Serbia, Early Parliamentary Elections, 25 October 2026: Needs Assessment Mission Report

Office for Democratic Institutions and Human Rights REPUBLIC OF SERBIA ANTICIPATED EARLY ELECTIONS 2026 ODIHR NEEDS ASSESSMENT MISSION REPORT 6 - 10 July 2026 Warsaw 30 July 2026

TABLE OF CONTENTS I. INTRODUCTION .......................................................................................................... 1 II. EXECUTIVE SUMMARY ............................................................................................ 1 III. FINDINGS ....................................................................................................................... 4 A. B ACKGROUND AND POLITICAL CONTEXT ....................................................................... 4 B. L EGAL FRAMEWORK AND ELECTORAL SYSTEM .............................................................. 6 C. E LECTION ADMINISTRATION ........................................................................................... 8 D. V OTER REGISTRATION .................................................................................................... 9 E. C ANDIDATE REGISTRATION .......................................................................................... 10 F. E LECTION CAMPAIGN ................................................................................................... 10 G. P ARTY AND CAMPAIGN FINANCE .................................................................................. 11 H. M EDIA........................................................................................................................... 12 I. E LECTORAL DISPUTE RESOLUTION ............................................................................... 15 J. P ARTICIPATION OF NATIONAL MINORITIES .................................................................. 15 K. E LECTION OBSERVATION .............................................................................................. 16 IV. CONCLUSIONS AND RECOMMENDATION ........................................................ 17 ANNEX: LIST OF MEETINGS ........................................................................................... 18

REPUBLIC OF SERBIA ANTICIPATED EARLY ELECTIONS 2026 ODIHR Needs Assessment Mission Report I. INTRODUCTION Following the letter of the Speaker of the National Assembly of the Republic of Serbia of 23 June, in anticipation of an official invitation to observe anticipated elections in the Republic of Serbia in 2026, as indicated by recent public statements of senior state officials, and in accordance with its mandate, ODIHR deployed a Needs Assessment Mission (NAM) from 6 to 10 July 2026. The ODIHR NАМ included Mr. Ülvi Akhundlu, Deputy Head of the ODIHR Election Department, and Dr. Martina Barker-Ciganikova, ODIHR Election Adviser. The purpose of the mission was to assess the pre-election environment and the preparations for the elections. Based on this assessment, the NAM should recommend whether to deploy an ODIHR election-related activity for the forthcoming elections, and if so, what type of activity best meets the identified needs. Meetings were held with officials from state institutions, as well as with representatives of political parties, media, civil society, academia, and international organizations. A list of meetings is annexed to this report. ODIHR expresses its appreciation to the authorities of the Republic of Serbia for their close co- operation and for facilitating the deployment of the NAM at an early stage of the electoral process, before the formal calling of the elections, enabling an early assessment of the pre-election environment and timely preparations for a possible ODIHR election observation activity. ODIHR would like to thank the Ministry of Foreign Affairs and the OSCE Mission to Serbia for their assistance and co-operation in organizing the NAM. ODIHR would also like to thank all of its interlocutors for taking the time to meet with the NAM and share their views. II. EXECUTIVE SUMMARY At the time of the ODIHR NAM, the date and type of the forthcoming elections had not yet been officially announced, although repeated public statements by the president and several senior state officials consistently indicated that early elections would be held later in 2026. The political landscape changed significantly following the student-led protests and broader civic mobilization across the country triggered by the collapse of the railway station canopy in Novi Sad in November 2024, killing 16 people. The forthcoming elections are expected to take place in a highly polarized political and social environment, with many ODIHR NAM interlocutors expressing concerns regarding increasing political tensions, the exercise of fundamental freedoms, declining public trust in state institutions, and the risk of post-election disputes and violence. The elections will also take place against the backdrop of Serbia’ s long-standing European Union accession process. The election-related legal framework has undergone further revision since the 2023 parliamentary elections, including amendments addressing a number of previous ODIHR recommendations by introducing a periodic independent audit of the voter register, mandatory training and certification of election officials, revised rules on candidate registration and electoral dispute resolution, and changes to the campaign finance framework. At the same time, several longstanding ODIHR recommendations remain unaddressed or only partially addressed, particularly with regard to

Republic of Serbia Page: 2 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report safeguards against the misuse of administrative resources, effective measures to prevent intimidation and undue pressure on voters, transparent and proactive campaign finance oversight, and balanced media coverage. While the authorities emphasized their continued commitment to electoral reform and the implementation of all ODIHR recommendations, many ODIHR NAM interlocutors expressed serious concerns regarding both the process and substance of the reforms, describing them as fragmented, selective and insufficiently inclusive, while questioning whether the reforms would address longstanding systemic electoral concerns and be implemented in good faith. The elections are administered by a three-tier structure comprising the Republic Electoral Commission (REC), local electoral commissions and polling boards. Electoral preparations are ongoing despite the uncertainty surrounding the timing and type of the elections. The REC expressed confidence in its preparedness to administer the elections, while noting that the recent introduction of a mandatory training system, combined with the compressed timelines applicable in the event of early elections, may pose implementation challenges. Many ODIHR NAM interlocutors, however, expressed concerns regarding the political neutrality of the election administration at all levels and the transparency and integrity of the electoral process, citing, among others, allegations of pressure on voters, voter tracking and the compilation of parallel voter lists, as well as irregularities and incidents of violence. Voter registration is passive and the Unified Voter Register (UVR), maintained by the Ministry of Public Administration and Local Self-Government, currently contains 6,439,075 registered voters. In line with a longstanding ODIHR recommendation, the 2025 amendments introduced measures aimed at enhancing the transparency of voter registration and established an independent Audit Commission to periodically review the accuracy of the register. While the authorities considered the Commission operational and expected the audit to be completed within the statutory deadline, many ODIHR NAM interlocutors questioned whether delayed access to historical and aggregated data and the limited time available would allow the audit to produce meaningful results before the elections. The continued disenfranchisement of persons deprived of legal capacity by a court decision remains contrary to international standards. Citizens eligible to vote may stand for presidential and parliamentary elections. Presidential candidates and parliamentary candidate lists may be nominated by political parties, coalitions and groups of citizens, and must be supported by 10,000 voter signatures. The REC is responsible for verifying support signatures and registering candidates and candidate lists. In line with a previous ODIHR recommendation, the May 2026 amendments allow voters to support more than one candidate list. Several ODIHR NAM interlocutors expressed concern that allowing voters to support multiple candidate lists could facilitate the registration of a larger number of so-called “phantom” candidate lists, referring to allegations of similar practices during previous elections although the amendment itself does not alter the legal criteria for candidate registration. The law requires a 40-per cent gender quota on the lists. Women hold 93 out of 250 seats (37 per cent) in the outgoing parliament, and 9 of the 30 current ministers are women. However, women remain underrepresented in all other elected and appointed offices, especially at the local level and in party leadership positions. The 2026 amendments to the campaign finance legislation establish a Women’s Political Participation Fund, with funding allocated to electoral lists on which women obtain more than 40 per cent of mandates. The official election campaign begins on the day elections are called and ends 48 hours before election day. The legal framework provides for equal campaigning opportunities for electoral contestants, while allowing most public officials to continue performing their official duties and engage in campaign activities. The forthcoming campaign is expected to take place in a highly

Republic of Serbia Page: 3 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report polarized environment, with the emergence of the student movement introducing a new political actor. Many ODIHR NAM interlocutors raised concerns regarding the significant disparity in resources available to electoral contestants, the potential misuse of administrative resources, pressure on public sector employees and voters, and increasingly confrontational, and at times aggressive, political discourse, including hate speech and online abuse, particularly targeting women. Online campaigning is expected to play a significant role, while the lack of a comprehensive regulatory and oversight framework, together with risks related to foreign and domestic information manipulation (FIMI/DIMI), were identified by many interlocutors as particularly challenging. The amended Law on Financing Political Activities, adopted on 9 July 2026 under an urgent procedure, introduces campaign expenditure limits for the first time, establishes a legal framework for third-party campaigning, strengthens campaign finance reporting and transparency requirements, and expands the supervisory powers of the Agency for Prevention of Corruption (APC), thereby addressing a number of previous ODIHR recommendations. At the same time, several longstanding ODIHR and GRECO recommendations remain unaddressed, including those concerning the campaign expenditure ceilings, proportionate and dissuasive sanctions, proactive oversight, and safeguards against the misuse of administrative resources. While the APC expressed confidence in its preparedness to implement the amended legal framework, many ODIHR NAM interlocutors continued to question the transparency of political and campaign finance and the effectiveness of the APC’s oversight and enforcement, particularly its ability to proactively detect and address violations. The legal framework requires broadcasters to provide balanced election coverage and equal conditions for electoral contestants. Many ODIHR NAM interlocutors expressed concerns regarding media pluralism, editorial independence and the implementation of the legal framework governing election coverage in an increasingly polarized media environment. Interlocutors also described a deterioration in the safety and working conditions of journalists, referring to intimidation, threats, attacks, online harassment, economic pressure on independent media, and a climate of impunity for attacks against journalists. The composition and effective functioning of the Regulatory Authority for Electronic Media (REM) continued to be identified as a matter of particular importance, including in the context of Serbia’ s EU accession process. On 10 and 11 July 2026, following the National Assembly’s adoption of an authentic interpretation of the Law on Electronic Media, four previously elected members announced that they would take up their functions, paving the way for the REM Council to resume its work. Voters, candidates and submitters of candidate lists are entitled to challenge election-related decisions, actions and omissions before the election administration and the courts. The May 2026 amendments to the Law on the Constitutional Court introduced shorter deadlines for certain procedural steps, a 30-day deadline for deciding electoral disputes and extended the timeframe for holding repeat elections following the annulment of election results. The Administrative Court informed the ODIHR NAM that election-related cases continue to place a significant additional burden on the Court during electoral periods without a corresponding increase in human resources. While representatives of the judiciary and prosecution expressed confidence in the legal framework and reiterated their commitment to resolving election-related disputes independently and fairly, many ODIHR NAM interlocutors voiced limited trust in the impartiality of the adjudicating bodies, citing concerns regarding the consistency and timeliness of decisions and the handling of alleged election- related violations. The Constitution guarantees persons belonging to national minorities the right to participate in political life, including the rights to vote and stand for election. In line with a previous ODIHR recommendation, the May 2026 amendments further clarify the criteria for the registration of national minority electoral lists and strengthen safeguards against misuse of the preferential electoral

Republic of Serbia Page: 4 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report framework. Several ODIHR NAM interlocutors nevertheless expressed concern that the special provisions applicable to national minority lists could still be misused by political entities not genuinely representing national minorities. The legal framework provides for citizen and international election observation, guarantees accredited observers access to all stages of the electoral process and, following the 2025 amendments, grants citizen observers access to voter registration data. Several civil society organizations (CSO) informed the ODIHR NAM of their intention to conduct long-term and election-day observation. At the same time, many ODIHR NAM interlocutors reported continued pressure on CSOs and observer organizations in particular, fundraising challenges, concerns over the deployment of politically biased or non-genuine observers, and the operational challenges created by the uncertainty surrounding the timing of the elections. All ODIHR NAM interlocutors welcomed the deployment of an ODIHR election observation activity and strongly emphasized the importance of a large-scale, long-term and country- wide presence. Many considered that an independent and impartial assessment by ODIHR would be particularly valuable in the highly polarized political and social environment surrounding the forthcoming elections, while several also noted that a robust international observation presence could help increase public confidence in the electoral process, reduce tensions, deter potential irregularities and election-related violence. Representatives of the authorities likewise welcomed an ODIHR observation activity, offered their full co-operation and underlined that it would enhance the transparency and credibility of the electoral process. ODIHR NAM interlocutors identified a number of aspects for assessment by an ODIHR election observation activity, including the implementation of the recently amended legal framework, the work of the election administration, the voter register and its ongoing audit, candidate registration, conduct of campaign, including online, campaign finance, media coverage and regulation and election-day procedures. They also highlighted allegations of vote-buying, the potential misuse of administrative resources and intimidation and undue pressure on voters as meriting further attention . Based on this, the ODIHR NAM recommends the deployment of an Election Observation Mission (EOM) to observe the forthcoming elections. In addition to a core team of analysts, ODIHR will request the secondment by OSCE participating States of 32 long-term observers to follow the electoral process throughout the country, as well as 300 short-term observers to observe election-day procedures. In line with ODIHR’s standard methodology, the EOM will include a media monitoring component, and will assess the campaign environment and activities across traditional media, online outlets, and social media platforms. The mission will also assess the institutional preparedness and effectiveness in identifying and responding to disinformation, misinformation, and potential foreign and domestic interference, as well as existing co-operation mechanisms with social media platforms. III. FINDINGS A. B ACKGROUND AND POLITICAL CONTEXT At the time of the ODIHR NAM, the date and type of the forthcoming elections had not yet been officially announced. Nevertheless, repeated public statements by President Aleksandar Vučić, as well as other senior state officials, consistently pointed to the likelihood that early elections would be called. On 27 June, President Vučić publicly announced his intention to resign in the coming weeks. During the ODIHR NAM, he subsequently stated that early parliamentary elections would be held first later in 2026, followed by an early presidential election. A number of ODIHR NAM interlocutors

Republic of Serbia Page: 5 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report noted that the absence of an official decision on the timing and type of the elections had created uncertainty and complicated preparations by electoral stakeholders, including opposition political parties, civil society organizations and citizen observer groups. The two previous parliamentary elections, held in April 2022 and December 2023, were also early elections. The Serbian Progressive Party (SNS) has remained the dominant political force since coming to power in 2012, with President Aleksandar Vučić continuing to play a central role in the country’ s political life. Following the 2023 early parliamentary elections, the SNS-led coalition retained a parliamentary majority, while several opposition parties and minority representatives are also represented in the 250-member National Assembly. 1 The political landscape changed significantly following the student-led protests and broader civic mobilization across the country triggered by the collapse of the railway station canopy in Novi Sad in November 2024 killing 16 people. 2 Prime Minister and SNS President Miloš Vučević subsequently resigned in January 2025, leading to the formation of a new government on 16 April 2025 under Prime Minister Đuro Macut. The student movement has emerged as an influential actor in the public sphere and has significantly shaped pre- electoral political discourse, prompting established opposition parties to adapt their strategies and positioning in the evolving political environment. The forthcoming elections will also take place against the backdrop of Serbia’ s continued efforts towards European Union accession. 3 The authorities reiterated their firm commitment to implementing ODIHR electoral recommendations as part of broader reforms and conducting democratic elections in line with Serbia’ s international obligations and OSCE commitments. At the same time, the ODIHR NAM noted that the forthcoming elections are expected to take place in a highly polarized political and social environment, where meaningful political dialogue and cross-party co-operation remain limited. 4 Many interlocutors considered that the student-led protests have further deepened divisions between the authorities and significant segments of society, including students, academia, civil society and independent media. Interlocutors also raised concerns about the environment for the exercise of fundamental freedoms, including the freedoms of peaceful assembly and expression, 5 as well as declining public trust in state 1 There are 18 parliamentary groups following the 2023 early parliamentary elections. 2 The student-led protest movement initially focused its demands on accountability, anti-corruption and institutional reforms. From May 2025 onwards, the movement also called for early parliamentary elections. 3 According to the European Commission, Serbia is evaluated against four political priorities: judicial reform, media freedom, the electoral framework and Serbia’s alignment with the EU’s Common Foreign and Security Policy. In early July, the European Commission has recommended that EU Member States approve the opening of Cluster 3 in Serbia’s accession negotiations this month, arguing that although none of the key political priorities has been fully completed, sufficient progress has been achieved for the process to move forward. However, the proposal did not secure the unanimous support of EU Member States required to open a negotiating cluster, and Cluster 3 was not opened in July 2026. 4 On 17 July, the President posted a video on Instagram inviting all of his political opponents to dialogue ahead of the elections. President Vučić has previously issued similar calls for dialogue, which opposition representatives have consistently dismissed as tactical initiatives. 5 The 2025 European Commission Serbia Report notes with respect to freedom of expression that “the environment for media and its free, independent and professional operation is constrained”. Regarding freedom of peaceful assembly, it states that “independent bodies have issued only little, or late, public reaction to human rights violations in the context of the protests. While freedom of assembly was generally ensured and protests allowed to take place, the safety of participants was not always guaranteed, and several violent incidents against demonstrators and journalists occurred, with reported cases of excessive use of force by the police”. See also the 2025 European Commission Rule of Law Report Country Chapter on the rule of law situation in Serbia.

Republic of Serbia Page: 6 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report institutions, particularly law enforcement authorities. 6 A number of the ODIHR NAM interlocutors considered that the heightened political tensions could undermine confidence in the integrity of the forthcoming elections and increase the likelihood of disputes over the legitimacy of the results, potentially leading to post-election protests and incidents of violence. Representatives of the law enforcement authorities, in turn, expressed confidence in their operational preparedness and capacity to ensure safety and security of citizens, election stakeholders and observers throughout the electoral process. 7 Women hold 93 out of 250 seats (37 per cent) in the outgoing parliament, and 9 of the 30 current ministers, including a minister in charge of gender equality, prevention of violence against women and economic and political empowerment of women. The Speaker of the National Assembly is a woman. However, women remain underrepresented in all other elected and appointed offices, especially at the local level and in party leadership positions. Several interlocutors raised concerns about gender-based violence against women in politics, including online harassment, sexist abuse, intimidation and smear campaigns, which they considered detrimental to women’ s full and effective participation in political processes. 8 ODIHR has observed 20 elections in Serbia since 1997, including the early parliamentary elections in 2023 and the local elections in 2024, when ODIHR deployed Election Observation Missions. 9 The final reports contain recommendations, including priority ones, for the authorities to improve the electoral process and bring it closer in line with OSCE commitments. 10 B. L EGAL FRAMEWORK AND ELECTORAL SYSTEM Parliamentary and presidential elections are primarily regulated by the 2022 Law on Election of Members of the Parliament (Election Law), the Law on the 2022 Election of the President (PEL), the 2009 Law on Unified Voter Register (LUVR) and decisions and instructions of the REC. Serbia is party to major international and regional instruments related to holding of democratic elections. 11 The election-related legal framework has undergone further revision since the 2023 parliamentary elections. Amendments to the LUVR were adopted in 2025, following a process on which ODIHR 6 Many ODIHR NAM interlocutors referred to allegations of excessive use of force by law enforcement authorities, as well as the alleged use of a sonic device during the 15 March 2025 protest, noting that these claims have yet to receive a comprehensive and transparent institutional response. Representatives of the ruling party, in turn, informed the ODIHR NAM about violent attacks targeting their party premises, public officials and party members. 7 The Ministry of the Interior (MoI) informed the ODIHR NAM that it would continue to ensure security impartially and in accordance with the law throughout the electoral process, and does not anticipate major security incidents or clashes during the electoral process. 8 See also the 2021 ODIHR report on Gender-based violence against women politicians in Serbia. 9 See previous ODIHR election reports on Serbia. 10 In paragraph 25 of the 1999 OSCE Istanbul Document, OSCE participating States committed themselves “to follow up promptly the ODIHR’s election assessment and recommendations”. 11 Including the 1966 International Covenant on Civil and Political Rights, 1979 Convention on the Elimination of All Forms of Discrimination Against Women, 1965 International Convention on the Elimination of All Forms of Racial Discrimination, 2003 Convention against Corruption, 2006 Convention on the Rights of Persons with Disabilities (CRPD), the 1950 European Convention on Human Rights. Serbia is also a member of the Council of Europe’s Venice Commission and of the Group of States against Corruption (GRECO).

Republic of Serbia Page: 7 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report issued five legal opinions. 12 In May 2026, the National Assembly adopted a package of amendments to the Election Law, the PEL, the Law on Local Elections and the Law on the Constitutional Court, and in July 2026, the Law on Financing Political Activities, both of which ODIHR assessed in two separate legal opinions. 13 In January 2026, a package of judicial amendments recalibrating the country’ s prosecutorial and judicial framework sparked significant domestic and international response. 14 The authorities informed ODIHR that revised draft amendments to the Law on Prevention of Corruption were expected to be introduced into parliamentary procedure by the end of August, before the dissolution of the National Assembly. In line with previous ODIHR recommendations, the adopted amendments, inter alia, establish a mechanism for a periodic independent audit of the voter register with the aim of strengthening its transparency, introduce mandatory training and certification of election officials, allow voters to support more than one candidate list, further regulate the registration of national minority electoral lists, and regulate certain aspects of electoral dispute resolution, including by introducing statutory deadlines for proceedings before the Constitutional Court. The amendments to the campaign finance legislation introduce campaign expenditure limits, regulate third-party campaigning, aim to strengthen the oversight and investigative powers of the oversight body and enhance reporting requirements. At the same time, a number of longstanding ODIHR recommendations remain unaddressed or only partially addressed, including with regard to safeguards against the misuse of administrative resources, effective measures to prevent intimidation and undue pressure on voters, transparent and proactive oversight of political and campaign finance, the independence and effectiveness of the media regulatory authority and balanced media coverage, voting rights of persons deprived of legal capacity, as well as adoption of proportionate and dissuasive sanctions for the misuse of administrative resources and violations of campaign finance regulations. The authorities reiterated their commitment to further align the legislation with previous ODIHR recommendations and emphasized the consultative nature of the reform process, including through holding public consultations. Conversely, many ODIHR NAM interlocutors from opposition parties and civil society expressed concerns regarding both the process and substance of the reforms and reiterated doubts about their effective implementation “in good faith”. While acknowledging that a number of ODIHR recommendations had been addressed, they considered the reform process to have been selective, procedurally flawed and insufficiently inclusive, focusing primarily on technical amendments while leaving more systemic and longstanding electoral concerns unaddressed. 12 The Working Group for Improvement of the Election Process (Working Group) was established in May 2024 by the parliamentary Committee on Constitutional and Legislative Issues to draft legal solutions to implement all ODIHR recommendations by 1 July 2025, to revise and adopt appropriate regulations to implement key ODIHR and Council of Europe recommendations, and to conduct a thorough revision of the voter register in accordance with ODIHR recommendations, as planned in the reform Agenda adopted by the Government of Serbia. The proposals for amendments to the LUVR were the first acts to be considered. In January 2025, opposition parties and civil society representatives withdrew from the group quoting an absence of an inclusive and transparent consultation process. 13 See all ODIHR Serbia-related legal opinions here. 14 The five laws included in the package are the Law on the Public Prosecutor’s Office, the Law on the High Prosecutorial Council, the Law on the Organization and Jurisdiction of State Authorities in the Fight against Cybercrime, the Law on Judges and the Law on the Seats and Territorial Jurisdictions of Courts and Public Prosecutor’s Offices. The Venice Commission in its 24 April Urgent Opinion concluded that, [the amendments] had “removed previously existing safeguards designed to protect prosecutorial autonomy” and recommended to address certain shortcomings. In June 2026, the Venice Commission adopted a follow-up opinion which noted that the revised legislation represented a significant improvement. The laws were adopted on 25 June by the National Assembly.

Republic of Serbia Page: 8 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report The 250 members of parliament are elected for four-year terms from a nationwide closed-list proportional system. Candidate lists must surpass a three per cent threshold to participate in the distribution of mandates, except those representing national minorities. The president is directly elected for a five-year term from a single nationwide constituency and may serve a maximum of two terms. To be elected in the first round, a candidate must win a majority of all votes cast. Otherwise, a second round is held between the two leading candidates in 15 days. C. ELECTION ADMINISTRATION The elections are administered by a three-tier structure comprising the Republic Electoral Commission (REC), 166 local electoral commissions (LECs) and some 8,300 polling boards (PBs). 15 The composition of the REC is proportional to the number of seats held by the parliamentary parties. The current composition, appointed on 27 November 2024, comprises a chairperson and 16 members (7 women), each with a deputy, appointed by the National Assembly for a four-year term upon nomination by parliamentary groups. The Secretary of the Commission and a representative of the Statistical Office participate in the Commission’s work without voting rights. The legal framework does not provide for the systematic collection of gender-disaggregated data across all levels of election administration. The REC informed the ODIHR NAM that, to fulfill a previous ODIHR recommendation, it intends to issue instructions requiring LECs to collect and submit such data to the REC. The REC oversees the overall conduct of elections, while LECs supervise the electoral process at the municipal level, appoint PBs, adjudicate certain categories of complaints, and tabulate election results. LECs comprise between 7 and 13 members appointed proportionally by political parties represented in the respective municipal assemblies, while PBs consist of a chairperson, two members and their respective deputies. For the duration of the electoral process, each proclaimed electoral list is entitled to appoint representatives to the extended composition of the REC, LECs and PBs, with the same rights and responsibilities as members of the permanent composition. Despite the uncertainty regarding the timing of the elections and the compressed timelines applicable in the event of early elections, the REC leadership expressed confidence in its capacity to organize early parliamentary, presidential or concurrent elections. The REC informed the ODIHR NAM that preparations were well advanced, including the drafting of the necessary rulebooks and instructions to implement the recent legislative amendments, and the launch of public procurement processes for all election-related materials. The May 2026 amendments introduced a mandatory training and certification system for election officials, under which the REC is responsible for organizing training and issuing certificates, while LECs are required to co-operate with the REC in organizing training for PBs. 16 The REC noted that the recent introduction of the training and certification system, combined with the compressed pre-election timeframe, may pose challenges for its effective implementation. In addition, the REC intends to launch a voter education programme with a particular focus on voters’ rights, secrecy of the vote and prevention of malpractices on election day. 15 The REC informed the ODIHR NAM that the number of polling stations is expected to increase slightly, particularly in larger urban areas, following the reduction in the maximum number of voters assigned to each polling station. The REC noted that this measure was introduced in line with a previous ODIHR recommendation to reduce overcrowding at polling stations and better safeguard the secrecy of the vote. 16 Once the relevant provisions enter into force, appointment of members of the standing and extended compositions of LECs and PBs, including replacement members, will require a valid training certificate. However, these provisions are scheduled to apply only from 1 January 2028, except for transitional requirements for the training of LEC leadership. For the electoral period, each presidential and parliamentary contestant can appoint a member to the extended composition of all commissions.

Republic of Serbia Page: 9 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report The law requires polling stations to be accessible to voters with physical disabilities. The REC informed the ODIHR NAM of a dedicated working group to implement previous ODIHR recommendations on electoral accessibility. At the same time, the REC noted that ensuring the availability of ballot papers and other election materials in over 20 officially recognized minority languages continues to present operational challenges, particularly given the design and layout requirements of ballot papers. The REC website includes accessibility features, including sign language interpretation and text-to-speech functionality for selected voter information materials. However, several ODIHR NAM interlocutors emphasized the need to further improve the accessibility of voter education and election materials for persons with visual, hearing and intellectual disabilities, as well as to strengthen the collection and publication of comprehensive data on the accessibility of polling stations. While the REC expressed confidence in its ability to administer the elections professionally and efficiently, a number of ODIHR NAM interlocutors questioned the impartiality and political neutrality of election administration at all levels. Many interlocutors also expressed concerns regarding the transparency and integrity of the electoral process, citing in particular the adjudication of electoral disputes, the completion of results protocols, the potential for irregularities at and outside of polling stations, such as tracking of voters and compilation of parallel voter lists, and allegations of pressure on voters during both the campaign and on election day. 17 Many ODIHR NAM interlocutors referred to reports of significant irregularities and incidents of violence during the local elections held on 29 March 2026 in 10 municipalities, as documented by both domestic and international observers. 18 D. V OTER REGISTRATION The right to vote is granted to citizens who reach 18 years of age by election day and have permanent residence in Serbia, except those deprived of legal capacity by a court decision. The continued disenfranchisement of persons with intellectual and psychosocial disabilities on this basis remains at odds with international standards. 19 A newly introduced provision requires at least six months’ residence in a new municipality for a voter to be registered there before national elections. Voter registration is passive. The Unified Voter Register (UVR) is an electronic database maintained by the Ministry of Public Administration and Local Self-Government (MPALSG) and continuously updated on the basis of data received from municipalities and other state authorities, as well as voter requests. Citizens may verify and request changes to their registration online or in person. The MPALSG informed the ODIHR NAM there were 6,439,075 voters registered. 20 The 2025 amendments to the LUVR aimed at strengthening the transparency of the voter registration process by expanding public access to voter registration data, requiring regular publication of information on changes to the UVR during the election period, and providing for both online and physical public scrutiny of voter lists. In line with a prior ODIHR recommendation, the amendments 17 The MoI informed the ODIHR NAM that allegations of vote buying are difficult to substantiate without material evidence and that all reports of alleged vote buying and other election-related offences are referred to the competent Public Prosecutor's Office. 18 See for instance the post-election statement by the Council of Europe Congress of Regional and Local Authorities. 19 See Articles 12 and 29 of the CRPD. Paragraph 9.4 of the 2013 CRPD Committee’s Communication No. 4/2011 states that “an exclusion of the right to vote on the basis of a perceived or actual psychosocial or intellectual disability, including a restriction pursuant to an individualized assessment, constitutes discrimination on the basis of disability, within the meaning of article 2 of the Convention”. 20 The legislation also provides for voting abroad. Special voter lists are compiled for voters in military and penitentiary institutions. Mobile voting can be requested due to serious illness, age or disability.

Republic of Serbia Page: 10 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report also established an independent Audit Commission mandated to conduct periodic audits of the UVR, identify irregularities and issue recommendations aimed at improving the maintenance and accuracy of the register. 21 The MPALSG informed the ODIHR NAM of the need for additional technical staff to ensure the timely and efficient implementation of its responsibilities. The Audit Commission was established on 28 February 2026 but the ODIHR NAM was informed that its members gained full access to historical and aggregated data necessary for cross-checking different databases only as of 6 July. While the authorities assessed that the Commission was fully operational and expected the audit to be completed within the statutory deadline, opposition parties and civil society interlocutors questioned whether the process could produce meaningful results before the elections, citing the delayed access to data and concerns about the political commitment to address identified shortcomings. At the same time, many ODIHR NAM interlocutors from across the political spectrum considered the Audit Commission as an important mechanism bringing together representatives of different stakeholders and emphasized the importance of transparent communication regarding the scope and expected outcomes of its work. E. C ANDIDATE REGISTRATION Citizens eligible to vote may stand for president or member of parliament, without any further eligibility criteria. Presidential candidates and parliamentary candidate lists can be nominated by political parties, coalitions of parties and groups of at least ten voters. The signature collection and candidate registration period start with the call of the elections. Requests to register presidential candidates and parliamentary candidate lists are submitted to the REC and must be supported by 10,000 signatures from voters (5,000 for lists representing national minorities). In line with a previous ODIHR recommendation, May 2026 amendments allow voters to support more than one candidate list, replacing the previous restriction limiting voters to supporting a single list. While several ODIHR NAM interlocutors expressed concern this could facilitate the registration of a larger number of so-called “phantom” candidate lists, referring to allegations of similar practices during previous elections, the amendment was intended to broaden voters’ ability to support political participation and does not, in itself, affect the legal requirements for candidate registration. Support signatures are verified by the REC against the UVR, in co-operation with the MPALSG. By law, contestants may rectify deficiencies in their nomination documents within 48 hours following the publication of the respective REC decision. The May 2026 amendments further specify the criteria for determining the status of national minority lists and extend eligibility to nominate such lists to groups of citizens (see Participation of National Minorities section). The law requires that at least 40 per cent of candidates on each list are of the underrepresented gender, with at least two such candidates in every group of five candidates. F. E LECTION CAMPAIGN The official election campaign begins on the day elections are called and ends 48 hours before election day. The legal framework provides for equal campaigning opportunities for electoral contestants, while allowing most public officials to continue performing their official duties and engage in campaign activities, provided these do not interfere with their official functions. State 21 In all five LUVR-related legal opinions, ODIHR repeatedly noted concerns regarding the composition and decision-making arrangements of the Audit Commission and the need for a more inclusive legislative process. The commission is composed of five representatives of the ruling coalition, three representatives of the opposition and two of the civil society organizations; all members have deputies.

Republic of Serbia Page: 11 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report officials who are also candidates are prohibited from receiving media coverage of official opening or inaugural events during the ten days preceding election day. Political parties and other prospective electoral contestants informed the ODIHR NAM that they intend to combine traditional forms of campaigning, including rallies, door-to-door canvassing and the distribution of campaign materials, with extensive use of social media and other online platforms. Several parliamentary opposition parties indicated that they seek ways to collaborate with the student movement, while others stated that they would contest the elections independently, citing differences over policy priorities, including Serbia’ s European integration. Representatives of the ruling coalition noted that they were prepared to contest the elections irrespective of the date and type of the elections. Many ODIHR NAM interlocutors raised concerns regarding the significant disparity in financial resources available to electoral contestants, allegations of pressure on public sector employees to attend campaign events and support the ruling party, the potential misuse of administrative resources, and the announcement of new publicly funded social welfare programmes. Several interlocutors also noted an increasingly confrontational, and at times aggressive, political discourse, including hate speech, discriminatory rhetoric and online abuse, particularly targeting women active in political life, and anticipated that such practices would intensify during the campaign. 22 Online campaigning is expected to play a significant role. Online political content and campaign spending remain largely outside the existing regulatory and oversight framework and no single institution currently has a clear mandate to comprehensively monitor campaigning on online platforms. While some ODIHR NAM interlocutors advocated additional regulation, others cautioned that further legislative intervention could adversely affect freedom of expression and be applied selectively. Several interlocutors also referred to challenges in engaging with very large online platforms (VLOPs), noting inconsistent responsiveness to requests concerning harmful content and election-related risks, with requests submitted by public authorities reportedly receiving more timely attention than those from other stakeholders. A number of ODIHR NAM interlocutors also noted risks posed by foreign information manipulation and interference (FIMI) and domestic information manipulation (DIMI), particularly through co-ordinated online dissemination and subsequent amplification by traditional media. G. P ARTY AND CAMPAIGN FINANCE Campaign finance is primarily regulated by the 2022 Law on Financing Political Activities (LFPA), while the 2019 Law on Prevention of Corruption regulates the prevention of conflicts of interest, oversight of public officials and the misuse of public resources during election campaigns. The regulations issued by the Agency for Prevention of Corruption (APC) supplement the legal framework; the APC is responsible for supervising political finance, monitoring the use of public resources during campaigns and enforcing relevant provisions of both laws. In addition, the State Audit Institution (SAI) oversees the public funds of parties. 23 Electoral contestants are financed through public funding, donations, membership fees, loans and their own resources. Donations from anonymous and foreign sources and several categories of 22 The MoI informed the ODIHR NAM that it acts upon all reported cases of online abuse and harassment through its specialized unit for combating high-tech crime, and that it had launched the “Cyber Watch” application to provide an additional channel for reporting cyber-related incidents. 23 The SAI informed the ODIHR NAM that, in accordance with its annual audit plan, it had selected five political parties for audit in 2026: United Serbia, New Face of Serbia, the Movement of Free Citizens, the Alliance of Vojvodina Hungarians and the Democratic Party of Albanians. The SAI noted that the audit reports are expected to become publicly available by the end of 2026. . The SAI further informed the ODIHR NAM that election years do not entail additional audits beyond those envisaged under its regular annual audit plan.

Republic of Serbia Page: 12 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report prohibited donors are banned. The amended LFPA, adopted on 9 July 2026 by an urgent procedure, introduces campaign expenditure limits for the first time, set at EUR 6 million for parliamentary and presidential elections (EUR 7 million where a presidential election is held in two rounds), reduces the maximum annual donations to 5 average monthly salaries (AMS) for natural persons and 10 AMS for legal persons, and limits additional contributions during election years to 50 per cent of the applicable annual ceiling. 24 Addressing a number of previous ODIHR recommendations, the amendments also establish a legal framework for third-party campaigning, strengthen certain transparency requirements, introduce mandatory publication of campaign finance data in machine- readable format, expand the supervisory powers of the APC, abolish the deposit requirement for certain electoral contestants to access public campaign funding, and require interim campaign finance reports to cover campaign activities up to seven days before election day. Contestants remain required to submit an interim report five days before election day and a final report within 30 days following the publication of the final election results. The amendments also establish a Women’s Political Participation Fund, financed by up to 0.0025 per cent of annual tax revenues and allocated to electoral lists on which women obtain more than 40 per cent of mandates. At the same time, several ODIHR and the Council of Europe’s Group of States against Corruption ( GRECO) recommendations remain unaddressed, including those concerning the level of campaign expenditure ceilings, proportionate and dissuasive sanctions, proactive monitoring by the APC, and safeguards against misuse of administrative resources. 25 Following the adoption of the amendments, the APC informed the ODIHR NAM that it would organize online and in-person training and awareness-raising activities for political parties and other stakeholders ahead of the elections. It also stated that, as in previous elections, it would deploy field observers to monitor compliance with the campaign finance legislation. Several interlocutors further noted that monitoring campaign expenditure related to online campaigning, particularly spending incurred through third parties, remained challenging due to limited regulatory and oversight mechanisms. While the APC expressed confidence in its preparedness to implement the amended legal framework, many ODIHR NAM interlocutors continued to express concerns about the transparency of political and campaign finance and the effectiveness of the APC’s oversight and enforcement, referring in particular to the timeliness and consistency of its work, safeguards against the misuse of public resources during election campaigns, and the limited transparency of its oversight methodologies and decision-making. At the time of the ODIHR NAM, draft amendments to the Law on Prevention of Corruption remained under parliamentary consideration. According to the authorities, the proposed amendments aim to strengthen safeguards against conflicts of interest and the misuse of public resources during election campaigns, broaden the scope of public officials covered by the law, and improve complaints procedures and oversight by the APC. H. M EDIA There are more than 2,000 media outlets registered, resulting in a highly fragmented media market. Television remains the primary source of information for the public. The public broadcaster Radio Television Serbia (RTS), several national commercial television broadcasters, the cable television channel N1 and a number of widely circulated tabloids are among the country’ s most influential media outlets. The online media landscape comprises a diverse range of independent news portals, 24 One AMS equals approximately EUR 1,000. 25 Following two prior legal opinions, the adopted version of the law had not been subject to prior ODIHR review.

Republic of Serbia Page: 13 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report tabloid websites and media affiliated with, or supportive of, the authorities. 26 Many ODIHR NAM interlocutors raised concerns regarding media pluralism, editorial independence and the effective implementation of the legal framework governing election coverage. In this regard, several interlocutors referred to the announced acquisition of the Adria News Network (ANN), which includes N1 and Nova S. 27 The media framework governing elections is primarily regulated by the Constitution, the Law on Electronic Media, the Law on Public Information and Media, the Law on Public Media Services, the Law on Advertising and the election legislation, supplemented by regulations of the Regulatory Authority for Electronic Media (REM). Public and private broadcasters are required to provide balanced election coverage and equal conditions for electoral contestants, while public service media are subject to additional obligations to provide impartial, comprehensive and timely information during election campaigns. Paid political advertising is permitted under equal conditions for all contestants and must be clearly identified. In 2025, amendments to the Law on Electronic Media, the Law on Public Information and Media and the Law on Public Media Services were adopted to further align the media legislation with the EU acquis. The amendments introduced, inter alia, changes concerning the financing and governance of public service media, transparency of media project co-financing and certain aspects of the regulatory framework for electronic media. However, many ODIHR NAM interlocutors criticized both the substance of the amendments and the legislative process, citing insufficient transparency and limited public consultation. 28 Many ODIHR NAM interlocutors expressed serious concerns regarding the media environment, describing a deterioration in the safety and working conditions of journalists. 29 They referred to reports of intimidation, physical attacks, threats, online harassment, smear campaigns, obstruction of reporting during demonstrations accompanied by the use of strategic lawsuits against public participation (SLAPPs). 30 Representatives of independent media stated that investigations into attacks and online threats against journalists remained ineffective, citing limited action by the police 26 See media landscape analysis by the Reuters Institute. 27 N1 was described by many ODIHR NAM interlocutors as one of the few remaining television broadcasters providing critical coverage of public affairs and the authorities, and concerns were raised that the change in ownership could further reduce media pluralism and affect editorial independence, notwithstanding the acquiring company’s public commitment to preserve editorial independence. 28 The July 2025 European Commission Rule of Law Report Country Chapter on the rule of law situation in Serbia noted that “the drafting process lacked transparent and inclusive consultations and did not respect the legal obligation of holding a public debate”. 29 The MoI informed the ODIHR NAM that attacks against journalists are not limited to election periods and that all reported cases are referred to the competent Public Prosecutor's Office, while the police take preventive measures to ensure journalists' safety. 30 According to data from the Supreme Public Prosecutor’s Office, as provided in the 2025 Activity Report of the Permanent Working Group for Safety of Journalists, the number of cases involving acts against journalists increased from 65 cases in 2024 to 134 in 2025, including an increase in reported physical assaults from 6 to 28. In parallel, Serbia ranked 104 th out of 180 countries in the 2026 World Press Freedom Index, a decline from 96 th position in 2025. The Mapping Media Freedom 2025 Monitoring Report found that “208 violations of press freedom were documented - more than double the number of cases (84) recorded in 2024 - affecting a total of 358 media workers or entities. Throughout this year, verbal attacks constituted a major concern (62%), followed by attacks on property (23.1%), physical violence (21.2%), interference (19.2%), and legal threats (5.8%)”. According to the Center for Media Pluralism and Media Freedom, Serbia is ranked as a “high-risk” country. In April 2025, student protesters blockaded the premises of the public broadcaster RTS for several days, criticizing its coverage of the protests and demanding a new procedure for appointing the REM Council. The authorities condemned the blockade as an unacceptable interference with media freedom and the work of the public broadcaster. (See here the statement of the MFA to that effect). RTS journalists informed the ODIHR NAM that they had been subjected to threats, including the publication of “wanted” posters bearing their names.

Republic of Serbia Page: 14 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report and the Special Public Prosecutor’s Office for High-Tech Crime and the persistence of impunity. 31 They also noted that cases involving attacks on journalists, particularly those engaged in investigative reporting, frequently remained unresolved. 32 Many interlocutors considered that independent media were operating in an increasingly restrictive environment, referring to economic pressure through limited access to public funding and media co-financing schemes, stigmatization of independent outlets, including being labelled by some public officials as “traitors” and “state enemies”, and difficulties in obtaining access to information from state institutions. The REM is the regulatory body responsible for supervising electronic media, monitoring broadcasters’ compliance with the legal framework, deciding complaints and promoting pluralism and equal conditions in the media sector, including during election campaigns. On 12 November 2025, the National Assembly appointed eight of the nine members of the REM Council ending the prolonged deadlock. 33 The election of the ninth member, representing national minorities, was not completed, following which four newly elected members resigned in December, citing concerns regarding the appointment process. 34 As a result, the REM Council remained non-functional due to the absence of the required quorum of six members. On 10 July 2026, the National Assembly adopted an authentic interpretation of the Law on Electronic Media concerning the legal effect of those resignations. The following day, the four members announced that they would take up their mandates, enabling the REM Council to resume its work. The composition and effective functioning of the REM Council was consistently identified by ODIHR NAM interlocutors as a matter of particular importance. The appointment and effective functioning of the REM Council also constitutes an important benchmark in Serbia’ s EU accession process. Several interlocutors stated that the prolonged absence of a functioning Council had significantly affected REM’s responsiveness, including with regard to overseeing broadcasters, managing licensing, and the handling of complaints, with some referring to a substantial backlog of unresolved cases. 35 A number of interlocutors considered the Council’s ability to address this backlog in a timely, transparent and impartial manner as an important indicator of its independence and 31 Several ODIHR NAM interlocutors raised concerns about co-ordinated online attacks targeting independent media. In December 2025 and January 2026, several independent media outlets and journalists were reportedly subjected to co-ordinated bot activity on Instagram, resulting in the temporary suspension of several accounts. International media freedom organizations described the incidents as a new form of digital pressure on independent media and called for effective safeguards against similar attacks. (See the statement of the European Federation of Journalists). 32 In February 2025, five of the six journalist and media associations participating in the Permanent Working Group for the Safety of Journalists suspended their participation, stating that they had lost confidence in the institutions’ willingness to effectively investigate attacks against journalists. The Ministry of Information and Telecommunications, by contrast, informed the ODIHR NAM that the associations had withdrawn because they were unwilling to continue participating in the working group. The Ministry further stated that media associations and opposition representatives had also declined to participate in other consultative bodies, including the working groups on the Media Strategy 2026–2030 and on media literacy. 33 The mandate of the previously appointed REM Council officially expired in November 2024. 34 The election of the ninth member representing national minorities was not completed after disputes arose over the nomination process, including the eligibility of certain national minority councils to participate in nominating candidates, resulting in none of the nominated candidates obtaining the required parliamentary majority and contributing to broader concerns over the credibility of the appointment process. At the time of the ODIHR NAM, the position remained vacant. The authorities informed the ODIHR NAM that the appointment process is expected to resume following the National Minority Council elections, scheduled to take place before the end of 2026. 35 The REM informed the ODIHR NAM of over 100 pending cases. The prolonged absence of a constituted REM Council created a legal vacuum that affected, among others, the governance of the public service broadcasters RTS and RTV. As a result, the mandates of several managing board members expired in July 2026 without legally required competitions being announced to appoint their successors while the appointment of the RTS Programme Ombudsman was also delayed, affecting the functioning of accountability mechanisms within RTS.

Republic of Serbia Page: 15 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report effectiveness, and a key test of its performance during the forthcoming electoral period. Government representatives, in turn, stated that the delay in constituting the Council had resulted from the unwillingness of the opposition to co-operate and had hindered the implementation of media policies and the regulator’s day-to-day work. I. E LECTORAL DISPUTE RESOLUTION Voters, candidates and submitters of candidate lists have the right to challenge election-related decisions, actions and omissions. Complaints against PB decisions are lodged with the REC, while complaints against REC decisions are first reviewed by the REC and may subsequently be appealed to the Administrative Court, whose decisions are final. 36 The law provides for expedited procedures for resolving election-related disputes prior to the election day. By law, proceedings before the Administrative Court are generally conducted without public hearings and election-related appeals are heard in camera. Representatives of the Court informed the ODIHR NAM that election-related cases, particularly in the event of simultaneous elections, continue to place a significant additional burden on the Court during electoral periods without a corresponding increase in human resources. Election-related constitutional complaints may be lodged after exhaustion of other available legal remedies. The Constitutional Court is empowered to annul all or part of an election where established irregularities could have affected the election results. The May 2026 amendments to the Law on the Constitutional Court introduced a 30-day deadline for deciding electoral disputes, shortened from eight to three days the deadline for the competent election administration body to submit its response and the relevant electoral documentation to the Court, and extended from 10 to 30 days the maximum period for holding repeat elections following the annulment of election results. Representatives of the judiciary and prosecution met by the ODIHR NAM welcomed these amendments and expressed a generally positive assessment of the current legal framework, while noting that they had not been directly consulted during the legislative drafting process. Representatives of the judiciary and prosecution reiterated their commitment to the independent and impartial adjudication of election-related disputes. At the same time, many ODIHR NAM interlocutors expressed concerns regarding the functioning of the system for resolving electoral complaints and appeals, citing the consistency and timeliness of decisions by election administration bodies and courts, the handling of alleged election-related violations, and the limited public confidence in the impartiality and performance of the institutions responsible for resolving such cases. 37 J. P ARTICIPATION OF NATIONAL MINORITIES The Constitution guarantees persons belonging to national minorities the right to preserve and express their identity, including through political association, education, culture, access to information in their own languages, and the rights to vote and stand for election. Twenty-four national minorities have 36 Election-related matters may also be considered by the Public Prosecutor’s Office, the police, the Commissioner for Information of Public Importance and Personal Data Protection, depending on their subject matter. 37 The 2026 European Commission Rule of Law Report released on 17 July 2026 noted that “legal amendments removed some of the existing safeguards to protect prosecutorial autonomy and judicial independence, hampering the implementation of the constitutional reform of 2023; following subsequent legislative and non- legislative measures, the Venice Commission confirmed that Serbia addressed a considerable part of its recommendations on these amendments. Concerns regarding prosecutorial autonomy remain. Political pressure on the judiciary and the prosecution increased significantly, with limited follow-up from the High Judicial and Prosecutorial Councils, the Government or Parliament”.

Republic of Serbia Page: 16 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report established officially recognized National Minority Councils. 38 At the time of the ODIHR NAM, 76 of the 127 political parties registered with the Ministry of Public Administration and Local Self- Government MPALSG were registered as representing national minorities. In line with a prior ODIHR recommendation, the May 2026 amendments further regulate the registration of national minority electoral lists by specifying the statutory criteria that the REC must apply when determining minority status, including requirements relating to the nominating entity, the composition of the candidate list and safeguards against misuse of the preferential electoral framework. 39 The amendments also restore the possibility for the REC to seek the opinion of the relevant National Minority Council when assessing minority status, while clarifying that such opinions are advisory rather than binding. Several ODIHR NAM interlocutors similarly expressed concerns that the preferential provisions applicable to national minority lists could still be misused by political entities not genuinely representing national minorities and emphasized the importance of consistent implementation of the amended legal framework. K. E LECTION OBSERVATION The law provides for citizen and international election observation and guarantees accredited observers access to all stages of the electoral process, in line with previous ODIHR recommendations. Citizen observers may be nominated by civil society organizations whose statutory objectives include election observation and that are registered no later than seven days before election day. The 2025 amendments to the LUVR allow accredited citizen observers to access voter registration data and report inaccuracies in the voter register. Several civil society organizations informed the ODIHR NAM of their intention to conduct both long-term and election-day observation. Electoral contestants may also appoint authorized representatives to election administration bodies. 40 Many ODIHR NAM interlocutors representing civil society stated that they continued to face public pressure and verbal attacks by representatives of the governing parties, contributing to an increasingly hostile environment for civil society organizations and independent election observation. 41 They considered that such rhetoric had fostered a climate of intimidation, discouraging citizen engagement in election observation and other civic activities. Interlocutors further noted that the continued uncertainty regarding the timing of the elections complicates operational planning, including fundraising, observer recruitment and the organization of training activities. Several ODIHR NAM interlocutors also expressed concerns about what they described as the deployment of politically biased or ingenuine observers during recent local elections and considered that similar practices could recur during the forthcoming elections. 42 The REC, in turn, informed the ODIHR NAM that accommodating a large number of accredited observers in polling stations presents practical challenges that could affect the smooth conduct of voting. 38 National Minority Councils are non-territorial, self-governing bodies established by ethnic communities to manage and protect their rights in the areas of culture, education, information, and official language use. These bodies are elected every four years through a special electoral register. 39 While welcoming these amendments, ODIHR Opinion stressed that “any determination of national minority status of an electoral list must be based on clear, consistently applied and objective criteria”. 40 Representatives of the student movement informed the ODIHR NAM of their intention to appoint authorized representatives to all polling stations across the country. 41 The July 2025 European Commission Rule of Law Report Country Chapter on the rule of law situation in Serbia noted that “the space for civil society is rated as ‘obstructed’. Organisations and individuals that criticise the authorities are under increasing pressure, in particular those monitoring alleged electoral irregularities […]”. 42 The 30 March 2026 post-election statement by the Council of Europe Congress of Regional and Local Authorities notes that “the delegation was appalled to see on the ground the proliferation of pseudo- observers, with other 6500 individuals accredited, many of them from organisations with no-track record or methodology and some not displaying accreditation and at times exercising varying and excessive degrees of influence”.

Republic of Serbia Page: 17 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report IV. CONCLUSIONS AND RECOMMENDATION All ODIHR NAM interlocutors welcomed the deployment of an ODIHR election observation activity and strongly emphasized the importance of a large-scale, long-term and country- wide presence. Many considered that an independent and impartial assessment by ODIHR would be particularly valuable in the highly polarized political and social environment surrounding the forthcoming elections, while several also noted that a robust international observation presence could help increase public confidence in the electoral process, reduce tensions, deter potential irregularities and election-related violence. Representatives of the authorities likewise welcomed an ODIHR observation activity, offered their full co-operation and underlined that it would enhance the transparency and credibility of the electoral process. ODIHR NAM interlocutors identified a number of aspects for assessment by an ODIHR election observation activity, including the implementation of the recently amended legal framework, the work of the election administration, the voter register and its ongoing audit, candidate registration, conduct of campaign, including online, campaign finance, media coverage and regulation and election-day procedures. They also highlighted allegations of vote-buying, the potential misuse of administrative resources and intimidation and undue pressure on voters as meriting further attention . Based on this, the ODIHR NAM recommends the deployment of an Election Observation Mission (EOM) to observe the forthcoming elections. In addition to a core team of analysts, ODIHR will request the secondment by OSCE participating States of 32 long-term observers to follow the electoral process throughout the country, as well as 300 short-term observers to observe election-day procedures. In line with ODIHR’s standard methodology, the EOM will include a media monitoring component, and will assess the campaign environment and activities across traditional media, online outlets, and social media platforms. The mission will also assess the institutional preparedness and effectiveness in identifying and responding to disinformation, misinformation, and potential foreign and domestic interference, as well as existing co-operation mechanisms with social media platforms.

Republic of Serbia Page: 18 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report ANNEX: LIST OF MEETINGS Ministry of Foreign Affairs Nevena Jovanovi ć, State Secretary National Assembly Ana Brnabić, Speaker, National Assembly Mihailo Jovanović, Director, Office for Information Technologies and eGovernment Ministry of Information and Telecommunications Perko Matović, State Secretary Ministry of Interior and the Police Directorate Veljko Odalović, Acting Secretary Dejan Luković, Assistant Minister, Information and Communication Technologies Sector Milan Žižović, Acting Assistant Minister and Head, Information and Communication Technologies Sector Ivica Ivković, Head, Police Administration, Police Directorate Dragana Trajković, Head, Administrative Affairs Administration, Police Directorate Duško Batoćanin, Assistant Head, Information Technology Administration, Information and Communication Technologies Sector Srđan Radisavljević, Chief Inspector, Business Process Improvement and Coordination of Activities within Police Work Areas II, Police Directorate Ministry of Public Administration and Local Self-Government Zoran Kasalović, State Secretary Jovan Knežević, Acting Assistant Minister; Head, Sector for Civil Registers and Registries Aleksandra Mlađan, Chief, Cabinet of Minister Republic Electoral Commission Vladimir Dimitrijević, President Srđan Smiljanić, Secretary Administrative Court Radojka Marinković, President Ivana Nenadović, Adviser for International Cooperation, Professional Development and Training Sonja Vujčić, Adviser for International Cooperation, Professional Development and Training Republic Public Prosecutor’s Office Zagorka Dolovać, Republic Prosecutor General Branko Stamenković, President , High Prosecutorial Council and Public Prosecutor, Supreme Public Prosecution Office Agency for Prevention of Corruption Dejan Damjanović, Director Dušan Jeličić, Assistant Director, Control of Political Activities Department Jasmina Ćirković, Acting Assistant Director, Conflict of Interest Resolution and Control of the Transfer of Management Rights Department Bojana Smartek, Acting Assistant Director, Integrity and Anti-Corruption Education Department Marija Baltić, Acting Assistant Director, International Co-operation and Strategic Documents Department

Republic of Serbia Page: 19 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report State Audit Institution Marija Obrenović, Vice-President Marko Strugarević, Supreme State Auditor Slavica Raspopović, Secretary Iva Vasilić Miljić, Head, Department for International Cooperation and Public Relations Office of the Ombudsman Zoran Pašalić, Ombudsman Regulatory Authority for Electronic Media Rajka Galin Ćertić, Executive Director Stevica Smederevac, Head, Monitoring and Analysis of Broadcasting Programs Department Miloš Garić, Council Member Milan Petković, Council Member Media Bojana Mlađenović, Editor -in-Chief, RTS News and Current Affairs Program, RTS Dragana Ignjić, Editor , Oko program , RTS Branislav Sovljanski , News Director, N1 Vojislav Stevanovic, Deputy News Director, N1 Vesna Mališić, Editor-in-Chief and the editorial board, Radar Weekly Vojkan Kosti ć, Editor-in-Chief, Beta Agency Sanja Ivačić Perović, Deputy Editor-in -Chief, Editor , Foreign Affairs Desk, Beta Agency Political Parties Aleksandar Jovanović , MP, Ecological Uprising Danijela Nestorović, MP, Ecological Uprising Radomir Lazović, MP, Green-Left Front – Don’t Let Belgrade Drown Biljana Đorđević, MP, Green-Left Front – Don’t Let Belgrade Drown Marinika Tepić , Vice-President, Party of Freedom and Justice (SSP) Dr. Ana Jakovljević, MP, People’s Movement of Serbia – New Face of Serbia Verica Milanović, MP, Serbia Centre – SRCE Miroslav Petrašinović, MP, Serbian Progressive Party (SNS) Branimir Jovanović , MP, Social Democratic Party of Serbia (SDPS) Uglješa Marković, MP, Socialist Party of Serbia (SPS) Dunja Simonović Bratić, MP, Socialist Party of Serbia (SPS) Života Starčević, MP, United Serbia (JS) Elvira Kovač, MP, Union of Vojvodina Hungarians (SVM) Branko Pavlović , MP, We – Voice of the People Representatives of the Students’ Movement Civil Society Emilija Orestijevic, Executive Director, CeSID Sladjana Komatina, Project Manager, CeSID Nemanja Nenadić, Program Director, Transparency Serbia Vukosava Crnjanski, Director, Center for Research, Transparency and Accountability (CRTA) Raša Nedeljkov, Program Director, Center for Research, Transparency and Accountability (CRTA) Pavle Dimitrijevi ć, Director for Legal Affairs, Center for Research, Transparency and Accountability Vladimir Erceg, Program Manager, Center for Research, Transparency and Accountability (CRTA) Tamara Filipović, Secretary General, Independent Journalist Association of Serbia (NUNS)

Republic of Serbia Page: 20 Anticipated Early Elections, 2026 ODIHR Needs Assessment Mission Report Dragana Bjelica, Journalist, Journalist Association of Serbia (UNS) Ivana Stevanović, Executive Director, Slavko Ćuruvija Foundation Saša Mirković, Media Expert, Association of Independent Electronic Media (ANEM) Stevan Ristić, President, Management Board, Media Association (ASME) Danilo Krivokapić, Director, SHARE Foundation Andrej Petrovski, Director of Tech/ CERT, SHARE Foundation Academia Prof. Dr. Maja Kovačević, Dean, Faculty of Political Sciences , University of Belgrade Prof. Dr. Dalibor Petrovi ć, Researcher and Professor, Faculty of Transport and Traffic Sciences and Faculty of Philosophy, University of Belgrade Dr. Katarina Popovi ć, Professor, Faculty of Philosophy, University of Belgrade Gazela Pudar Draško, Director, Institute for Philosophy and Social Theory, University of Belgrade International Community 43 Representatives of the OSCE Mission to Serbia and diplomatic missions of European Union Delegation, Germany, Greece, Ireland, the Netherlands, Russian Federation, Sweden, Switzerland, United Kingdom, and United States of America. 43 The ODIHR NAM extended an invitation to representations of all OSCE participating States resident in Serbia.