The new Law on the Financing of Political Entities and Election Campaigns significantly improves the formal framework and the visibility of financial flows, but it does not strengthen substantive accountability or institutional oversight. This is the conclusion of an analysis of the law’s compliance with the recommendations of the OSCE/ODIHR Mission, conducted by the Association for Responsible and Sustainable Development (UZOR).

The aim of the analysis was to determine to what extent the new legal framework adopted in 2025 corresponds to ODIHR’s recommendations contained in the final reports on the parliamentary and presidential elections held between 2020 and 2023.

The findings show that the new law represents a notable formal improvement compared to the previous legislation, particularly in the areas of transparency of financial flows, regulation of digital political advertising, regulation of third-party campaigning, and more precise reporting on funds allocated to women’s organizations within political entities. In this way, a significant portion of ODIHR’s recommendations related to enhancing the publicity and availability of campaign finance data has been addressed.

However, the analysis indicates that the law still does not ensure full compliance with international standards. Of particular concern is the absence of a system for systematic and electronic cross-checking of donors and related persons, which has been one of ODIHR’s longest-standing and most important recommendations.

In the field of political advertising, the new law recognizes digital campaigning and introduces an obligation to report expenses incurred online and on social media, which represents a significant normative advance. Nevertheless, the lack of a clear methodology for data collection, the limited capacity to oversee global platforms, and the absence of a requirement that promotional materials include information on the заказилац and payer of the advertisement leave room for inconsistent implementation in practice.

With regard to the financing of women’s organizations within political entities, the law introduces new obligations concerning the regular transfer of funds, their public disclosure, and special reporting on how the funds are spent. Although these solutions improve formal transparency, the absence of appropriate sanctions for misuse of funds significantly limits their effectiveness and leaves room for abuse.

This analysis was prepared within the project “Electoral reform in focus: Time is now!”, implemented by the Association for Responsible and Sustainable Development (UZOR) in cooperation with the Centre for Democratic Transition (CDT) and the Association of Youth with Disabilities of
Montenegro (UMHCG), with financial support from the European Union, through the EU Delegation to Montenegro, and co-financing from the Ministry of Public Administration.