For popular initiative referendums, there are two campaign periods during which different campaign finance provisions apply: the first is an initial period of campaigning during the signature collection phase (prior to the referendum being called) and the second is the referendum campaign period. Both campaign periods have financial reporting requirements. The initiative group and other entities which will campaign during the initial period are required to set up an initiative campaign fund (distinct from the referendum campaign fund.) During this initial campaign period, the initiative team is not subject to any spending limit as per Article 70.3 of the Draft law, while the other entities (political parties and CSOs) are subject to the general campaign spending limit during the referendum campaigning as referenced in the above paragraph. This unequal treatment of supporters and opponents during the initial campaign period with regard to campaign finance is contrary to paragraph 1.2.2.a of the Code of Good Practice on Referendums for guaranteeing equality of opportunity for supporters and opponents in the campaign. It is therefore recommended to address this disparity in the Draft law.