The duties of the initiative groups/NGOs, which initiate or carry out the procedure, are sanctioned by Article 19. Article 19.1 could be interpreted in a way that sanctions would be applied also in case memorandums of cooperation, as provided for by Article 6, are not in accordance with the requirements of the law, for example. It should be up to the NGOs to decide how active they are in collecting the signatures, based on their financial and human resources, as the minimum number of signatures might be collected only from one large city without the need to organise the collection of signatures in all municipalities. Articles 19.2 and 19.3 already sanction the fraudulent activities of NGOs. The Venice Commission and ODIHR recommend explicitly providing in Article 19.1 that it applies only to the responsible civil servants.