Update
Where the UVR Commission stands as the 31 May deadline nears
The UVR Commission is operational. It has adopted its rules of procedure, work plan, budget, and aud...
CRTA+
Voter register audit: only 4 of 69 checks can be performed under current data access
CRTA's June 2026 assessment maps the full audit methodology against the data access actually granted to the Commission and finds that 95% of planned checks cannot be carried out. Full access, required by Article 22j of the UVR Law, has not been provided.
The four aims
AccuracyDo entries match the real, lawful situation?
ResilienceIs the system protected from error and abuse?
EfficiencyAre records kept and updated in time?
AccountabilityCan a fault be traced to its cause?
How the audit creates impact
Findings are not the end point. Each one feeds a step that changes the register and the system around it — and contributes to confidence-building in the UVR.
The audit program at a glance
The structure of the methodology. Colours show whether the procedures in each phase/level can be performed with the current access granted; no part reaches full scope. Each box is clickable — select one to jump to that part of the detailed program below.
full scope — not reached by any partonly the legal review or individual complaint checksnone can run
The access story over time
Across 2026 the Commission’s access has never risen above very limited record-by-record queries. The full access the law provides has not been delivered, while the deadlines and the reporting obligation have continued to run. The graph shows the access actually provided against the full access the law mandates (dashed).
Click to enlarge
Select a point on the timeline for detail.
How much of the audit can be performed
Data access
4%
1%
95%
3checks performable in full
1partially performable
65cannot be performed (of 69)
100%
69checks performable in full
0partially performable
0cannot be performed (of 69)
Select a bar segment or a figure above to list the checks it covers.
3 checks that can be performed in full
2.1.1 Legal review — central-register framework
- Full review of laws, by-laws, arrangements and controls governing the register
2.2.1 Legal review — local-update framework
- Full review of competences, deadlines, remedies, decision trails and controls in updating
2.3.1 Legal review — source-register framework
- Full review of the normative framework governing source registers
1 check that is partially possible
2.4.3 Handling citizen complaints
- Preliminary examination of a complaint’s data
65 checks that cannot be performed
2.1.2 Whole-register quality scan
- Aggregate profile of the register by category
- Outlier number of voters per address / household
- Outlier rate of changes per individual voter
- Identification of missing data
- Logical-consistency checks
- Arithmetic-consistency checks
- Field syntax and meaning checks
- Referential-integrity checks
2.3.2 Quality scan of the source registers
- Aggregate profile of civil, residence and other registers
- Outlier permanent-residence changes
- Outlier temporary-residence changes
- Outlier passivisation changes
- Outlier citizenship changes
- Outlier border-police data
- Outlier civil-registry data
2.3.5 Match register against source records
- Consistency with residence records
- Consistency with civil registries
- Consistency with the citizenship register
- Consistency with the IDP register
- Consistency with legal-capacity, sanctions and military-service records
- Consistency of changes, register vs source
- Statistical analysis of mismatches
2.3.6 Verify against census, address and other registries
- Consistency with census data (SORS)
- Consistency with other central-registry data
- Addresses vs the Address Register (RGA / Post)
- Consistency with household data from other records
- Consistency with other relevant registers
- Spatial clustering of mismatches
2.2.3 Legality of entry and deletion decisions
- Legal validity of the decisions underlying register changes
2.3.3 Legality of the residence basis
- Legal basis for establishing residence, incl. naturalised citizens
2.4.1 Field check — register to citizens
- Verify register entries against citizens’ real circumstances
2.4.2 Field check — citizens to register
- Verify citizens’ real circumstances against the register
2.1.4 Security of the central IT environment
- Access management
- Change controls
- Action logging and audit trail
- Data integrity and quality
- Stability, availability and continuity
- Change and maintenance management
- Legal and organisational maintenance framework
- General security and data protection
2.1.3 Verify register extracts and historical displays
- Process of public display by polling station
- Pre-election closing of the register
- Consistency of displayed data with the register
- Consistency of extracts used with the register
- All current and historical data, by period
2.2.2 Abuse risk in change authorisation
- Map of entry / deletion / amendment rights by authorisation
- Quality of access-log security during updating
2.2.5 Officials’ authority and training
- Legal review of officials’ authorisations
- Process of receiving changes, drafting and forwarding decisions
- Quality of training vs required competences
2.2.6 Resources for updating
- Material and financial resources for updating and how they are used
2.2.7 Integrity of hiring
- Recruitment and engagement of officials who maintain the register
2.2.4 Review of inspection supervision
- The inspection process and follow-up on ordered measures
2.3.7 Security of the source-register IT
- Access management
- Protection against unauthorised changes
- Action logging and traceability
- Data integrity and quality
- Stability and continuity
- Change and maintenance management
- Legal and organisational maintenance framework
- General security and data protection
2.3.4 Officials’ conduct in residence and civil changes
- Recording life-fact changes into source registers
- Recording residence changes
- Dual-citizenship acquisition process
- Data exchange with competent authorities
Only the three legal reviews can be carried out in full, and the first review of citizen complaints only partially — because the register shows a voter’s current data but no history of changes. That is 3+1 of the 69 checks the methodology defines. Every check that requires analysing the register as a whole, cross-referencing it against other registers, auditing changes in the registry, or examining the system’s security — where the great majority of the work lies — cannot be performed.
With the full access the law provides (Art. 22j), all 69 checks across the 21 procedures could be carried out — the audit could be completed as the methodology designed.
The audit program and its coverage
The methodology defines 69 individual checks under 21 procedures. Each row shows the evidence a procedure requires and whether that evidence has been made available. Select any row to see the checks within it.
Detail
Show
| Area 1 — Is the data accurate?From the first signal of an inaccuracy to a confirmed or dismissed conclusion. | ||
| Phase 1 · Find the signals | ||
| 2.1.2Whole-register quality scan | The register analysed as a whole (aggregate access) | ○Cannot be performed 8 |
| 2.4.3Handling citizen complaints | Individual look-up of present data only — no history of changes per voter | ◑Partially 1 |
| Phase 2 · Cross-check the registers | ||
| 2.3.2Quality scan of the source registers | Aggregate view and change history of source registers | ○Cannot be performed 7 |
| 2.3.5Match register against source records | Cross-referencing at scale; citizenship, IDP, legal-capacity, sanctions records | ○Cannot be performed 7 |
| 2.3.6Verify against census, address and other registries | Census (SORS), Address Register, other datasets | ○Cannot be performed 6 |
| Phase 3 · Legal validation | ||
| 2.2.3Legality of entry and deletion decisions | Decision records and supporting documents | ○Cannot be performed 1 |
| 2.3.3Legality of the residence basis | Previous addresses and basis documents | ○Cannot be performed 1 |
| Phase 4 · Field verification (the final step) | ||
| 2.4.1Field check — register to citizens | A representative sample drawn from the full register; field access | ○Cannot be performed 1 |
| 2.4.2Field check — citizens to register | A representative sample; field access | ○Cannot be performed 1 |
| Area 2 — Is the system resilient?Whether the legal, organisational and IT framework prevents, detects and corrects error and abuse. | ||
| Level 1 · The central register | ||
| 2.1.1Legal review — central-register framework | Publicly available legal norms | ●Can be performed 1 |
| 2.1.4Security of the central IT environment | ICT access logs, configuration and change controls | ○Cannot be performed 8 |
| 2.1.3Verify register extracts and historical displays | Historical and change records | ○Cannot be performed 5 |
| Level 2 · Local updating | ||
| 2.2.1Legal review — local-update framework | Publicly available legal norms | ●Can be performed 1 |
| 2.2.2Abuse risk in change authorisation | Access logs and change records | ○Cannot be performed 2 |
| 2.2.5Officials’ authority and training | Internal change records and training documents, held by the authorities | ○Cannot be performed 3 |
| 2.2.6Resources for updating | Internal resource records, held by the authorities | ○Cannot be performed 1 |
| 2.2.7Integrity of hiring | Recruitment / HR records, held by the authorities | ○Cannot be performed 1 |
| 2.2.4Review of inspection supervision | Inspection-supervision reports | ○Cannot be performed 1 |
| Level 3 · The source registers | ||
| 2.3.1Legal review — source-register framework | Publicly available legal norms | ●Can be performed 1 |
| 2.3.7Security of the source-register IT | Access logs and controls of the source systems | ○Cannot be performed 8 |
| 2.3.4Officials’ conduct in residence and civil changes | Change records and records of officials’ actions | ○Cannot be performed 4 |
What this means
A limitation of scope
On the evidence made available, the audit cannot reach a conclusion on the accuracy or integrity of the register. This is a limitation of scope — not a finding that the register is sound, nor that it is flawed, but a record that the checks could not be carried out.
What can be done now
- Legal review of the rules governing the register, at all three levels
- First intake and preliminary review of citizen complaints, one at a time
- Looking up individual records in the register, civil registries and residence records
What is missing
- Any analysis of the register as a whole (no aggregate access)
- The history of changes — basis, date, official, decision number
- Cross-referencing against source and check registers
- System logs and security configuration
- A statistically representative field sample
The methodology’s own threshold. Data from any single register are not sufficient grounds for a conclusion where cross-checking with another register is technically possible. The individual look-ups now available therefore cannot, on their own, meet the standard the Commission set for a finding — they can frame the work, not complete it.
Annex — data access on record
View = can be seen, one record at a time. Aggregate = can be analysed across the register. Verify = can be independently confirmed. No aggregate or verification access has been granted for any category.
| Data / record | View | Aggregate | Verify |
|---|---|---|---|
| Unified Voter Register | |||
| Individual current voter data (name, JMBG, residence, polling station, passivisation, IDP) | Yes | No | No |
| Record of changes (basis, date, official, decision number) | No | No | No |
| Legacy reporting module (missing / incorrect data) | No | No | No |
| ICT system logs (traces of unauthorised access) | No | No | No |
| Source registers | |||
| Current residence — permanent and temporary | Yes | No | No |
| Previous residence; passivisation of addresses | No | No | No |
| Civil registries — births, deaths, marriages | Yes | No | No |
| Citizenship — yes/no search by JMBG | Yes | No | No |
| Citizenship — full records; IDP; legal capacity; prison sanctions | No | No | No |
| Cross-check registers | |||
| Inspection reports; statistics (SORS); address register; pension; health; tax; ID and passport | No | No | No |
