In 2019 the Parliamentary Assembly of the Council of Europe adopted Resolution No. 2251 (2019) on ensuring free referendums in Council of Europe Member States, which includes a set of recommendations on the matter.10 In this Resolution and the Explanatory Memorandum thereto, considerable attention is dedicated to risks that may arise out of improper regulation of referendums and manipulation of voters' opinions, especially in countries where democratic traditions are only developing (and where the executive power could use this tool to bypass the legislator). In point 4.3, special emphasis is placed on the importance of maintaining a balance between representative and direct democracy:

"where possible, referendums should be post-legislative; where this is not possible, a process should be set out requiring two referendums if the first referendum does not allow voters to choose between the options that are ultimately available;”