Article 83(2) of the Draft law provides that official observers are to be accredited at the district commission level, thereby preventing observation of stages of the referendum process prior to the establishment of the district commissions. In light of this, Article 84, which sets out the rights of observers, establishes a limited scope of observation. The Code of Good Practice for Referendums, paragraph II.3.2, provides that accredited observers should have the right to observe all aspects of the referendum process, including the signature collection period and referendum campaign. In past ODIHR election observation reports, it recommended to simplify the process of accreditation of observers from CSOs in order to provide them with the possibility to observe all stages of the election process, including formation of the district commissions and the work of the CEC from the beginning of the election process. The above recommendations from ODIHR election observation reports also stand in relation to the Draft law.