On 30 April 2025, the Moldovan Parliament adopted a new provision—Article 472 of the Contravention Code ‘Corruption for organised assemblies’ —to combat electoral corruption. Adopted through a rushed and opaque process, the amendment sanctions financial incentives for participation in certain public assemblies, including those deemed to involve ‘political advertising’. While framed as a response to real concerns about organised paid protests, the provision:
duplicates existing legislation;
introduces vague and overly broad language; and
risks unjustified restrictions on the right to freedom of assembly.
Civil society has raised concerns both about the substance of the amendment and how it was adopted, warning of its potential for abuse and incompatibility with Moldova’s international human rights obligations.
Adopted in a non-participatory procedure, violating the legislation on decision-making transparency
The adoption procedure was profoundly non-participatory and violated the legislation on decision-making transparency. The amendment was included in a package of amendments aimed at combating electoral corruption on April 29, 2025, and the entire package was adopted in the second reading on April 30. It was not subject to public consultations or review by state institutions, which contravenes the legislation on transparency and participation in decision-making. It was not debated separately in Parliament but was adopted in bulk along with other legislative changes.
Redundant and vague provision risks undermining freedom of assembly
The amendment introduces a new article in the Contravention Code Article 472 Corruption for organised assemblies, aimed at penalising the following acts:
The solicitation, acceptance, or receipt of financial means for the purpose of participating in organized assemblies aimed at a) disturbing public order, b) violating public morality or the rights of others, or for c) political advertising. The proposed sanction is between 250–375 EUR for individuals.
The promise, offering, or giving of undue financial means with the intent to induce someone to participate in organized assemblies aimed at a) disturbing public order, b) violating public morality or the rights of others, or for c) political advertising. This is sanctioned with 1250–2500 EUR.
The Law on Public Assemblies already prohibits assemblies aimed at disturbing public order or inciting mass disorder, violating public morality, the rights and freedoms of others, or endangering their life or health. Article 67 of the Contravention Code also punishes violations of legislation on assemblies. In this regard, the new article brings no novelty and is redundant.
On the other hand, including ‘political advertising’ among the purposes for which ‘corrupt inducement for organised assemblies’ is penalised adds further legal uncertainty, as such assemblies are not among those explicitly prohibited. The objective of ‘political advertising’ may be arbitrarily interpreted to target a wide range of organised assemblies.
While payment for participation in assemblies may be morally questionable to some, it does not necessarily delegitimise or make the assembly illegal. Most organised assemblies involve financial and other types of costs (time, effort, etc.) for both organisers and participants. Social movements and assemblies need not be entirely spontaneous, voluntary, or devoid of financial transactions. Historically, many civic protests for human rights have been organised by associations that remunerate their organisers and members. Organisers may provide for food, transportation, or other necessities for participants without causing public harm. Electoral competitors are allowed to pay artists to perform at events for political advertising purposes. Such expenses are common during peaceful assemblies and should not be confused with corrupt practices or automatically deemed unlawful.
The article's language is vague, leaves room for interpretation, and may be abusively applied in contexts not foreseen by the legislator, posing the risk of unjustified and disproportionate restrictions on the right to freedom of assembly.
In this context, the application of the article lacks predictability and opens the door to interference with the freedom of assembly, as it does not satisfy the principles of necessity or proportionality.
International standards oppose disproportionate sanctions on incentivised participation in assemblies
The Venice Commission and OSCE/ODIHR Guidelines on Freedom of Peaceful Assembly state that: ‘the practice of encouraged participation in assemblies (for example, where organizers provide free transport to an event to would-be participants) should not be subject to legal regulation unless the provision of such incentives would contravene laws imposing proportionate limits on campaign financing’ (par. 52). In other words, paid participation in assemblies may be regulated, but only within proportional limits and exclusively in the context of electoral campaign financing. As noted, the provisions of the adopted article go beyond the electoral campaign context and are neither proportionate nor predictable.
Classifying the acceptance of material benefits for participation in assemblies as a contravention constitutes a disproportionate and dangerous interference, likely to discourage the organisation and participation in peaceful assemblies. According to international standards, sanctions against participants in such assemblies must be minimal, proportionate, and must not have a chilling effect.
Recurring efforts to address paid participation in public assemblies
Paid participation in public assemblies has been a recurring practice in the Republic of Moldova and became particularly acute during the 2024 and 2025 electoral campaigns. Journalistic investigations and police inquiries uncovered a large-scale pyramid scheme for distributing payments to individuals in exchange for their participation in protests. The main beneficiaries of these schemes are a group of electoral competitors linked to fugitive Ilan Shor, criminally convicted for bank fraud and money laundering, and is currently residing in the Russian Federation.
The adoption of Article 472 is not the first attempt to legislate sanctions for giving or receiving payments for participating in public assemblies. In July 2024, Parliament proposed an article on passive electoral corruption, which also applied to participation in public assemblies. At that time, following objections from civil society, the article was revised to remove references to payments for attending assemblies. This time , however, Parliament adopted the amendment in second reading just one day after it was proposed, bypassing any form of public consultation or debate on the matter.
While the issue of paid participation should be subject to public debate and legal solutions, the tools chosen by the Parliament to address it are unlikely to effectively combat the phenomenon.
Instead, they represent a disproportionate interference with the right to freedom of assembly.
A joint statement by Promo-LEX and CPR Moldova criticises both the content of the article and the manner in which it was adopted. The signatories call for the withdrawal of the Article 472 Corruption for organised assemblies, the development of anti- electoral corruption measures in line with international human rights standards, and transparent public consultations on any legislative changes affecting the right to assembly.
Article on ‘Corruption for organised assemblies’ highlights a troubling legislative approach—one that sacrifices rights-based safeguards in pursuit of politically expedient solutions. While the manipulation of public assemblies through financial inducement is a legitimate concern, addressing it must not come at the expense of fundamental freedoms. The provision’s vague wording, lack of proportionality, and potential for arbitrary enforcement pose a real threat to the right to peaceful assembly in Moldova. Civil society has called for its withdrawal and for future reforms to be rooted in international legal standards and developed through transparent, participatory processes. In democratic societies, protecting public order must never become a pretext for silencing dissent or deterring civic engagement.