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Monitoring of campaign financing - second preliminary findings

Transparency Serbia presented its findings on the financing of the election campaign, costs for advertising on TV stations and Facebook, on what preliminary reports brought, as well as on the observed violations of regulations and the outcome of the reports it submitted.

TS kzn 6. april 01Program director of TS Nemanja Nenadić said that preliminary reports on campaign financing did not contribute to increasing the transparency of campaign financing - they do not show the real situation and may lead to the wrong track. Considering that they refer to the data from March 19, they show only 15-20% of the campaign costs, pointed out Aleksandra Ajdanić.

This campaign is the most expensive so far - 15.7 million euros have been allocated from the budget, and the SNS will receive more than 8 million euros. According to TS estimates, 6.9 million euros were spent on TV advertising (not counting local TV stations). Of that, SNS paid around 4.1 million euros. TV Pink collected the most money (around 2.7 million euros), followed by RTS (around 1.8). 381,000 euros were spent on advertising on FB. SNS "boosted" ads with 263 euros each on average. A total of almost 200,000 euros. In second place is SVM with 31,700 euros. Advertisements without the label of a political entity that glorify the city government or are against the opposition were promoted with 35,000 euros.

Robert Sepi said that TS submitted four reports to the Agency for the Prevention of Corruption for violating the law by the public officals. The agency invested a lot of inventiveness not to provide answers or to respond to what was not the subject of the application. In several cases, it did not submit a decision, but only a "notice".

Expensive campaign at the expense of citizens: The campaign for the united presidential and parliamentary elections in 2022 is a record for the amount of money that the citizens of Serbia paid to convince the parties to vote for their lists and candidates. The total level of budget allocations, which most parties led together for both types of elections during 6 and a half weeks, this year is 15.7 million euros. In the 2014, 2016 and 2017 elections, it was between 4.7 and 6.9 million euros, while ten years ago, when the campaign lasted a little longer (two election rounds), budget grants were similar to now. More than generous budget financing will have two consequences - the campaign will be more expensive and participants will use other sources of income to a lesser extent (transfer of money obtained to finance regular work from a permanent party account, real or fake donations and bank loans).

How much did eevryone get?

koliko ko dobija

Who benefited from the amendments to the Law: Amendments to the Law on Financing Political Activities increased the share of budget money that is divided into equal parts in parliamentary elections (from 20 to 40%), and reduced the share that is divided equally when it comes to presidential elections 50 to 40%). This change was useful for parties that had only a parliamentary electoral list, and did not pass the census (eg SRS, Ajmo ljudi, Ruski savez), because they received twice as much money as they would have received if the law had not been changed. Also, the financial winners of these changes are minority parties that will receive between 6.3 and 9.6 million dinars more from the budget than they would have if the law had not been changed.

On the other hand, those parties that ran in both types of elections received collectively less money than they would have received if the Law had not been changed. Parties that did not pass the census, but won at least 1% of the votes, received 66 million dinars each, and according to the old law, they would be entitled to one million dinars more. The difference is about 10% in the income of the parties that won 10-15 seats in these elections (Dveri, Zavetnici, Moramo, NADA), while in the case of UPS, the difference is as much as 26 million dinars (154: 180 million). The SPS is also to the detriment, which will acquire the right to about 10 million dinars less than according to the provisions of the old law. The changes slightly affected the SNS, which thus gained the right to 951.6 million dinars, while by applying the rules from the previous law, it would get about 700 thousand dinars less.

Was there enough money for everyone? At first glance, it could be concluded that the financial conditions for participation in the election race were more favorable than in the elections in the last ten years, due to significantly higher budget allocations. However, a major obstacle for most opposition participants now was the lack of significant funds to launch the campaign, as a result of the decision to boycott the 2020 parliamentary elections, as well as debts due to election campaigns that exceeded their capabilities in previous years. An additional unfavorable factor for the opposition lists was the poor chances of winning the elections, which certainly did not act as a stimulus for potential interest donors. Also, the high centralization of power at all levels in the hands of the ruling coalition, did not leave opportunities for their rivals to resort to the illegal use of public resources of local governments for political promotion. Finally, the membership of the parties themselves is generally small and the culture of making small donations by true sympathizers is underdeveloped.

The SNS did not have financial problems to start the campaign, as did other parties that receive significant money to finance regular work from the budget (SVM, SDA, SPP, Albanian Coalition, and to a lesser extent SPS, due to previous debts repaid with those funds). Also, according to the financial reports, the SRS has a solid financial base resulting from previously received budget grants.

Most of the other participants seem to have built the financial basis of their campaign on the expectation of budget grants. The deadline for the payment of the budget advance was 24.3, and for the parliamentary 27.3, that is, only 7 or 4 days before the day when the campaign was supposed to end. Given that the parties did not even apply for short-term loans in order to financially bridge the period until receiving budget grants (it is unknown whether they tried to negotiate them), the question remains whether the lack of money was the main reason for something more modest than expected campaign intensity of the majority of opposition lists and candidates in the first weeks or it was something else (eg late decisions on participation in elections and coalitions, strategy, changes in plans due to the war in Ukraine that overshadowed part of the campaign, etc.).

The impression is that after these elections, and before the deadline of 30 days for submitting the final financial report, more participants will try to spend all the money they are entitled to from the budget (if they do not want to return part of these funds) than be the ones to worry about finding legal sources of funding for all the costs incurred.

How are the costs planned? The system of budget financing of the campaign in Serbia, since 2004, is such that most of the money is distributed on the basis of future uncertain circumstances - winning the presidential election or the number of seats won in the parliamentary elections. Parties that have support for their campaigns and other sources of income can calculate that they will invest that money in the first place, and then, depending on the election success, return it to a permanent party account or spend it and budget grants. Their political rivals, who put everything on the map of crossing the electoral threshold, or at least the "budget threshold" of 1% of valid votes, risk a great loss of the deposited election guarantee and entering into a debt relationship with suppliers. By the way, none of the parties in this election disclosed information about their planned campaign expenses, neither on their own initiative, nor after the questionnaire submitted by the TS.

Absence of expenditure restrictions: Contrary to the practice of most democracies in the world, Europe, and even our immediate neighborhood, as well as the 2016 ODIHR recommendation, the total cost of the campaign is not limited in Serbia. The TS proposed that such a restriction be introduced when the Law on the Financing of Political Entities was amended a few months ago. According to our proposal, that limit would be 300 million dinars for the parliamentary and 200 million dinars for the presidential elections (300 million if you vote in the second round), which is similar to the surrounding countries (eg Hungary, Croatia, Bulgaria). The absence of this limit in Serbia encourages inequality of election participants, especially in the constellation of forces that has existed since 2014, with one extremely dominant political party, whose campaign costs often exceed the expenditures of all competitors.

Other unresolved issues: Amendments to the Law have not been used to provide a more effective way to prevent circumventing campaign financing, through a campaign run by "third parties" rather than political parties, coalitions and citizen groups themselves. Also, the opportunity to adjust the reporting on campaign costs to the new circumstances was missed, so that the costs of advertising on social networks, which are increasingly represented, are shown separately. 

Changes in regulations concerning media advertising have contributed to solving an old problem - the unavailability of political advertising price lists. However, advertising on other types of media was left without this rule, as well as adequate supervision. Finally, the amendments to the Law have not been used to more adequately regulate the issue of liability for violations of the rules and the publicity of data on initiated and completed proceedings. Regarding the work of the Agency for the Prevention of Corruption, some new useful rules have been introduced (the Agency's duty to prepare a report on its control, deadline for drafting reports, duty to prepare and publish a control plan), but failed to provide all mandatory elements of the report and plan. .

Changes in the structure of campaign expenditures. In this election, the trend of increased campaign presence through social networks and the Internet continued. Other forms of advertising are still used to a significant extent, especially billboards. On the other hand, the number of mass gatherings (compared to the elections before the pandemic) was reduced, as well as the delivery and installation of classic promotional material (posters, leaflets).

TV advertising. This type of advertising is traditionally by far the largest generator of campaign costs, in which it participates with approximately half of the reported expenses. It seems that these elections were not significantly different in that respect either.

tv oglašavanjetv oglašavanje po stanicamaSNS i SPS po TV stanicamaAccording to the estimate of TS, which is based on the published price lists and discounts of national TV stations and major cable broadcasters, the total value of the recently completed television campaign for the republican and Belgrade elections reached close to 7 million euros. To this should be added the costs of regional and local television, as well as several leased terms that were observed on individual TV stations. It is important to note that the costs for TV Happy were calculated according to the list of discounts from 2016, since they were not available for the last elections, and even now, unlike all other observed TV stations.

SNS has achieved a distinct dominance in this type of advertising, with about 60% of total costs. When measuring the total time of broadcasting advertising messages, this dominance is even more pronounced (about 79%). However, the difference between the SNS and the competitors is somewhat less pronounced in the value of advertising, because this party acquired the right to the biggest discounts on all TV stations. It should also be noted that the SNS was the only one to advertise during the first weeks, and that until the last week of the campaign, its share in the pre-election market was even higher (around ¾).

TV Advertising and Electoral Success: The SNS's investment in TV advertising is identical to the percentage of support won in the presidential election, but significantly exceeds its success in the parliamentary elections. The second in terms of investments is the SPS, with 15%, which may have had an impact on the unexpectedly good election result of this party. That cannot be said for the SRS, which spent as much as one tenth of the total costs of the TV campaign, and received five times less percentage of votes in the elections. If the costs for the parliamentary elections were considered separately, it could be concluded that the investment of the SNS was significantly more profitable than that of the SPS, because it won 3.75 times more mandates with 16% more money invested. Thus, the investment of the SRS looks even more catastrophic, because with 19% of the value of TV commercials for the parliamentary elections, this party received only 2% of the votes.

In relation to the amount of TV investment, it could be said that the opposition coalitions UPS and Moramo, as well as Dveri and Zavetnici, achieved very good results. With the DSS (NADA) and the "Ajmo, ljudi" list, investing is approximately equal to electoral success.

Some lists did not use this type of advertising at all. The expensive TV campaign was avoided by the Sovereignists, which may have contributed to the weaker election result, while minority parties traditionally do not advertise on the national media, but on local ones in areas where potential voters are predominantly concentrated. The only minority list that did that was Together for Vojvodina, which obviously did not count only on members of the Croatian national minority, but on the wider electorate in Serbia.

Different types of choices. From the point of view of the Law, each election process is special and the participants in the elections will have to precisely differentiate the costs of the campaign for the presidential, parliamentary and local elections. The practice so far has been that this seems largely arbitrary, depending on the extent to which the costs of a particular type of choice need to be justified. The Law itself did not set strict rules for such a delimitation, which would be necessary, especially in situations when the same advertising message calls on citizens to give support to the same party or group in two or even three types of elections. According to our monitoring, the value of the presidential and parliamentary election campaigns (which started two weeks earlier) was approximately the same - about 3.2 million euros. The TV campaign for the Belgrade elections was significantly more modest - less than 250,000 euros. This is obvious in connection with the budget allocations, which in the case of the Belgrade elections are symbolic in relation to the republic level. Each participant in the campaign could count on only 16 thousand euros from the budget, and a total of half a million was distributed.

By TV stations. The largest part of the ad cake refers to TV Pink and its connected cable channels (around 2.6 million euros), RTS (1.8 million), Happy (1.2 million, based on discounts from previous elections) and the group PRVA-B92 (831 thousand euros), while it was significantly lower with cable TV stations.

Facebook: Thanks to the possibility of insight into political advertising on this social network, in this election we had data on paid advertising of individual participants. In the first three months of this year, which includes the campaign before the campaign that many participants led, but does not include the first three days of April, about 400 thousand euros of political advertising costs were registered in Serbia.

Half of that amount refers to various orders openly supported by the Serbian Progressive Party. It is interesting that the next one is SVM with about 32 thousand euros of paid ads. Also, Dveri, the coalition Moramo were very active on this social network, and to a lesser extent UPS, NADA and Sovereignists. In addition to these costs, which we believe will find a place in the financial statements (at least for the period from February 15, that is, after the elections), the political campaign was led by entities whose party profile was not clearly marked, worth over 35 thousand euros. These ads were mainly aimed at promoting the results of the city authorities in Belgrade or were a campaign against opposition parties. The control of these unregistered campaign participants is not adequately secured or regulated.

oglašavanje na FB

Billboards: The analysis of the data we collected during the monitoring so far indicates a significant increase in this type of costs. Namely, in the observed sample for Belgrade, the total number of billboards increased by 90% compared to the campaign from two years ago. We asked the City Administration for data on the total number of issued permits, but we have not received them yet. When it comes to the number of ads of a political nature, they increased by as much as 170% in the observed sample compared to 2020. At that time, we estimated the value of the campaign at 720 thousand euros, and now the calculations are underway. This was obviously greatly influenced by the fact that elections to the capital were held in parallel with the republican elections.

In the Belgrade campaign, in the last two weeks, the SNS had 45% of billboards, followed by the SRS, SPS, UPS and NADA with over 5%. At the beginning of March, there were significantly fewer participants in this type of campaign, and in addition to the SNS, the SRS, SPS, NADA and Moramo were also represented at the time.

In other cities, such an increase in the number of billboards was not noticed, and in Novi Sad there was even a decrease in the number of political billboards compared to the same period in 2020. There, however, the SNS's dominance was even more pronounced (2/3 of the total number of billboards).

Cases of irregularities in the financing of the election campaign

Transparency Serbia also dealt with the expenses of the election campaign of the participants in the April elections by devoting part of its activities to monitoring whether the participants in the elections respect and to what extent the ban on its financing prescribed by the Law on Financing Political Activities. On this occasion, TS, using the available legal means, submitted four applications to the Agency for the Prevention of Corruption and one initiative to the Supervisory Board for the election campaign for the 2022 parliamentary elections.

Chronologically, the first application to the Agency was submitted in February 2022 due to the suspicion that certain publications on the account under the username "Aleksandar Vučić @ avucic", on the social network Twitter, i.e. those that inform citizens about the activities undertaken by the Serbian Progressive Party may violate the said prohibition. The report points out that the account, among other information about him, reads that it is "Official order of the President of Serbia and the President of the SNS", which is why he, although it is a social network that provides its users with free vision communications, can be considered a public resource that has been used to achieve a benefit (political promotion and advertising) for the party of which he is president and whose logo and name are on the said announcements. On the occasion of this report, the Agency submitted to the TS the Notification on the outcome of the procedure and the Decision which determines that there are no grounds for deciding on the existence of a violation. In the explanation of the Decision, the Agency, based on the insight into the official website of the President of the Republic of Serbia, concluded that the official account of the President https// is on the social network Twitter, which is why the account under the user name '' AleksandarVučić @ avucic "It does not represent an official order of the President of the Republic of Serbia." In addition, according to the Agency, the account on the mentioned social network Twitter is not a public resource, which is why the Serbian Progressive Party did not violate the ban on financing political activities.

At the same time, TS, emphasizing that we know that the presidential elections have not yet been called at the time of its submission, filed an application due to suspicion that the statement - statement of Deputy Prime Minister and Minister of Defense Dr. Nebojsa Stefanovic, published on the official website of the Ministry of Defense may constitute a violation of the said prohibition if it is present even after the announcement of the presidential elections. Despite the fact that the mentioned statement was published on the official website of the state body and signed as a statement of a public official, it is obvious from its content that it does not refer to measures and activities that the Ministry of Defense is authorized and obliged to undertake. It concerns persons who are presented in the media and by political entities as future presidential candidates in the presidential elections, the holding of which was announced for April this year. In it, primarily, the Deputy Prime Minister and the Minister of Defense express himself negatively about Zdravko Ponos, using the official web presentation of the Ministry of Defense for a negative campaign against him. At the same time, a statement-statement promotes Aleksandar Vučić, President of the Republic of Serbia and a person who is also presented in the media and by political entities as a future candidate in the presidential election, thus benefiting (political promotion and advertising) for him. Regarding this application, the Agency deviated from the valid legal regulations and common practice, and TS submitted only the notification on the outcome of the procedure, without submitting an appropriate decision. In the mentioned Notice, the Agency, even after confirming all the facts from the application, concludes that the presidential elections were not called, ie that the statement does not mention the Serbian Progressive Party, which is why it estimates that the political party did not organize the publication of the said statement. attribute responsibility for its publication.

TS also filed a complaint due to suspicion that the preface to the brochure entitled "Dela govore/We did it together", authored by Aleksandar Vučić, and on the cover of which, in the lower right corner, the Serbian Progressive Party logo can be seen, may violate the ban. The application points out that the public function of the author of the preface - the President of the Republic of Serbia, as well as official flags - the inventory of state bodies were used to promote and advertise a political entity of which he is also president, and whose logo and name are on the cover. On the occasion of this report, the Agency submitted to the TS the Notification on the outcome of the procedure and the Decision which determines that there are no grounds for deciding on the existence of a violation. In the explanation of the Decision, the Agency, based on the insight into the brochure, assessed that the photo illustrating the foreword was a previously published and available photo whose production was not financed by the Serbian Progressive Party or created for the purpose of making the brochure. the said ban.

TS, emphasizing that the announcement on which the application is submitted was made after the announcement of the elections for deputies and was not removed even after the announcement of the presidential elections and the announcement of certain presidential candidates, submitted another application. The report was filed due to suspicion that certain parts of the statement of Deputy Prime Minister and Minister of Defense Dr. Nebojsa Stefanovic, entitled "Minister Stefanovic: Serbia is proud of its army today", published on the official website of the Ministry of Defense, may violate the ban. Similar to the first time, this time the statement was publicly available at the official presentation of the Ministry of Defense, although some parts of it were directed towards political opponents of the Minister of Defense and the party to which he belongs. By publishing the statement, the official web presentation of the Ministry of Defense was used for a negative campaign against the candidates for MPs who were on the electoral list of a political entity that competed in the elections with the party belonging to the Minister of Defense, as well as for negative representation. in the media and by political entities, at the time of publication presented as future candidates in the upcoming presidential election. This time as well, the Agency submitted to the TS the Notification on the outcome of the procedure and the Decision which determines that there are no grounds for deciding on the existence of a violation. In the explanation of the Decision, the Agency concluded, after confirming all the facts stated in the application, that the mentioned statement does not mention the Serbian Progressive Party. Also, the Agency accepted the statement of the party's proxy according to which that party cannot control the announcements and assessed that the Serbian Progressive Party did not organize the publication of the mentioned statement, nor can it be attributed responsibility for its publication.

When it comes to the Supervisory Board for the election campaign for the parliamentary elections in 2022, the TS submitted the Initiative for pointing out irregularities in the conduct during the election campaign and sending warnings to the media and the Serbian Progressive Party. The initiative points to the practice, noticed in a number of media, of publishing news on their web pages, the content of which is a textual presentation of the statements of Serbian Progressive Party officials from the video, including the statements of Aleksandar Vučić, which illustrated this news. At the same time, the only and basic goal of publishing such news is to inform the citizens that "the Serbian Progressive Party published a new pre-election video on its YouTube channel called" Each of us is special and important. " Because it is an informative activity that is not, in fact, it is a covert political advertisement by broadcasting a video of a political entity that achieves a double benefit - greater visibility of their election videos among readers of these media and completely free of charge because broadcasting does not pay for the pre-election video in that way, TS called on the Supervisory Board to supervise the actions of the representatives of the Serbian Progressive Party and the media, determine the facts of possible violations of the rules and principles of equality, point out irregularities in the election procedure.

Preliminary reports on campaign financing

Preliminary reports as recommended by the ODIHR: One of the amendments to the Law on Financing Political Activities is the introduction of the obligation to submit preliminary reports on campaign financing. Although one of the ODIHR's recommendations was formally met in this way, it was done in a way that does not allow for significantly greater transparency of this data during the election campaign.

Small benefit: As TS warned, making a report on finances 15 days before the election does not bring much, because parties pay most of the costs later, and mostly only after the election, when they receive the bulk of budget grants.

Late Arrival of Budget Alocations: The deadline for payment of the part of budget grants paid before the election, to those who have submitted the election guarantee, was March 24, 2022. for the presidential elections (46,126,500 dinars each) and March 27 for the parliamentary elections (20,500,667 dinars each), that is, nine or six days before the voting day, so that the preliminary reports do not include even these party revenues.

A better solution for transparency: Therefore, we proposed that a system of transparent accounts be introduced in Serbia, following the example of the Czech Republic, which would enable real-time insight into revenues and expenditures, while protecting certain personal data (eg account number and address of contributors). ). All other information is otherwise public and would be published in the financial statements or would be available upon request for access to information.

Concerns - Unpaid Expenses: No less important, given that campaign expenses are paid deferred, we proposed to unequivocally prescribe a reporting obligation, not only on expenses incurred, but also on contractual obligations (e.g. the value of billboards or advertisements that are contracted). Neither the Law nor the Rulebook passed by the director of the Agency for the Prevention of Corruption are clear enough about whether only the costs that have been paid or those that are still "pending" are reported. As a result, in practice, different interpretations are possible and a situation in which one party would show the cost and the other not, even though they are in the same situation. That probably happened, judging by the published data.

What was the deadline for reports: Although according to the Law the deadline for submitting reports is "seven days before election day", that is, Saturday, March 26, 2022, the Anti-Corruption Agency interpreted that the rules for calculating deadlines from the Law on general administrative procedure, so the deadline was set for the first following working day, Monday, March 28, 2022.

Reports are unavailable almost until the beginning of the election silence: The law did not introduce an obligation for campaign participants to publish the submitted reports on their website, but only an obligation for the Agency to publish them within three days of receipt. Due to such a deficient provision and interpretation of deadlines that obviously hinders the achievement of the purpose of these reports, the deadline for their publication was the last day before the election silence (March 31, 2022).

This practically prevents any analytical reporting of the media on how the submitters of electoral lists and nominators of candidates fulfilled their legal obligation, as well as the possibility for a large number of citizens who would be interested to know something about the costs and sources of financing the campaign. a month and a half.

This shortcoming is all the greater when it is known that by far the largest part of that campaign will be paid by those citizens themselves, because a record 15.7 million euros are being distributed from the budget for this year's presidential and parliamentary elections.

Who violated the legal obligation: By the day of the election, a total of 93 preliminary reports had been published on the Agency's website. Seven refers to the presidential elections, so it can be concluded that everyone fulfilled the obligation, except the nominator of the candidate, Miša Vacić.

15 reports were published for the parliamentary elections, and the lists "Muftijin amanet" (SPP), "Alternative for Change - Albanian Democratic Alternative", "Roma Party" and "Russian Minority Alliance" did not fulfill the obligation. The only thing missing from the Belgrade elections is the list of the "Russian Minority Alliance". The other 60 reports relate to elections in other cities and municipalities.

How many costs have been reported so far: Collectively, for the presidential elections as of March 18 (or 19, depending on the interpretation), March 2022, costs have been reported in the amount of 104,710,992 dinars, ie about 880 thousand euros, as well as revenues of 111,889,644 dinars (about 950 thousand euros). 225,776,210 dinars (about 1.9 million euros) of expenses were reported for the parliamentary elections and a shade more income (251,042,803 dinars, about 2.2 million euros).

What is the share of campaign costs known to the public: Bearing in mind that about 3.1 million euros were collected from donations and transferred from standing accounts (part of which will be returned after receiving budget money), as well as the fact that parties and groups traditionally they tend to cover every dinar of the received budget money with their accounts, it can be assumed that the total reported costs of the campaign for the republican elections will reach 18 million euros.

This further means that only about 15% of the total expected costs of the election campaign became known from the published preliminary reports, and that the citizens for whom the data on costs were important for deciding on the elections did not have approximately accurate and complete information. search for them yourself and find them on the Agency's website.

Credibility of the report - total amounts: Thus, for example, citizens could conclude that the SNS campaign in both types of republican elections, in the period from 15.2. until March 18, 2022, was only a shade more expensive than the SPS campaign for the parliamentary elections (104 versus 93 million dinars), which is very far from the real situation when you take into account the observed promotional activities in the campaign. Judging by these reports, the SNS participated in the total costs of the campaign with only 31%, while in reality the percentage was probably at least twice as high, the SPS with almost 30%, Dveri with 13%, the coalition Moramo with 8.3%, DSS with 3.8%, and minority SVM and SDA with as much as 4.3 and 3.4 percent, respectively.

SNS reaction: On April 1, 2022, the SNS information service, probably reacting to the estimates of certain campaign expenses presented by TS the day before, announced that the total expenditures of the political campaign "as of March 31, 2022" (last day of the campaign) were 339,877. 618 dinars (about 2.9 million euros). According to TS estimates, the value of TV commercials for this party with calculated discounts exceeds 4 million euros. Therefore, it is not clear whether the SNS provided only data on campaign expenses paid by 31.3, or only expenses related to one type of election (eg parliamentary elections).

What is shown from the costs of TV commercials: The fact that a very small part of the costs of TV commercials is reported contributes the most to the distorted picture that would be obtained on the basis of preliminary reports. Their share in the preliminary reports is only 16.09%, and based on previous experience, it can be expected that in the final reports they will amount to about half of the total campaign expenditures.

SNS was almost the only one to advertise on TV stations in the first weeks of the campaign, but reported only payments for ads on B92, Prva and regional TV stations, while advertising on RTS, Pink and Happy, which also took place during the reporting period, was not stated. It is interesting, however, that, unlike the SNS, the SPS stated the costs of advertising on RTS, and the proponents of the candidates Ponos, Jovanovic and Obradovic did the same.

Billboards: It seems that the reported costs of renting billboards in this period, where the amount exceeded 400 thousand euros, are much closer to the real ones. However, less than ¼ of the costs reported in this way go to the campaigns led by the SNS, although in reality the representation of the billboards of this party's candidates was more than half in the first weeks of the campaign. The billboard of the campaign worth between 40 and 50 thousand euros was reported by the coalition "Moramo" and "Dveri".

Public events: SPS reported the highest costs related to the organization of public events in the campaign (over 20 million dinars). The SNS reported a shade less - 12 million for the presidential elections and 7 million for the parliamentary elections.

Money from party accounts and contributions: SNS transferred 174 million dinars from the permanent party account for campaigns. Although according to the Law it is treated as "financing from private sources", that money mostly comes from the budget (money that the party received for financing work outside the campaign, based on representation in the Assembly). There is a noticeable lack of collection of contributions, although this is the party that has by far the largest number of members and which has previously used this type of financing extensively.

On the other hand, the SPS reported as much as 80 million dinars in contributions from individuals and another 39 million dinars from a permanent party account (ie budget grants for regular work). The SRS, which has not been represented in the national parliament for more than two years and has not received significant budget grants, obviously has saved money from before, so it transferred 28.5 million dinars from the permanent account. SVM transferred and spent half as much money, and the Coalition of Albanians of the Valley 4.4 million dinars.

DSS (about 6.7 million dinars), lists led by Marinika Tepic (3.1 million) and Boris Tadic (2.8 million), as well as the Coalition "Moramo" (2.7 million) and Dveri (1.4 million).

No income ?: "Zavetnici" (whose campaign cost until March 18 was allegedly only 45 thousand dinars), the coalition "Sovereignists" (with a cost of 7.3 million) and the "Otete bebe" did not report a dinar of income on any basis. With the SDA, the income was negligible (81,000), and the reported costs reached 11.4 million dinars. It is interesting that the mentioned lists and nominators of candidates (except for the SDA) did not list some costs that are common among others and that had to be incurred at the very beginning of the campaign - signature verification.

Research and communication: Among the data that can be mentioned as a curiosity or as a question that requires checks, we single out the very high costs of public opinion polls in the report "Dveri" (almost 4 million dinars) and the absence of communication costs in reports DSS, Zavetnici and GG United for Serbia .

Travel expenses: According to the reports, Dveri spent the most on trips and tours of Serbia - about 30 thousand euros, which is seven times more than all other lists and candidates combined. As this is unlikely, the question remains whether their cost is exaggerated or left out by other parties.

Signature verification: The differences in the price of signature verification are huge - from 27 thousand dinars for the presidential candidate Zavetnici, to 3.2 million dinars for the SNS candidate (and 1.5 million for the party's electoral list).

Internet and social networks: Advertising on the Internet was reported only by "Sovereignists", SVM, "Moramo" and "Dveri", and other advertising costs, which may include social networks (no special section is prescribed) are reported by UPS, "Moramo", "Dveri" and the list "Ajmo, ljudi". The SNS did not report a dinar of expenses in the reports for the presidential and parliamentary elections on the Internet, although it was the most represented in this type of advertising as well. "Other advertising costs" are an unusually high item in the SDA Sandzak - 4.8 million dinars. On the other hand, on the social network Facebook, numerous advertisements were registered in the same period, which promoted SNS, Dveri, SVM and the coalition "Moramo".

Newspapers and radio: Reported investments in the print media reached 100 thousand euros, and on radio stations a modest 30 thousand.

Overall Conclusions: The introduction of the obligation to submit preliminary reports on campaign finance has somewhat increased transparency, but in a way that does not achieve the desired goal and can lead to erroneous conclusions. Instead of giving citizens an insight into the price of the campaign before deciding on the elections, most of the reports became publicly available only in the afternoon of the last day before the election silence, so any serious analysis or discussion about them was impossible. This situation arose, among other things, due to the interpretation of legal deadlines in a way that is contrary to the meaning of the introduction of this obligation. The reports show the state of finances with a cut of 15 days before the elections, by which time a relatively small part of the costs was paid - according to TS estimates in these reports can be found only about 15% of campaign costs that will eventually be reported. It is obvious that the parties used different methodologies when presenting data in preliminary reports, when reporting delayed payments, so these reports can lead to erroneous conclusions about the campaign price of individual election participants. In addition, large differences in the amount of individual costs, as well as the absence of reported revenues and expenditures for some election participants are already calling into question the correctness of financial reporting. Five participants in the republican elections did not submit reports at all, for which fines were prescribed. The Anti-Corruption Agency has not yet made public their names. Although there is no legal obligation to do so, the publication of this data, immediately after the deadline, could have increased public interest in this legal novelty and increased its effects.