Advisory opinion on the planned 2023 Electoral Amendment Act

9 Jan , 2023  

Vienna, 9 January 2023: Election-Watch.EU ( welcomes the submission of a private member bill by the governing parties to reform Austria’s electoral law and election conduct. The proposal to amend the electoral law includes some planned measures that our working group has already put forward in its list of proposals for the reform of Austrian election processes (January 2017), and which were supported by the research project “Wahlbeisitz in Austria” (2021) carried out together with VieCER.

Election-Watch.EU ( In contrast to the election study project partner VieCER and other civil society organizations involved (e.g. BIZEPS), Election-Watch.EU ( did not receive a request for a statement (6.12.2022). This is regrettable, since Election-Watch.EU ( published concrete electoral reform proposals in the Journal für Rechtspolitik (JRP, volume 26, issue 1, 2018), held two panel discussions on the subject of electoral law reforms with the Directory of Parliament (2018 & 2022) and, since Election-Watch.EU ( was referenced in the OSCE/ODIHR election reports on Austria since 2016.

Election-Watch.EU ( also refers to the 44 election reform recommendations of the OSCE/ODIHR, of which only two have been implemented so far and five have been partially implemented. Austria, as the host country of the OSCE, has a special responsibility to implement OSCE decisions and promote the implementation of electoral reform recommendations.

Election-Watch.EU ( has also joined forces with seven other civil society organizations involved in democracy policy to create the Democracy Index Austria, which points to all areas that need to be strengthened and identified deficits in Austrian democracy. The Democracy Index, which was presented to the public for the first time in November 2022, explicitly includes the area of ​​elections and shows gaps in the implementation of recommendations and good practices.

Election-Watch.EU ( has the following statement on the electoral reform proposals presented in the initiative application, which is based on our published recommendations and research results in the relevant area:

1) Positive aspects of the initiative application:

a) Considered “pool solution” for polling station committee members

b) Upgrading the activity of members of the electoral authorities (regulating wages, working hours and legal entitlements)

c) Extended use of the central voter register (ZeWaeR)

d) Mandatory barrier-free access to all polling stations

e) Improvements in postal voting (delivery, counting, QR code) and online publication of district election results by municipalities


2) Negative aspects of the initiative application:

a) Justification for the invalidity of postal votes (if the election envelope is sealed)

b) Concerns about voting with a postal ballot card at the polling station


3) Missing aspects of the initiative application:

a) Limitation of international election observation (only OSCE) and lack of admission of civil society election observation

b) Electronic declaration of support for candidates and parties

c) Missing flap to cover the voter’s signature and details on the postal voting card with data protection concerns, especially for Austrians living abroad

d)Independence and transparency of the electoral administration

e) Legal security for complaints and objections

f) Comprehensibility and coherence of the electoral law


4) Demand for participatory and inclusive electoral reform processes


Detailled Statement of Election-Watch.EU (; in German language)

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