Translate or Listen
Accessibility Settings:
Additional translations and tools are available here.

Oversight project

See overview of Oversight here

0.2 Acknowledgements
0.3 Glossary
1 Part 1 Implications of the Legislative Framework for Oversight Institutions
1.1 International Standards and Agreements
1.2 Reasons to Regulate Political Finance
1.3 Components of Political Finance Regulatory Systems
1.4 Emerging Legal and Regulatory Issues
2 Part 2 Strategic Framework and Planning
2.1 Overview of Strategic Framework
2.2 Overview of Planning
2.3 Overview of Project Management
2.4 Risk Management
2.5 Performance Management
2.6 Stakeholder Engagement
2.7 Continuous Improvement Opportunities
3 Part 3 Operational Delivery
3.1 Oversight Institution's Role(s)
3.1.2 Advisory Services
3.1.3 Publication of Financial Reports and Your Decisions and Actions
3.1.4 Policy Development
3.1.5 Increasing Public Awareness
3.2 Compliance Control Mechanisms
3.2.1 Supervision and Monitoring
3.2.2 Preparing Reporting
3.2.3 Receipt and Review of Statutory Reports
3.2.4 Complaints and Allegations
3.2.5 Audits
3.3 Handling Issues of Non-Compliance
3.3.1 Investigations
3.3.2 Enforcement
3.4 Ensuring Appropriate Resources to Deliver the Oversight Institution's Role
3.5 Operational Policies and Procedures

3.2.1 Supervision and Monitoring

Oversight project logo

Supervision and monitoring are part of the tasks political finance oversight bodies can be vested with. Depending on the country and the mandate entrusted to the political finance oversight body, supervision and monitoring of political finances can encompass different mechanisms or powers. Besides the review of financial reports, the handling of complaints and allegations and the review of auditors / accountants’ reports, the oversight institution can also have recourse to other channels of information, i.e.:

3.2.1.1 Field monitoring

Field monitoring of election campaigns is a relatively new phenomenon which has recently been introduced (sometimes incorporated in the legislative framework) in some countries, such as Albania (Field monitoring – Albania.pdf), North Macedonia and Serbia (Serbia Case Study, Supervision and Monitoring Final Version.pdf). This usually consists of experts specifically hired by the oversight body to observe and monitor campaign activities and election-related events during the election campaign but can also be conducted in-house. The monitoring of election campaigns can be accompanied/ supplemented by the costing of observed activities. In such case, the goal pursued is to provide to the oversight body information about campaign spending and enable the latter to compare and cross-check data contained in the financial reports with campaign monitoring findings/ estimates.

Real-time monitoring of election campaigns through, for instance, the establishment of a unit monitoring traditional or social media is a more common practice that can be carried out either by the oversight institution or outsourced to private companies (Lithuania) (Lithuania.pdf). CSOs can also play a significant role in monitoring campaign finances (Tunisia) 

When designing your campaign monitoring programme, it is important to consider the following elements if you need to issue an instruction/ decision setting out the rules and the scope of campaign monitoring:

  • Who will undertake the monitoring and if done externally, the selection criteria, procedure and appointment of campaign monitors, as well as the monitoring scope, monitoring period, entities monitored;
  • The geographical area of monitoring must be defined in the relevant instruction/ decision;
  • The monitoring scope must precisely cover the breadth of the monitoring activities, i.e. monitoring of the use of propaganda materials, polling stations, election propaganda materials, rallies, meetings, events, and/or of the compliance with prohibitions and restrictions on certain activities before election date and/or misuse of state resources during the monitoring period. Ideally, the monitoring process should be followed by a cost benefit analysis to consider the pros and cons of such a mechanism;
  • Monitoring tools must be developed by your institution, i.e. reporting templates (Field monitoring template – Albania.pdf), training curricula;
  • Logistical planning and development of a communication plan by your institution especially when the monitoring involves the observation of the illegal use of state resources by public institutions;
  • The mandate and powers of the campaign monitors must be clearly spelled out, i.e. do they have to provide an estimate of the observed activities, can they hold interviews with electoral contestants and their officers, public officials and third parties and ask for information/ documents, can they conduct (social) media monitoring, etc;
  • Whether your institution wants to publish the monitoring reports taking into account the nature of these reports, i.e. collection of data and facts that might not be of such great interest to the public, and the impact the disclosure of the latter may have on the monitoring process, i.e. some monitors could restrain themselves due to the potential public scrutiny or feel pressured to mitigate what is observed in order to avoid any kind of criticism.

Upon receipt of the campaign monitor’s report, your institution will determine based on the information contained in the monitoring report and any comments received from the political party/ candidate whether there may have been a violation of election campaign finance rules in accordance with your internal procedures. Depending on the gravity of the alleged violation/ irregularity, the matter might be substantively assessed for further action, either immediately or during the review phase of financial reports.

3.2.1.2 Matters identified by the oversight body ex officio

Staff members of your institution may become aware of potential violations through a number of public sources including newspapers, TV, social media. Any employee receiving information which appears relevant to possible non-compliance with the political finance rules should communicate that information as soon as possible to those handling such matters. The information should be registered and dealt with following the procedure in place for the receipt of complaints and allegations. Naturally, the risk may be high that among relevant information about political finance violations there may be significant amounts of misinformation or speculation, and careful investigations are essential.

Your legislation may ban anonymous allegations. In those circumstances, you may need to consider whether and under what circumstances the issues raised anonymously could be addressed ex officio. For example, if accusations in an anonymous complaint are supported by publicly available information, is your institution at liberty to begin a review on its own initiative without reliance on the anonymous complaint?

For examples, see pages 7 and 8 in this Federal Electoral Commission (FEC) document from the US, and here about Montenego (Montenegro.pdf).

3.2.1.3. Matters referred to the oversight body by another public institution

It may happen that elements regarding a potential breach of campaign finance or political party financing regulations is referred to a political finance oversight institution by another public institution. For instance, the media regulator might receive a complaint or allegations of wrongdoings regarding political advertisements placed on social media by non-contestant campaigners. Although the media-related part of that complaint may fall under the jurisdiction of the media regulator, accusations pertaining to non-contestants and political advertising might need to be handled by your institution, and the media regulator may therefore refer that information to you. In some cases, referrring relevant information between institutions may be mandated by law. 

For example, in the United States, enforcement proceedings may also originate from other entities referring potential violations to the FEC. These entities include local and state law enforcement authorities, federal enforcement authorities, and other federal agencies - see pages 8 and 9 in this FEC document.