Observers from the Centre for Monitoring and Research (CeMI) reported that 2.4% of citizens were registered to vote by letter, i.e. 11,500 voters, at 967 processed polling stations.

Given that members of the electoral committee visit registered persons in the period from 13:00 to 20:00, estimates are that it is difficult to process more than 20 voters in that period if they spend an average of 20 minutes per voter. At 120 polling stations, more than 20 persons were registered to vote by letter. CeMI estimates that 779 citizens will not be able to use their right to vote at these 967 polling stations, due to the instructions that the members of the polling boards received from the SEC.

In its opinion (580/2) dated August 26, 2020, the SEC pointed out the concentration of election actions and the time frame from Article 91, para. 2 of the Law on the Election of Councilors and Members of Parliament, which stipulates that the electoral committee is obliged to deliver election materials to the municipal election commission no later than six hours after the polling station closes. Based on this position, the SEC estimated that it is realistic to expect that the commissioners for voting by letter deliver the electoral material to the polling boards no later than one hour after the polling stations close in order to start determining the voting results. This implies that the commissioners for voting by letter will not allow those voters who are in another municipality to vote, if this would mean that they cannot return to the polling station within an hour after the polling station closes.

We believe that in this way a certain number of voters who submitted a request to vote by letter will be denied the right to vote and that the rule from Article 70, paragraph 2, that voters who were at the polling station at the time of the polling station's closing will be allowed to to vote.

At CeMI, we are of the opinion that voting must be enabled for all those who registered to vote by letter, that is, they should be treated as voters who happened to be at the polling station at the time of its closing. Anything else would mean a gross violation of the voter's right to vote.