the financing of third-party activities, the Agency has published on its website information on the rules that apply to them, including who is considered a third party, which activities are subject to the obligations under the Law and what the obligations of third parties are in relation to the financing of campaign activities. It is noticeable, however, that the Agency's communication in this area has so far been primarily informative, without any publicly available record of third parties' activities or financial data, which makes it harder to follow their actual involvement in the election campaign.

As regards financing from public sources, 0.07% of the tax revenues of the budget of the Republic of Serbia, or 1,475,810,000 dinars, around 12.6 million euros, was provided for the 2026 parliamentary elections. Of that amount, 40%, or 590,324,000 dinars, makes up the first tranche of funds which, under the conditions prescribed by law, is distributed in equal amounts to the submitters of confirmed candidate lists that have declared they will use funds from public sources.

If 18 confirmed candidate lists meet the conditions for payment of the first tranche, each list would therefore receive 32,795,777 dinars, or around 280,305 euros. This figure is, however, illustrative and depends on whether all the lists will meet the statutory conditions for payment.

The return of funds by lists that do not win the number of votes prescribed by law is a separate issue. Lists that win at least 1% of the vote, or 0.2% in the case of minority lists, keep the funds received, while the others are required to return them. For lists that were obliged to lodge an electoral guarantee - the security non-parliamentary actors must lodge in order to access public funds for the campaign - recovery can be made from that guarantee. However, the law exempts certain citizens' groups, political parties and coalitions from the obligation to lodge a guarantee, and in those cases the question arises of the mechanism for recovery if a list does not win the required number of votes and does not voluntarily return the funds. This question will be important for monitoring the application of the campaign financing system and accountability for public funds.

Publicly available decisions of the Agency

A dedicated page for decisions on breaches of Article 50 of the Law on Prevention of Corruption has been set up on the Agency's website; so far the available information is that the Agency has decided in 16 proceedings - four cases brought on complaints and 12 initiated of its own motion. The cases initiated of the Agency's own motion concern breaches of Article 50(3) of the Law on Prevention of Corruption, which introduces an obligation for public officials to label the social media account they use in their capacity as public officials and a ban on publishing content relating to the activities of a political party on that account. The four proceedings brought on complaints concern breaches of Article 50(12) of the Law on Prevention of Corruption, that is, the ban on public officials taking part in the activities of a political party and on conducting political activities during the working hours of a public authority. On the basis of these complaints, the measure of a warning was imposed on the public officials.

The Agency issued a decision, on suspicion of a breach of Article 23 of the Law on Financing of Political Activities, that is, of the use of public resources in the campaign, on a complaint against the citizens' group “Student List - Students Are Winning”, which is available on a dedicated page of the Agency's website. The complaint states that a candidate on that list, Aleksandra Nikolajević, on 16 September sent staff a message from the official address of the Faculty of Philosophy in Niš opening a new round of applications for financial assistance provided by “Solidarity Network” (“Mreža solidarnosti”). In the message she gave instructions on amounts and the deadline and announced that she would forward the list of applicants to coordinators. According to the complaint, the assistance was intended for staff who met a criterion of prior public engagement. The person responsible for the citizens' group disputed the allegations, stressing that the emails mention neither the citizens' group nor the candidate list and that the professor had acted in an individual capacity. By a decision of 25 September the Agency found that there were no grounds to rule on the existence of a breach of Article 23 of the Law on Financing of Political Activities. In its reasoning it states that this was an individual action by the candidate, that the citizens' group neither organised nor financed the activity and that the emails do not call on staff to support the list or vote for it.

In addition, the Agency issued two decisions on complaints against the Serbian Progressive Party (SNS). One decision concerned allegations about the use of vehicles of the public enterprise “Inđija put” for the purposes of the SNS, while the other concerned allegations about the use of public resources and the activities of the President of the Republic for the purposes of the SNS election campaign. In both cases the Agency found that there were no grounds to establish a breach of the Law on Financing of Political Activities.

CRTA's complaints to the Agency for Prevention of Corruption

Since the start of the election campaign CRTA has filed 19 complaints with the Agency for Prevention of Corruption on suspicion of breaches of the rules, of which 13 concern breaches of the Law on Financing of Political Activities and six the Law on Prevention of Corruption. CRTA has also filed a supplement to its Initiative for active monitoring of the political activities of the Serbian Progressive Party. By the time this report was finalised, CRTA had not received a single reply to the complaints filed.

The complaints were filed over breaches of Article 23 of the Law on Financing of Political Activities, including paragraphs 2, 4 and 5, by a political actor, as well as over breaches of Article 50 of the Law on Prevention of Corruption by public officials.

The complaints filed on suspicion of breaches of the Law on Financing of Political Activities concern the limits on financing and the use of public resources in the election campaign. The breaches occurred through the publication of content on the social media profiles of the local branches of the Serbian Progressive Party in Sombor, Barajevo, Smederevo, Lučani, Mali Iđoš, Nova Varoš, Ćuprija and Bajina Bašta.

The largest number of complaints under the Law on Financing of Political Activities concern the promotion of public works and of the activities of public authorities on party profiles. Posts were recorded about the renovation of a school, preventive health check-ups, the asphalting of roads and other infrastructure projects financed from public funds.

The other complaints concern suspected breaches of the Law on Prevention of Corruption, which regulates the limits on the political activity of public officials and prevents the abuse of public office and of public resources for political purposes. The complaints concern the activities of the following public officials: Žarko Mićin, mayor of Novi Sad; Marko Lazić, president of the municipality of Mali Iđoš; Dušan Kozarev, Secretary General of the Ministry of Foreign Affairs; Siniša Mali, Minister of Finance; and Miloš Vučević, special adviser to the President of the Republic and president of the Serbian Progressive Party.

Among these, CRTA filed two complaints against Siniša Mali: one concerns his appearance in a promotional video for the Serbian Progressive Party and the candidate list “Aleksandar Vučić - United Serbia”, during a visit to the “Kreativno-inovativni multifunkcionalni centar - Ložionica” in his capacity as a public official, while the other points to the misuse of a public official's social media account. A complaint was also filed against Miloš Vučević over an Instagram post in which a visit to a mobile clinic in Senje was presented in a way that places public resources in the context of political promotion.

In addition, CRTA filed a supplement to the initiative for active monitoring of political activities submitted on 4 September, with further evidence and established facts. The supplement provides additional support for the claim that the Serbian Progressive Party conducted election campaign activities before the elections were called and thereby used funds intended for regular activity contrary to Article 19 of the Law on Financing of Political Activities.

The supplement covers the rally in Smederevska Palanka of 23 August 2026, at which campaign messages were delivered and voters were called on to vote, with stands, panels and flags bearing the words “United Serbia”. Links from the party's official Instagram and Facebook accounts were also attached, showing that the same name and visual identity - “Aleksandar Vučić - United Serbia” - was used both before 9 September 2026, when the elections were called, and later during the campaign itself, after the SNS candidate list was confirmed under that name.

The supplement points to a reasonable suspicion that the misdemeanour under Article 42(1)(9) and (2) of the Law has been committed, and it proposes that the Agency, while the election campaign is still under way, file a request for misdemeanour proceedings to be initiated against the party and the responsible person and inform the complainant and the public accordingly.

The Regulatory Authority for Electronic Media (REM): towards functionality, but without full monitoring coverage

REM entered the electoral process with limited capacity for effective and comprehensive oversight, after years of institutional deadlock, without an elected president and with a practically bloc-like balance of forces of 4:4. Because the Council was unable to adopt a new supervision plan and methodology in good time, monitoring began under the 2023 methodology, which left out of supervision media service providers that had in the meantime become significant on the media market. Even after the Council's president was elected, no agreement was reached on extending the sample to the new influential cable channels, including Informer TV, while the report of the Monitoring and Analysis Service was not adopted. The limited coverage of the monitoring thus left some influential outlets outside regular oversight precisely during the election campaign.

The decision to begin monitoring under the 2023 methodology was announced on 11 September 2026, when REM's assistant director for legal affairs informed the public that monitoring had officially begun the previous day and that, because the Council had not yet elected a president, it would be carried out under the methodology applied during the 2023 election campaign.

The application of the 2023 methodology means, above all, supervision solely over the programming of those media service providers that were supervised ahead of the election campaign in December 2023, and that sample covers the public service broadcasters, four television stations with national coverage licences and three cable television stations: N1, Nova S and K1.

On 18 September CRTA submitted a request for access to information of public importance, seeking details of the decision, or the act, on the basis of which the supervision of electronic media during the pre-election campaign had begun, including who had adopted or signed it, its content and the date of its adoption. It also requested information on the act of the Regulator on the basis of which monitoring had begun if there had been no prior formal decision. On 1 October CRTA received a reply stating that REM does not hold the requested information and that supervision had been initiated of its own motion, after the start of the election campaign, on the basis of the Council's decision then in force on the selection of media service providers and on the supervision methodology.

Given that the law expressly establishes an obligation for the Regulator to amend the supervision plan no later than 10 days after the elections are called and adapt it to the specific features and risks of each particular campaign, such a decision is unlawful and runs counter to the very purpose of the supervision established by the provisions of the Law on Electronic Media.

Article 33(4) of the Law on Electronic Media: “In the supervision plan for a year in which elections are held, the Regulator shall include supervision of compliance with the provisions of the law and of other regulations governing the conduct of media service providers in relation to the election campaign, including the campaign of state officials, and the objectives in accordance with paragraph 3 of this Article. If elections are subsequently called after the supervision plan has been adopted, the Regulator shall amend the supervision plan for that year without delay, and no later than ten days from the day the elections are called, and shall include the said supervision and the objectives relating to it.”

First, the 2023 Methodology was applied even though it is legally invalid, since its application was exhausted when the previous electoral cycle ended.

Second, by retaining the old sample, influential cable channels with a high risk of breaching the law were completely ignored (such as Informer TV), which directly breached the statutory criteria of media influence and of risk assessment for the public interest.

Third, the Expert Service applied an obsolete act on its own initiative and without any statutory authorisation, and in doing so knowingly reproduced methodological shortcomings that make objective monitoring of media pluralism and of the equal treatment of campaign participants impossible. If the institution was already seeking to monitor media conduct systematically and proactively, without a Council decision which under the provisions of the Law must be adapted to the particular election campaign, it could and should have gone a step further and itself determined an adequate range of outlets in line with the actual situation on the ground.

Election of the new president and the “non-adaptation” of the monitoring methodology

After three unsuccessful attempts, the REM Council elected a president at its fourth constitutive session, held on 22 September 2026. Stevica Smederevac, previously for many years the head of REM's Monitoring and Analysis Service, was elected president of the Council. Smederevac was elected unanimously. Some representatives of the group made up of the four Council members elected to that office on the proposal of press and media associations, citizens' associations and other non-governmental organisations stressed that they had agreed to such a compromise vote and to Smederevac's election as president of the Council so that the Council would become functional in good time during the campaign.

As one of the reasons for their support in the election of the president, they also cited the expectation that the monitoring would include precisely those television stations which only after the 2023 elections became the most watched in their category and against which viewers had filed the largest number of complaints during the period when the Council did not exist.

However, no decision to extend the sample was taken at the Council session held on 28 September either, leaving the new influential cable channels outside the monitoring. That decision was justified by the contents of an official note drawn up by the Monitoring and Analysis Service, which stated that the service did not have the capacity to extend the monitoring, and it came only a few hours after the Council members had, according to accounts from some of them, agreed that they would vote to place Informer TV under supervision.

By invoking a lack of capacity at a crucial point in the elections, knowingly abandoning its statutory obligations and refusing to adapt the supervision plan to the real situation on the media market, REM turned election monitoring into a mere formality, leaving the most influential outlets, which potentially generate the largest number of breaches, outside any oversight. In addition, at the first regular session of the Council in its new composition, the report of the Monitoring and Analysis Service on the first fifteen-day snapshot of the monitoring of the media service providers that were under 24-hour supervision during the campaign was also not adopted. One member of the Council stressed that the findings were accurate but that they did not “contribute to a true representation of matters”.

In this way, during a crucial part of the election campaign REM was left with a limited scope of supervision, one not fully adapted to the changes on the media market or to the statutory obligation to adapt monitoring to the specific features and risks of the particular campaign.

Broadcasting without the appropriate licences: the absence of a timely response from REM

Shortly before the start of the election campaign, as part of a six-month promotion Telekom Srbija enabled free, unencrypted reception via the terrestrial DVB-T2 network for around 30 television channels, among them Informer TV, Kurir TV, Blic TV, K1 and Euronews Srbija. The programming of television stations which, according to publicly available information, do not hold REM licences for national terrestrial broadcasting thereby became available also to citizens who receive the television signal via an indoor or rooftop aerial.

In the circumstances of an election campaign, such a change in the availability of television programming raised the question of REM's timely action, since it is precisely this body that is responsible for issuing terrestrial broadcasting licences and for supervising the lawfulness of the provision of media services. Although the REM Council became operational on 22 September with the election of its president, the Regulator did not take the initiative on its own assessment.

Sixteen media and journalists' associations and civil society organisations submitted an initiative to REM on 24 September calling for measures to restore lawfulness in the field of terrestrial broadcasting. Only then did the REM Council consider the matter, at its session of 28 September, and decide to send letters to Telekom Srbija, ETV and RATEL requesting their comments. The Regulator's response thus came after the programming was already available via the terrestrial network, during the election campaign. In such circumstances, the absence of an earlier response from REM raised the question of its ability to react in good time to changes in the way television programming is distributed which may matter for media pluralism and for the equal standing of participants in the electoral process.

CRTA's complaints to REM

After the election of the Council's president, CRTA filed three complaints with REM against the media service provider Insajder tim d.o.o. (Informer TV) over content broadcast during the election campaign.

The complaints concern the programmes “Kolegijum” and “Srpski dnevnik”, both broadcast by Informer TV, and point to patterns of one-sided and negative coverage, hate speech, violations of dignity and privacy, as well as covert pre-election promotion, together with the placing of public officials in a privileged position.

The first complaint concerns the “Kolegijum” programme of 16 September and 1 October, in which Bojan Pajtić and the Student List were linked to violence, civil war and alleged drug use, together with claims about his role in the formation and the activities of the list. CRTA assessed the problematic nature of the content in terms of violations of privacy and dignity, negative campaigning, one-sided reporting and covert pre-election promotion.

The second complaint concerns the “Kolegijum” programme of 30 September, in which an opposition list was presented through claims about violence, revolution and “bloodshed”, with the use of labels such as “fascist methods” and “street terror”. CRTA pointed to hate speech, violations of dignity and the one-sided presentation of political actors, with elements of covert pre-election promotion.

Finally, the third complaint concerns the “Srpski dnevnik” programme of 25 September, in which candidates and supporters of the Student List were presented through a series of insulting and discrediting claims, including links to violence, crime, foreign services and extremist ideologies. CRTA filed the complaint over hate speech, violations of dignity, one-sided negative campaigning and covert pre-election promotion, as well as over the privileged position of public officials in the coverage.

A legal response to attempts to discredit CRTA: a lawsuit and an application for an interim measure

On 6 October 2026 CRTA filed a lawsuit with the Higher Court in Belgrade against the editor-in-chief of the Informer portal for violation of the right to reputation, together with an application for an interim measure prohibiting the republication of the disputed content. The lawsuit was prompted by three Informer posts of 4 October in which CRTA was linked to a recording in which the lawyer Vladimir Tupanjac allegedly instructs students on how to attack the police. In those posts CRTA was described as a “criminal organisation” and an “intelligence and subversion outpost”, with claims that it incites conflict, bloodshed and civil war.

The lawsuit also points to the context of publication, namely the fact that the disputed content was published 20 days before the elections, at a time when CRTA was accredited to observe the electoral process. Given CRTA's role as an independent observation mission, such linking to alleged violence and criminal activity may result in its discrediting and in the erosion of trust in its work during the electoral process. The lawsuit is based, among other things, on the provisions of the Law on Public Information and Media concerning the impermissibility of information that portrays a person in a false light and the duty of journalistic diligence.

The role of Radio Television of Serbia (RTS) in the election campaign

Radio Television of Serbia (RTS) has a dual role in the election campaign: in addition to its duty to provide free and equal presentation of candidate lists, as the public service broadcaster it has a broader duty to inform citizens about the election campaign in an impartial, fair and balanced manner. These duties derive from the Law on Public Service Broadcasters and the Law on the Election of MPs, while RTS has further regulated how they are to be fulfilled in its own Rules on monitoring the election campaign and on the presentation of submitters of candidate lists and candidates. The fulfilment of RTS's statutory duties cannot therefore be assessed solely on the basis of equality in the free slots for presenting candidate lists, but also through the way in which the principles of impartiality, fairness, balance and pluralism are applied in the regular news programming and in debates. It is precisely this content that is of particular importance for informing voters, since the way topics, events and interviewees are selected determines how far different political views will be represented in the public service broadcaster's programming.

Legal framework for the public service broadcaster in the electoral process

The Law on Public Service Broadcasters requires RTS to provide, during the election campaign, free and equal presentation of political parties, coalitions and candidates with confirmed candidate lists. Under the same provision, RTS is required to ensure impartial, fair and balanced presentation of political entities, candidate lists and candidates in its regular news programmes and in special programmes devoted to the campaign.

RTS's duties go beyond the presentation of candidate lists alone. The public interest it serves includes encouraging pluralism of political ideas, without serving the interests of particular political parties, as well as the impartial treatment of political and other issues with the equal confrontation of different views. The law also provides for the possibility of organising radio and television duels, that is, debates on current political issues. The work of the public service broadcaster is based on the principles of truthful, impartial, complete and timely reporting, the independence of editorial policy and pluralism of content and opinion.

In addition, the public service broadcaster, like all other media service providers, is required to comply with the obligations laid down in REM's Rulebook on the manner in which media service providers are to fulfil their obligations during the pre-election campaign. Those obligations include a ban on covert or indirect recommendation of candidate lists and candidates in programming that is not campaign programming, which in particular entails strict adherence to professionalism and objectivity in reporting on the activities of officials, a ban on granting a privileged position to representatives of the authorities, the prevention of manipulative and promotional techniques in news programming, and a complete ban on candidates appearing in entertainment and fiction content or in the role of presenter or journalist during the election campaign. The Rulebook also regulates how the pre-election activities of submitters of candidate lists or of candidates are to be reported from the calling of the elections onwards, which includes ensuring non-discriminatory representation across the whole of the news programming alongside truthful, objective, complete and timely reporting, a ban on reporting on ceremonial events attended by public officials who are at the same time candidates (the opening of facilities and works) in the 30 days before election day, and a ban on publishing negative campaign content.

The agreement on the presentation of submitters of confirmed candidate lists

Article 144 of the Law on the Election of MPs separates the agreement on the number and duration of presentation programmes from the rules for presenting candidate lists, electoral programmes and candidates. For the agreement, the law prescribes a deadline of five days from the entry into force of the decision calling the elections. The agreement is concluded by two representatives each of RTS, the Government and the political parties that have MPs, and the concluded agreement is published on the website without delay.

Since the elections were called on 9 September, the deadline for concluding the agreement expired on 14 September. It was not publicly available whether the agreement had been concluded, nor was any such information published on RTS's website, despite the statutory obligation to publish the agreement. This leaves open the question of how the obligation under Article 144 concerning the determination of the number and duration of programmes was fulfilled.

CRTA submitted a request to RTS for access to information of public importance, seeking a copy of the Agreement on the number and duration of programmes for the presentation of submitters of confirmed candidate lists, information on the representatives of RTS, of the Government and of the parliamentary political parties who took part in concluding it, as well as details of the date it was concluded and published, in accordance with Article 144 of the Law on the Election of MPs. As of the date this report was finalised, CRTA had not received a reply from RTS to the request.

The second obligation under Article 144 concerns the rules for presentation. The law prescribes the range of participants involved in determining them, including the submitters of confirmed candidate lists. RTS's Rules were adopted on 14 September, when only two candidate lists had been confirmed - “Aleksandar Vučić - United Serbia” and “Ivica Dačić - A Factor of Stability”. The other submitters could take part in the procedure only after their lists were confirmed, so their participation in the adoption of the Rules was not possible at the time the Rules were adopted.

The Rules themselves state that RTS determines them with the participation of representatives of the Government, of the parliamentary parties and of the submitters of confirmed candidate lists, but they contain no information on the participation of other submitters of candidate lists in their adoption. Under Article 19, the Rules are delivered to confirmed lists subsequently. At the same time, RTS announced that the draw for the order of presentation would be held after the Republic Electoral Commission (REC) had confirmed all the candidate lists.

Rules on monitoring the election campaign and on the presentation of submitters of candidate lists for the 2026 parliamentary elections

On 14 September 2026 RTS adopted the Rules on monitoring the election campaign and on the presentation of submitters of candidate lists and candidates. They regulate news coverage, free presentation, debates, advertising, the campaign silence and election day.

The Rules require RTS to observe independence, equality and fairness, balance and impartiality in its coverage of the campaign. In its regular news programming RTS is to present participants on an equal footing, while retaining the criterion of the newsworthiness of events, and reporting on the work of state bodies must not be used for political propaganda. The Rules also provide for a right of reply and correction, as well as a restriction on reporting on the promotional activities of public officials who are candidates.

Dedicated slots allow for the free presentation of candidate lists, the order of which is determined by a draw, while panels are excluded. The Rules also specifically regulate debates between representatives of parties and coalitions. Campaign advertising is permitted under equal programming, financial and technical conditions.

During the campaign silence and on election day RTS does not broadcast campaign content or participants' logos and slogans, while information on turnout and on electoral irregularities is published as official data from the competent authorities.

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