Democracy promotion abroad, barriers at home? The East–West gap in the recognition of citizen election observers across the European Union

Abstract

Many European Union Member States that actively promote democracy and election observation abroad do not legally recognise citizen election observers at home. Drawing on structured comparative data from two large-scale Election Assessment Missions (EAM) conducted by Election-Watch.EU in 2019 and 2014, triangulated with an analysis of OSCE/ODIHR reports, this paper demonstrates persistent inconsistencies in the implementation of OSCE commitments regarding access for election observers in the EU. Based on the EAM’s findings, we identify structural legal barriers and administrative practices that render citizen election observation unrecognised or operationally unfeasible in a majority of EU Member States. Crucially, the data reveal a pronounced asymmetry between “Old” (EU14) and “New” Member States (EU13), with newer members demonstrating significantly higher rates of compliance with OSCE commitments. While only 1 of 14 “Old” Member States provides a legal framework for citizen observation, 8 of 13 “New” Member States do. We situate these findings within debates on democratic conditionality and hypocrisy in democracy promotion, showing how universally formulated norms are implemented asymmetrically. In the context of growing challenges to democratic legitimacy, this research report proposes concrete legal and institutional reforms to harmonise domestic practices with international standards and regional commitments, and strengthen democratic resilience within the EU.

1 Introduction

1.1 The research puzzle

Election observation is a practice that aims to assess the integrity of a key pillar of democracy – the process that selects the political decision-makers, the powerholders, in a state. Election day is generally perceived as the most salient expression of the will of the “demos,” taking on the task of self-government. However, most election observers do not focus solely on Election Day but also cover a wide range of social and political developments over many weeks before and after the elections, for instance, media freedom, campaign finance transparency, and voter registration accuracy. All of these observations cover crucial parts of the electoral cycle (Norris, 2013, 568) and go beyond mere election administration. While many election observation missions (EOMs) consist of international teams sent by multilateral organisations or international non-governmental organisations (NGOs), the vast majority of election observation activities are conducted by domestic, non-partisan NGOs – these local practitioners are usually called citizen election observers.

Overall, since the 1990s, election observation has become an increasingly professionalised practice and an almost universally recognised norm worldwide. In particular, the rise of international election observation is well documented (Bjornlund, 2004; Hyde, 2011; Kelley, 2012). Many election observation organisations emerged with varying track records in evaluating elections (Kelley, 2009) and implementing international standards (Shlyk, 2022). However, the seeming universalisation of election observation has been asymmetric. While a few closed autocracies never accepted election observers in the first place, there is a second group of countries that, so far, have unexpectedly not provided the legal and practical conditions for election observers to operate: Western, “established” democracies. The seeming unidirectional nature of election observers deployed from the “democratic West” to “democratising” countries in the non-Western world has been a source of much criticism in target countries (e.g., Marchesano, 2015, 265; Lidauer et al., 2017; Lidauer and Rabitsch, 2024, 368).

This research report investigates this asymmetry within the European Union (EU) - an actor that is simultaneously one of the world’s largest supporters of international democracy promotion and home to states that lack basic legal provisions for domestic citizen election observers. Comparing citizen election observer access across the EU, this research report demonstrates how legal gaps and policy shortcomings lend credence to frequent accusations that Western election observers promote democratic processes abroad that are not practised at home. Their shortcomings openly contradict EU-level and OSCE commitments on electoral integrity as a strategic priority, such as the European Commission’s, 2023 Recommendation on inclusive and resilient electoral processes, the European Democracy Action Plan (EDAP), the proposed Democracy Shield (European Commission, 2020 and 2025) and Paragraph 8 of the Copenhagen Document 1990 (OSCE, 1990).

By demonstrating intra-EU asymmetry in a concrete policy field, we contribute to scholarship on norm diffusion and conditionality (Kelley, 2004; Schimmelfennig and Sedelmeier, 2004) by analysing the long-term impact of conditionality-driven policy transfer leading to a significant divergence between those countries that needed to comply with OSCE norms to join the EU and those states that did not need to update their legislation. Theories of conditionality, therefore, offer a useful lens for a better understanding of why the “new” EU13 states outperform the “old” EU14 states regarding election observer access. Moreover, we contribute to the debates about hypocrisy in liberal-democratic ordering (Finnemore, 2009; Millar, 2024) and the inconsistencies and tensions between external democracy promotion and domestic practice in donor states, which is best captured by Lincoln A. Mitchell’s concept of the “Democracy Promotion Paradox” (2016), in which he criticises the gap between discourse and practice in the field.

Based on original data from two Election Assessment Missions (EAMs) conducted by Election-Watch.EU in 2019 and 2024 (Election-Watch.EU 2019, 2024), as well as corresponding data from OSCE/ODIHR missions to EU Member States, we investigate whether citizen election observers can gain accreditation and access in the EU in order to carry out their work. We show how uneven recognition in the EU leads to a highly fragmented landscape for citizen election observers: only 9 out of 27 countries recognise domestic election observers in their electoral law, whereas 16 out of 27 recognise international election observers. Hence, the majority of EU countries, and particularly “old” Member States, do not provide sufficient legal and practical conditions for accreditation and access of citizen observers to the electoral process. The Election-Watch.EU’s EAM efforts in gaining accreditation in all EU Member States before the European Parliament elections only succeeded in less than half of the cases (13 out of 27), further underlining the practical and legal hurdles in place, and divergences between the written law and administrative practices. Making voting and counting accessible to the public, as practised as a substitute in many “old” Member States, or the accreditation of observer groups without respective legal frameworks (e.g., Latvia), are insufficient replacements for legal provisions for accreditation. Given these legal and practical asymmetries, we provide policy recommendations to close the legal gaps between the “new” EU13 and the “old” EU14 and increase the democratic credibility of EU countries supporting democracy abroad.

This research report first embeds our empirical data and argument in the literature on citizen election observation, democracy promotion, and membership conditionality. We then present the original data collected in this research project. Based on the empirical findings, we discuss several reform pathways and interpret them in light of ongoing debates about the East–West gap in the EU and membership conditionality.

1.2 Citizen election observers and democracy promotion

International election observation has been on the rise since the end of the Cold War (Kelley, 2012, 17). Originally an unstructured exercise in showing solidarity with countries undergoing democratisation, it has become increasingly professionalised in recent decades (Hyde, 2011, 163–174). Lidauer et al. (2017, 362) describe the objective of international election observation as “providing an independent opinion” on legal, political, administrative, and media-related questions of electoral integrity. Moreover, election observation should serve as a “deterrent measure for potential electoral fraud,” an “incentive for international aid,” and “peer oversight” over reform progress.

Citizen election observation carried out by local actors has followed a similar trajectory. The literature typically associates the National Citizens’ Movement for Free Elections (NAMFREL) in the Philippines with the first large-scale and systematic election observation effort led by civil society actors, which occurred in 1986 and included the creation of a Parallel Vote Tabulation (PVT). Subsequently, local observation became actively supported and subsidised by external democracy promotion actors (Bjornlund, 2004, 211–255). For a long time, citizen election observers have been treated as second-order observers by the international democracy promotion community. As Tuccinardi and Balme (2013, 96) describe, “factors such as lack of resources, limited attention to reporting, poor public outreach strategy, perceived or real political bias, and exposure to infiltration from political groups have often led to mistrust in the work of citizen election observation groups.” International election observers were often perceived to be better equipped and more impartial.

Nevertheless, since the early 2000s, citizen observation has become more prominent on the agenda of democracy promoters. In the widely referred-to standard-setting document in the field that defines central democratic principles, the Declaration of Principles for International Election Observation and Code of Conduct for International Election Observers (OSCE Office for Democratic Institutions and Human Rights, 2005b), which was endorsed at the United Nations (UN) by the European Commission and OSCE/ODIHR, among others, citizen election observation became an explicit demand:

“International election observation missions should advocate for the right of citizens to conduct domestic nonpartisan election observation without any undue restrictions or interference and should in their recommendations address removing any such undue restrictions or interference” (Declaration of Principles, OSCE Office for Democratic Institutions and Human Rights, 2005b, Paragraph 16).

Even before, OSCE/ODIHR made Domestic Election Observation an explicit standard to be assessed by democracy promoters (Copenhagen Document 1990, Paragraph 8), published a “Handbook for Domestic Election Observers” in 2003 (OSCE Office for Democratic Institutions and Human Rights, 2003), and included it as a parameter in all electoral missions sent by the organisation - which contributed to EU candidate states wishing to signal their democratic credentials (Hyde, 2011) to respond to corresponding recommendations (see Appendix I). More recently, and with support of the EU, the UN has explicitly affirmed that citizen election observers qualify as human rights defenders within the meaning of the 1998 UN Declaration on Human Rights Defenders (Lawlor and Voule, 2022).

This reassessment of citizen election observation occurred for four interconnected reasons. First, resources and political space for international election observation have become increasingly constrained. This is evident in the current budgetary downsizing of American election observation institutions such as the International Republican Institute (IRI) and the National Democratic Institute (NDI) (Kine, 2025). Citizen election observer groups, despite their acknowledged limitations, may prove to be more resilient long-term actors in an international environment that is increasingly inhospitable to international democracy promotion.

Second, many citizen election observers have significantly professionalised and systematised their methodological approaches. Similar to international election observation, citizen election observation has been subject to extensive efforts of orchestration and standardisation. Notably, in 2012, citizen election observation groups created the Global Network of Domestic Election Monitors (GNDEM) (2012). They formulated a standard-setting declaration (Declaration of Global Principles) that outlines a common Code of Conduct. Nevertheless, it is important to note that this professionalisation remains uneven across countries and organisations, and that the quality of citizen observation, like that of international observation, varies considerably (Kelley, 2010; Carothers, 1997).

Third, in a time of increasing polarisation and decreasing institutional trust, citizen election observation can be an effective tool for participatory democratic practice. Unlike international election observers, local observers can contribute to long-term trust in the political system by publicly endorsing and participating in genuine electoral processes, criticising shortcomings and fraud, and advocating for electoral reforms.

Fourth, the work of credible, non-partisan election observers can be particularly important in an era of increasing disinformation about electoral integrity and growing concerns about foreign interference. Election observation practices are also being used as tools of disinformation. Prior research has shown that parallel “shadow observation groups” (Debre and Morgenbesser, 2018; Pollak, 2025) provide alternative assessments of electoral integrity and can be effective in shaping public legitimacy of fraudulent elections if not countered by recognised observer organisations. Because such “shadow observation groups” may also take the form of domestic citizen observation organizations, and because they can be used to contradict the findings of non-partisan observers, it is essential to have clear legal standards and transparent administrative procedures to accredit observers. Such procedures are what allow credible, non-partisan citizen observer groups to serve as a meaningful source of democratic resilience.

Nevertheless, citizen election observation often remains impossible altogether, particularly in Western countries that played a central role in shaping democracy promotion policies. In many of these cases the obstacle is the legal architecture itself: without legal framework and formal accreditation of citizen observers, there is no recognised path and can be used to contradict the findings of non-partisan observers, it is essential to establish clear legal standards and transparent administrative procedures for accrediting for independent, non-partisan actors to gain access in the first place, let alone to receive training from electoral management bodies where appropriate. Accreditation and legal recognition are therefore not a formality but the precondition for access and legal certainty that quality observation requires.

1.3 EU membership conditionality, rule changes, and hypocrisy

Studying the asymmetries in citizen election observation across EU countries is particularly important, given the EU’s confident and central role in international democracy promotion and its recent emphasis on democratic and electoral resilience (the European Democracy Action Plan, the Democracy Shield, etc.). Given the arguments in favour of citizen election observation and the active international promotion of the practice, the question arises as to the extent to which European support for election observation is consistently implemented internally.

Does the EU live up to its own standards?

As we will show, a clear pattern emerges when comparing EU Member States that recognise observers with those that do not - the “New” Member States clearly outperform the “Old” Member States regarding election observer access. However, how can we make sense of the divergence between EU13 and EU14 in theoretical terms? In her seminal article on membership conditionality, Judith Kelley (2004) investigated how international institutions influence domestic policies in the 1990s. She finds that, in contrast to liberal expectations of norm diffusion, socialisation-based methods of promoting norms were not very effective in changing states’ behaviour. She concludes that membership conditionality was the defining political mechanism that triggered change in domestic policies, even in the face of domestic opposition. In practice, European organisations used conditionality to shape prospective Member States in line with their ideals. Similarly, Schimmelfennig and Sedelmeier (2004) find that the EU is most successful in transferring laws and policies at the moment of accession. Comparing different countries shows how Central and Eastern European candidate countries accepted and adopted rules through what they call the “external incentives model of governance,” which includes democratic conditionality.

However, the rules of accession have changed over time. For example, citizen election observation has not been considered a parameter for democratic conditionality, or a credible signal for democratisation (Hyde, 2011) until the mid-1990s, as the lack of coverage of the issue in early OSCE election observation reports shows. In 1997, the OSCE/ODIHR mission to Croatia expressed “serious concern” about the “absolute exclusion of domestic non-partisan observers from the election process,” which ran “contrary to the spirit of the Copenhagen Document” (OSCE Office for Democratic Institutions and Human Rights, 1997). Given this OSCE assessment, a new election law was swiftly created and implemented by 1998 (OSCE Office for Democratic Institutions and Human Rights, 2000). Similarly, a law concerning observers was introduced in Romania in the early 2000s, following repeated criticism from OSCE/ODIHR missions and just in time before EU accession in 2007 (OSCE Office for Democratic Institutions and Human Rights, 2001; OSCE Office for Democratic Institutions and Human Rights, 2005a).

Given the change of norms that are externally promoted as standards of liberal-democratic governance, one might expect that Member States also adopted the norms internally, following the logic of socialisation-based models. Empirically, this paper shows that this was not the case in the field of citizen election observation, leading to a significant gap between external policies and domestic practice. We argue that the changes in the external assessment of liberal democracy over time, combined with the lack of policy tools to impact reform in Member States and the strength of conditionality strategies, may have led to a Democracy Promotion “Paradox” (Mitchell, 2016) in the European citizen election observation landscape. A significant East–West gap appeared between EU13 and EU14. Importantly, this would imply that membership conditionality may, in the long run, produce unintended consequences and may lead to divergent constructions of liberal-democratic rules, as well as increasingly evident hypocrisies between the so-called “established” democracies of the EU and the “transitioning” EU accession countries with a communist past.

2 Methods

Election-Watch.EU’s Election Assessment Mission (EAM) to the European Parliament Elections 2024 offered a unique empirical opportunity. A team of 77 election experts, working in all 27 EU Member States in cooperation with 10 partner citizen observer organisations, conducted desk research, an analysis of legal frameworks, and semi-structured interviews with electoral management body (EMB) officials and civil society representatives. Expert interviews and written exchanges with EMB representatives and civil society stakeholders served two distinct functions. For the majority of countries, they provided contextual and background information to support desk-based legal analysis. In a small number of cases where publicly available legal documentation was limited or ambiguous – for example, where observer access rests on administrative practice rather than a statutory framework – expert input also constituted part of the direct evidentiary basis for coding decisions; such cases are explicitly flagged in Annex I. Interviews and written exchanges were conducted only where institutions were available and willing to engage within the timeframe of the research.

In the framework of the mission,http://election-watch.eu/ Election-Watch.EU was seeking election observer accreditation from EMBs in all Member States. This generated direct first-hand evidence of the practical conditions for observer access. The EAM data are supplemented by findings from Election-Watch.EU’s earlier EAM to the 2019 European Parliament Elections, which followed a similar methodological framework (but with 28 Member States including the United Kingdom).

The 27 EU Member States were coded according to six binary variables (yes = X, no = blank). (1) Whether domestic law contains explicit legal provisions for international election observation. (2) Whether formal accreditation procedures for international election observers exist in practice. (3) Whether domestic law contains explicit legal provisions for citizen election observation. (4) Whether formal accreditation procedures for citizen election observers exist in practice. (5) Whether Election-Watch.EU successfully obtained accreditation during the 2024 EAM. (6) Whether voting and counting at polling stations are open to the general public without formal observer accreditation. These variables were selected to capture both the legal dimension (variables 1, 3, 6) and the practical implementation dimension (variables 2, 4, 5) of observer access, since our prior experience across both EAMs indicated that legal frameworks and EMB practice sometimes diverge. You can find detailed information about methodological questions, operationalisation, coding, and primary sources in Appendix I.

3 Results

Tables 1 and 2 present the comparative findings for EU14 and EU13 Member States. They illustrate a highly fragmented landscape for citizen election observers across the EU – one in which the formal recognition of observers, the existence of accreditation procedures, and the practical conditions diverge substantially.

Among the EU14 states, only Finland provides a comprehensive legal framework that recognises both international and citizen election observers and has functioning accreditation procedures. Austria, Belgium, and Luxembourg recognise international observers in law, but have no equivalent provisions for citizen election observers, with Austria moreover explicitly limiting international observation to the OSCE. Greece, Ireland, and Portugal have no legal provisions for election observers. The remaining EU14 states, Denmark, France, Germany, Spain, and Sweden, allow public access to voting and counting at polling stations but have no provisions for election observers. Only one EU14 Member State (Finland) provides a legal framework for citizen election observation, and accredited Election-Watch.EU in 2024.

The contrast between EU14 and EU13 is striking. Eight states of the EU13, Bulgaria, Croatia, Estonia, Lithuania, Poland, Romania, Slovakia, and Slovenia, provide legal recognition of citizen election observers (6 out of 13 have both a law in place and accreditation procedure, see Table 2), and Election-Watch.EU was accredited in 11 out of 13 Member States in 2024. Latvia, Malta, and Cyprus present the distinctive borderline cases further discussed in Annex I: they have practical accreditation procedures for observers in place (and accredited Election-Watch.EU), yet neither has a legal basis for this practice. The Czech Republic and Hungary legally recognise international observers and granted Election-Watch.EU accreditation in 2024, but it has no provisions for citizen election observers. Estonia and Slovakia have legal provisions for both categories, but lack formal accreditation procedures.

The geographical distribution of these findings (Figure 1) illustrates the asymmetry and East–West gap highlighted by our analysis. Many more EU13 states are at the compliant end of the spectrum, while the EU14 states are significantly less compliant. This pattern is consistent with the conditionality argument advanced above. EU13 states included election observation in their legal frameworks during a period when citizen election observation was already an explicit component of democratic conditionality, while EU14 states joined the EU before this norm was consolidated and faced no equivalent external pressure to update their legislation.

Figure 1

4 Discussion – legal asymmetries in citizen observation and the longue-durée of membership conditionality

The original data from Election-Watch.EU’s Election Assessment Missions in 2019 and 2024 show how many EU Member States fall short of international and regional commitments in the domain of election observation. While actively supporting democracy promotion and election observation abroad, the majority of EU Member States still lack the legal provisions and accreditation procedures to enable election observers to do their work in their own countries. Our central finding is striking: only 7 Member States fully recognise both domestic and international election observation, with corresponding accreditation procedures, and only 9 have legislation specifically providing for citizen election observers. The majority of Member States fall short of the OSCE commitments that they have formally endorsed.

Our theoretically most significant finding is the pronounced EU13/EU14 asymmetry. Among the seven countries that fully comply with OSCE observer commitments, six are EU13 states (legal recognition and accreditation procedure). While only 1 out of 14 “Old” Member States provides a full legal framework for citizen observation, 8 out of 13 “New” Member States do. We argue that this pattern is best understood through the lens of democratic membership conditionality (Kelley, 2004; Schimmelfennig and Sedelmeier, 2004): EU13 states institutionalised observer-friendly legal frameworks as part of the democratisation requirements attached to EU membership, in a period when citizen election observation had already become an explicit standard of democratic governance (e.g., enforced through OSCE assessments). EU14 states, having joined before this norm was consolidated, faced no equivalent external incentive to update their legislation. In the absence of such pressure, they did not. This finding also speaks to the durability of conditionality-induced change and the limits of socialisation-based models of norm diffusion in the absence of ongoing incentive structures.

If the EU13/EU14 gap reflects the long-term effects of democratic conditionality in candidate countries, with newer Member States institutionalising observer frameworks as part of democratisation requirements that older members never faced, then the barriers to reform in EU14 states are unlikely to be primarily technical. They are more plausibly rooted in institutional inertia, limited domestic demand for reform, and the absence of the external incentive structure that conditionality provided. Given the lack of top-down mechanisms to drive reform, this research report aims to ground and advance the debate on citizen observation and to highlight the underlying hypocrisies of the existing system – particularly regarding the role of the EU14.

The findings also speak to debates about the “Democracy Promotion Paradox” (Mitchell, 2016) and to the broader literature on hypocrisy (Finnemore, 2009; Millar, 2024). The EU’s simultaneous external championing and internal neglect of citizen election observation is not a minor inconsistency - it actively undermines the EU’s democratic credibility. Closing these legal gaps would therefore serve not only the immediate goal of democratic resilience but the broader goal of credible European norm leadership in the world.

One important limitation is built into our results. Our coding only captures whether citizen observers are legally recognised and can be accredited – it does not capture which observation organisations successfully claim that status. Importantly, legal recognition alone is not sufficient. An overly permissive framework grants non-partisan observers access to the electoral system, but potentially also opens it to malign actors. Where accreditation is available, partisan or deliberately deceptive “shadow observers” may seek the same recognition as genuine non-partisan observers. Electoral management bodies (EMBs) often lack clear, codified criteria for distinguishing them (Debre and Morgenbesser, 2018; Pollak, 2025). Thus, expanding legal recognition needs to encompass robust, principled accreditation. Recent efforts to design reliable observer accreditation procedures, such as those model observer accreditation procedures drafted by Election-Watch.EU – consulted in an expert group meeting in 2026 - are crucial to tackling this problem.

Nevertheless, the problem of “shadow observers” clearly complicates the interpretation of our results as a simple ranking, where more recognition is unambiguously “better.” It also impacts our recommendations - not only should citizen observers be recognised (4.1), but this recognition must also be based on the substantive standards of independence and impartiality set out in the Declaration of Principles (OSCE Office for Democratic Institutions and Human Rights, 2005b) (4.3).

5 Conclusion – reform pathways and recommendations

Our data shows that citizen election observation is still insufficiently recognised in the European Union - and in particular in the “old” Member States. Given these findings, we conclude by presenting three recommendations to address these shortcomings and create opportunities to close the legal gaps and enhance European democratic credibility in the world. In the current geopolitical climate, where democratic norms are openly contested and illiberal governance models are increasingly normalised, the institutionalisation of independent citizen election observation serves as a critical democratic safeguard. It strengthens societal resilience against autocratisation, mitigates the risks of politicised electoral administration, and reinforces Europe’s commitment to pluralism and the rule of law. We discuss three recommendations in turn.

5.1 Introduce legislation to recognise and accredit citizen election observers

Only 9 out of 27 Member States have corresponding legislation which foresees citizen election observation. In Latvia and Malta, accreditation procedures exist in the absence of corresponding legislation. Some of the 18 Member States, with no legal provisions for citizen election observation, recognise international election observers (Austria, Belgium, Czechia, Italy, Luxembourg, Netherlands). This includes closing the legal gap in countries where de facto accreditation of observer groups co-exists with the absence of legal provisions (in Cyprus, Latvia, and Malta).

A clear legal framework governing the accreditation of citizen election observers is essential to safeguard the integrity and credibility of electoral processes. Formalised and transparent accreditation mechanisms, anchored in internationally recognised standards (such as the Declaration of Principles, OSCE Office for Democratic Institutions and Human Rights, 2005b), enable EMBs to better distinguish bona fide, non-partisan observers from actors pursuing partisan, disruptive or deceptive agendas, including so-called “shadow” observation initiatives that may undermine public confidence (Debre and Morgenbesser, 2018).

5.2 Introduce legislation to recognise and accredit international election observers

As of 2024, Cyprus, Denmark, France, Germany, Greece, Ireland, Latvia, Malta, Portugal, Spain, and Sweden have not introduced such legislation (11 out of 27), while other Member States have limited such provisions to OSCE observers (Austria, Italy). Despite legal provisions, Belgium, Estonia, and Slovakia have no accreditation procedures for international election observers, but usually provide accreditation to observer organisations upon request. In this context, we recommend clarifying, or explicitly abolishing, the distinction between “international” vs. “citizen” election observation in legal frameworks, if there are any to be made. The EAM findings show that, in many countries, a practical distinction is made but is often blurred and applied in a rather arbitrary manner.

A constructive approach can be found in Finland, where no formal distinction is made between international and citizen election observers in accreditation procedures. Instead, the Ministry of Justice recognises observer organisations based on adherence to established principles of impartial and professional observation. Accreditation is accompanied by structured briefings, ensuring both transparency and preparedness. This model demonstrates that observer recognition can be grounded in objective standards of independence and professionalism rather than formal categorisation, thereby promoting equal and reliable access to the electoral process while safeguarding its integrity.

5.3 Ensure accreditation procedures comply with democratic principles and cover the full electoral cycle

Legal provisions are necessary but not sufficient. Accreditation itself should be grounded in law, applied non-discriminatorily, and designed to be transparent, proportionate, and accessible. Procedures that are overly restrictive, discretionary or bureaucratic risk becoming instruments of exclusion rather than safeguards of integrity. In legal systems where de facto accreditation practices exist in the absence of clear jurisdiction, the resulting legal ambiguity should be addressed to ensure predictability, equal treatment, and protection against arbitrary decision-making. Therefore, properly designed accreditation systems serve a dual function: they protect the electoral process from manipulation by partisan actors while ensuring that genuine citizen election observers can contribute to democratic accountability. Most critically, the common EU14 practice of substituting public access to polling stations for formal observer accreditation must be recognised for what it is: an inadequate alternative that does not enable the systematic, legally protected observation of the full electoral cycle. Election observers require reliable access to EMBs and campaign finance documentation in the weeks before Election Day, the ability to deploy coordinated teams across multiple polling stations simultaneously, and the legal protections that accredited status provides (Norris, 2013).

Addressing these gaps connects directly to the hypocrisy argument developed in this paper. It is precisely in these countries - Belgium, Denmark, France, Germany, Spain, Sweden – where the contrast between active support for election observation abroad and the absence of adequate domestic frameworks is most visible and most damaging to the EU’s democratic credibility.

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