Untangling Political Finance - Transparency International...CRINIS – ray of light in Latin – is a jointly developed project of Transparency International and The Carter Center

Untangling Political Finance

Transparency in Funding of Elections Campaigns - Kosovo 2013 3

Untangling Political Finance

Kosova 2013

Crinis Research Project

Kosova Democratic Institute (KDI)/

Transparency International Kosova (TIK)

Front-page (picture): Jeton Mikullovci

June 2013

Kosova Democratic Institute (KDI) / Transparency International Kosova (TIK)43

Acknowledgements

CRINIS – ray of light in Latin – is a jointly developed project of Transparency Internationaland The Carter Center. It evaluates and compares levels of transparency and accountabilityin party and campaign financing systems, and allows for targeted advocacy for reform of thelegal structure and change in practices. Using nearly 150 indicators, it detects weaknessesand strengths in key areas. CRINIS is currently implemented in Albania, Croatia, Kosovo,Macedonia, and Serbia.

This research report is made possible with the combined efforts of the Kosova DemocraticInstitute and Transparency International Kosova devoted to among other things: promotingtransparency and accountability in political finance in the Republic of Kosovo. Special thanks go to the following:

Researchers

Colleagues

Donor

Last but not least, Transparency International Secretariat in Berlin for the methodology usedfor this research. Tinatin Ninua, Helen Turek, and Andrew Mcdevitt deserve special mentionfor hours of work they put in to validate the results and commenting on the report in its variousstages.

Thank you all.


Personnel:

Ismet KRYEZIU - Executive Director Email: [email protected]

Valmir ISMAILI - Coordinator of ProjectsEmail: [email protected]

Vjollca VOGËL - Admin & Finance ManagerEmail: [email protected]

Leonora CIKAJ - Admin & Finance AssistantEmail: [email protected]

I Program

Democratization and Parliamentary Practices

Project:

10 Years of Parliamentary Work

Driton SELMANAJ - Program ManagerEmail: [email protected]

Besnik RAMADANAJ - ResearcherEmail: [email protected]

Project:

Activism Increase in communities and

citizen inclusion in decision-making

Driton SELMANAJ - Program ManagerEmail: [email protected]

II Program

Local Governance and Civic Participation

Project:

Participation of Citizens in the Democratic

Processes

Naim CAHANAJ - Project ManagerEmail: [email protected]

Arben HOXHA– MonitorEmail: [email protected]

Project:

Citizens’ inclusion in transparency and

accountability

Jetmir Bakija – Project ManagerEmail: [email protected]

III Program

Transparency and Anticorruption

Project:

Transparency and accountability in

public procurement

Merita MUSTAFA - Project managerEmail: [email protected]

Isuf ZEJNA – Senior researcherEmail: [email protected]

Shqipe GJOCAJ – ResearcherEmail: [email protected]

Project:

Crinis

Besian BICURRI – AnalystEmail: [email protected]

IV Program

Free and Fair Elections

Valmir ISMAILI - Contact PersonEmail: [email protected]

Dardan BERISHA - DiA Secretariat coordinatorEmail: [email protected]


Table of Contents

Foreword …...............…………………………….............……….……………………………................. 7

I. Executive Summary ……………………………….............……...........................….…........... 8II. Introduction and Background to the Study ………..............…………………...........……..….10III. General Context on Political Party Financing ……..............………….…….….………..…..…11IV. Methodology…………………………..…………………..............……………….……..…..……14V. Research Results: overall findings ……...………….…..............……………….…..……..…...18

Dimensions

1. Internal bookkeeping………………………….…….....………..............………...........…….… 192. Reporting to the Oversight Agency………………….…….…...............……….…...…...….….. 203. Scope of Reporting………………………………….………..…...............…………................. 224. Depth of Reporting………………………….…………….….….……..............….…................. 235. Reliability of Reporting………………………………………………..............……….…...……. 246. Public Disclosure……………….……………………….….….………….................................. 257. Preventive measures………………….……………………..…………….…..............…..……. 278. Sanctions……………..……………………………….…..……….…………......................…… 289. State Oversight………….…………………………….…..…………………...............……...…. 2910. Public oversight……………………….……… ………………………...............................…… 30

VI. Recommendations…………………………………..……………………….................…..…… 31

VII. Appendixes

1. Political Parties…………………………………………….…..…….…..............…….…...….… 362. Overview of scores by dimension…………….…………..….………..............…….……….… 363. List of Tables and Graphs……………………........................................................................ 37

5


Multiple political parties that compete with different philosophies and programs are crucialfor further developing Kosovo’s democracy. Competition between parties creates democraticvalues and a more accountable government.

In democratic countries, party pluralism is a competition amid philosophies, choices, opinions,and the people who come to terms with their political ideologies and programs. For politicalparties, money is an important tool to develop and implement their ideas and programs.

Kosovo has significantly transformed its legislative approach toward regulating the financesof political parties. However, political parties are still in the process of developing and do notalways function according to democratic principles. Lack of transparency – both from outsideand from within – in their financing, lack of internal democracy, lack of participation in buildingpolitical platforms, failure to hold elective assemblies to the deadlines defined in their statutes,and the extraordinary power of party leaders undermine the democratic values that politicalparties champion so dearly.

The low level of democracy in political parties also reflects the work of the state institutionsthat are often characterized by undemocratic decision-making processes.

In Kosovo, political parties are often challenged because some of their funding comes fromtaxpayer’s money, yet they are not transparent and misuse these public subsidies. The manyways in which political parties are financed still remain unknown due to the current legal loop-holes, non-implementation of laws in the country and the weak capabilities of the state over-sight institutions responsible for regulating political finance.

On multiple occasions, Kosova Democratic Institute (KDI)/Transparency International Kosova(TIK) has attempted to address this issue and strengthen the voice against corrupt practicesin party financing, which damage the development of political parties and the developmentof democracy in Kosovo.

With the “Crinis” project, KDI/TIK’s primary purpose is to be able to “shine a light on moneyin politics” and to participate in the future drafting and implementation of adequate legislation,which would allow for transparent financing of political parties that would eventually contributeto the building of a democratic society based on values of the rule and respect of law.

Foreword


Since the 1999 conflict, Kosovo has made asubstantial progress in reforming and regu-lating political finance and has held a total ofsix central and local elections. Learning fromthe mistakes made in each election, and withthe help from international organizationssuch as the Organization for Security andCooperation in Europe (OSCE), it has re-formed the political party finance legislationsnotably. With many political finance reformsin place, Kosovo has developed a re-spectable legal framework regulating politicalfinance that rivals other countries in the re-gion. Although the legislation in place has im-proved rapidly, implementation remains weakacross all the institutions responsible for reg-ulating political finance and other activities ofpolitical parties. The main barrier for trans-parent party financing remains the lack ofproactive monitoring of the laws in place, andproper sanctions for violations.

Concerning reporting, the majority of partiesdo not reveal all their donors; supportersthemselves are discreet because they fearblackmail. In-kind contributions are underes-timated or not reported at all. Information re-garding campaign and regular finance isdisclosed to party delegates only during an-nual party conventions. Political parties inKosovo do not use a standardized formatwhen reporting. Furthermore, the accuracy ofreports is difficult to measure because in-come and expenses, excluding the publicsubsidy fund, are hard to verify and calculateaccurately. Finally, reports are not trustworthybecause the Central Election Commission(CEC) relies only on private accounting firmsto ensure the accuracy of the information inthe financial reports of political parties; more-over, the General Auditors’ office does notaudit private donations, thus in Kosovo theverification of information is only done by pri-vate firms.

Political parties (except Lëvizja Vetëven-dosje, hereinafter VV, and the CEC do not

disclose financial records to the public.1

While the legislation obligates the CEC topublish all public documents on their page;the law does not specify an exact time frameand the publication channels. Benefiting fromlegislative loopholes, the CEC does notproactively publish financial and audit reportsof political parties. Most of Political parties donot publish their annual or campaign financialreports also. The channels through which thepublic can get information on campaign fi-nances are ambiguous to most people be-cause it is unclear where and to whom todirect the requests.

The current sanctions in place are only sym-bolic and they do not incentivize political par-ties to implement the laws. The total amountof fines issued in 2011 was 2700 EUR (US$3,475), which averages to about 451 EUR(US $578) in fines per political party that isincluded in this research.2

Although the violations of laws are many, asstated in the 2010 audit report, the CEC didnot issue any fines for non-compliance withmajor accounting rules (except for reportssubmitted late). The CEC rarely issues finesfor minor offences, allowing political partiesto be unpressured to improve the capacityand resources of their administrative staffwho prepare the financial reports.

Results from the citizen’s test (a group of cit-izens, journalists and students requested in-formation addressed to various stakeholders,such as political parties, donors, TV stations,etc) indicate that the majority of citizens donot know that their taxes fund political parties,signifying that public oversight is also weak.There is a need for greater public educationon the subject of political finance. Most peo-ple are uninformed, which leads to inade-quate supervision, and in turn creates aclimate where the CEC and political partiesdo not feel any pressure for change. Most ofthe media in Kosovo do not carry out inves-tigative reporting for party finance; they are

7

1 The CEC has only published the Annual Audit Report for 2010, and the Campaign Audit Report for electionsin Kaçanik and Ferizaj in 20122 The Annual Report for the Work and Activities of the Central Election Commission (CEC), January-December2011, Pristina, January 2012, page 243 Transparency International: 2011-2012 Global Corruption Barometer

I. Executive Summary


only reactive and rarely discover or publishviolations of legal provisions.

To improve the current laws and practices oncampaign finance, KDI/TIK recommends thefollowing measures be taken:

1. The CEC must demonstrate better trans-parency

The CEC must publish all financial reports(campaign and annual), including audit re-ports, immediately on their website. Theyshould develop an electronic archive of all re-ports and relevant documents submitted thusfar. Documents should be properly catego-rized (for instance: annual party reports, cam-paign reports, sanctions, etc.) to allow thepublic to easily evaluate the data over time.

2. The General Auditors’ Office (GAO) must

check the accuracy of reports submitted by

political parties.

GAO must audit the finances of political par-ties, including private donations. The currentpractice of outsourcing auditing to private ac-counting firms is not sufficient because theydo not systematically verify the accuracy ofreported income and expenses

3. The CEC must adopt a zero tolerance pol-

icy and impose fines for all major and minor

violations.

Sanctions should be increased and issuedfor all major and minor violations that politicalparties make. A zero tolerance policy wouldact as a strong incentive for political partiesto implement the laws. Additionally, the CECmust set up a daily interest rate fee equal tothe current market interest rates for all unpaidfines.

4. The Parliament must draft a new amend-

ment to eliminate the 100 EUR thresholds,

and outlaw, or at least reduce cash dona-

tions.

The legislation in place permits political par-ties not to report donations and expensed of100 EUR or less. This measure should be re-moved as it reduces transparency by allow-ing for discreet donations and leeway for illicit

donations.

5. The Parliament must draft a new law to

combine all the legal provisions and the re-

sulting set of laws regulating political finance

into one law.

Combining all the laws and rules regulatingpolitical finance into one law would eliminateconfusion, and enable faster access to infor-mation. The series of laws in place causeconfusion, since they are not harmonizedand sometimes contradict one another.


Transparency International developed the as-sessment tool Crinis (Latin for ray of light) tomeasure the level of transparency in politicalparty funding. Crinis is an assessment toolthat evaluates legislative systems and stud-ies the practices of key actors involved in po-litical finance. It aims to identify gaps andshortcomings in political financing systems,with the objective of promoting transparencyin political party funding. It is premised on theconviction that transparency is a prerequisitefor monitoring money in politics.

Political parties in Kosovo are perceived tobe the most corrupt institution.3

The transition to democracy with multi-partysystem after the 1999 conflict has created anopportunity for political parties to be influ-enced in their policy decisions through dona-tions. To reduce corruption in political finance,Crinis aims to make all donations publiclyavailable for everyone to see.

This research will be used to advocate leg-islative reforms, especially in areas that aredeemed to be the weakest and to inform thepublic in order to make political finance trans-parent.

2.1 Brief historical overview

Before the conflict, the majority of Kosovo Al-banians were dedicated supporters of theDemocratic League of Kosovo (LDK). Afterthe conflict, many more political partiessprung up from the disbanded Kosovo Liber-

ation Army (KLA). The most noticeable polit-ical parties that came out of the KLA are theDemocratic Party of Kosovo (PDK)4 and theAlliance for the Future of Kosovo (AAK).5

Currently, PDK and LDK generally dominatethe political scene. Self Determination Move-ment (VV)6 is lately picking up momentum bywinning thirteen seats in the Assembly.Twenty seats are reserved for Minorities.7

Prior to Kosovo declaring independence in17 February 2008, the activities and financesof political parties were regulated with UnitedNations Mission in Kosovo (UNMIK) regula-tion.8

After Kosovo declared independence, theAssembly approved a number of laws that re-placed UNMIK regulations and currently reg-ulate political finance.9

The Central Election Commission (CEC) hasdrafted a set of rules on its own initiative thatfurther defined and regulated the existing leg-islation.10

However the current legislation still has someloopholes and is not fully implemented by po-litical parties and the institutions responsiblefor regulating them. Apart from continual re-proaches from NGOs, there has not beenany significant external pressure to changepolitical finance in Kosovo thus far. Indeed,“political parties are extremely centralized,undemocratic and enjoy the image of beingthe least trusted institution.”11

9

For more details, see: http://www.transparency.org/policy_research/surveys_indices/gcb/2011

4 The current Prime Minister of Kosovo Hashim Thaqi is the party leader5 Former short-term Prime Minister of Kosovo Ramush Haradinaj is the party leader6 Lëvizja Vetëvendosje (VV) is a new political movement, which opposes some forms of international involve-ment in Kosovo’s internal affairs. They are considered nationalistic and want to hold a referendum on unitingKosovo and Albania.7 10 seats for the Serb community and 10 seats for other minorities: Roma, Askali, Egyptian, Turkish, Goranand Bosnian.8 UNMIK Regulation No 2004/11 dated 4 May 2004 following UNMIK Regulations No. 2000/16 dated 21 March2000.9 Law 03/L-073 on General Elections, Law 03/L-072 on Local Elections, Law 03/L-094 on the President of theRepublic of Kosovo, Law 03-174 On Financing Political Parties and the Law 04/L-058 On Amending and Sup-plementing the Law No. 03/L-174 on Financing Political Parties.10 The CEC has since 2008 drafted 16 Rules, the latest being on Financing of Political Parties11 Kosova Democratic Institute: Assessment of Institutional Integrity, Kosova 2011, Political Parties Overviewpg. 226

II. Introduction and Background to the study


More than a decade has passed since thefirst free elections were held; yet, political fi-nance still remains shady and political partiesare facing many problems, such as: unpro-fessional staff (uncertified accountants), un-defined political programs and philosophy,and lack of democracy in the internal func-tioning of the parties themselves.

The electoral system in Kosovo does not ad-equately represent all citizens, as Kosovo istreated as one electoral district. The Mem-bers of Parliament (MPs) do not represent allregions equally. Some municipalities areoverrepresented, underrepresented or notrepresented at all.

Given that the assurance of adequate fund-ing is one of the main ways to support a dem-ocratic system, the Crinis initiative is basedon the belief that “money is a necessary ele-ment for democracies to run smoothly butonly as long as financing is transparent, prop-erly accounted for, with full public disclosure,and subject to effective governmental and so-cial oversight mechanisms.”12 To have a suc-cessful political funding system in place thatmeets internationally recognized standards,the responsible institutions must, amongother things, proactively monitor the imple-mentation of laws in place and adequatelysanction violations.

The research results clearly show that em-phasis should be placed on monitoring imple-mentation of laws. There is clearly a greaterneed for the relevant institutions to proac-tively monitor the implementation of law andproperly sanction violations. The institutionsresponsible for enforcing the law must beoverhauled entirely as these institutionsbarely enforce the law.

Laws on Political Financing: Electoral andnon-electoral periods

In post conflict Kosovo during 1999 and2000, the United Nations Mission in Kosovo(UNMIK) was the first institution to establishrules for political party financing with UNMIKRegulations No.1999/1 and regulation No.2000/16, “On Registration and Operations ofPolitical Parties in Kosovo in March 2000.”13

These regulations allowed the political par-ties to be financed from public subsidies, pri-vate donations, in kind contributions,membership fees and other income gener-ated by political parties using their own re-sources. The UNMIK regulations obligedpolitical parties to submit annual reports tothe Political Party Registration Office (nowthe Central Election Commission, hereinafterCEC) and disclose them to the public. Inpractice however, the financial reports of po-litical parties were never made public.14

“The law on political party financing

should be amended in a manner that pro-

hibits or strictly regulates donations from

legal entities that also provide goods and

services to the public administration,

obliges political parties to have a single

bank account and defines time limits for

publishing financial reports”

12 Carter Centre, Press Release of 3 June 2007, titled: Lack of Transparency in Political Financing Poses Seri-ous Problems for Countries http://www.cartercenter.org/news/pr/crinis_060407.html.13 CEC Electoral Rule 10/200114 The CEC has only published the Annual Audit Report for 2010 and the 2012 Campaign Audit Reports for localelections held in Kaçanik and Ferizaj, political parties (except VV) have never made public their accounting books.

III. General Context on

Political Party Financing


Limits on Income and Expenses

The lack of transparency and the ineffective-ness of the new regulations persuadedUNMIK to pass an additional political party fi-nance reform.15 The new regulations re-quired political parties to disclose allcampaign expenditures, income and the as-sets that they owned. The amended law wasan important step for political party financereform. Learning from a series of general andmunicipal elections, and recommendationsfrom the OSCE, UNMIK was led to pass an-other regulation which among other thingsestablished the finance disclosure andspending limits and toughened sanctions.16

After independence was declared on the 17th

of February 2008, the Assembly of the Re-public of Kosovo passed a law which furtherregulated the financing of elections, and ex-tended sanctions.17 The law was amended in2010 to address considerable pressure fromthe international community and civil society.The newly amended law addressed onlysome of the concerns and left many issuesunresolved, persuading the Assembly to passanother completely new law in 2010.18

Public funding

The new law, among other things, regulatedthe public funds that political parties receiveby allocating 0.17% of the overall statebudget to finance the regular activities of thepolitical parties and allocated another 0.05%of the total state budget to finance the localand central elections. The law further definedthe way in which public subsidies must bedisbursed by distributing 90% of funds“based on the number of seats in the Assem-

bly” and 10% of the remaining funds fornewly certified political parties.19

The 2010 European Commission (EC) Re-port for Kosovo confirmed, however that “Thelaw on financing of political parties has beenadopted, but is not fully in line with Europeanstandards. One of the key weaknesses of thelaw is that it neither prohibits nor strictly reg-ulates donations from legal entities whichprovide goods or services to the Public Ad-ministration.”20

The Assembly passed another law21 but it didnot address the remarks of the EC, in fact, itadded a favorable amendment for politicalparties by increasing the public subsidiesfrom 0.17% to 0.34% of the overall budget ofthe Republic of Kosovo.22

The 2012 amendments to the Law on Fi-nancing of political parties further strength-ened campaign financing legislation but didnot tackle the EC remarks regarding dona-tions from legal entities that provide goodsand services to the public administration. The2013 EC report from the European Commis-sion to the European Parliament and theCouncil of Europe on progress by Kosovo inFulfilling the Requirements of the Visa Liber-alization Roadmap once more affirmed that“the law on political party financing should beamended in a manner that prohibits or strictlyregulates donations from legal entities thatalso provide goods and services to the publicadministration, obliges political parties tohave a single bank account and defines timelimits for publishing financial reports.”23 At thetime of writing this report, the Ministry of Fi-nance is currently working on a new draft lawto amend and supplement the laws regulat-

11

15 Regulation No. 2001/16 Amending UNMIK Regulation No. 2000/16 on the Registration and Operation of PoliticalParties in Kosovo16 Regulation No. 2004/12 on Elections for the Assembly of Kosovo, Chapter 6, Campaign Spending Limit andFinancial Disclosure17 Law No. 03/L-073 on General Elections in The Republic of Kosovo18 Law No. 03/L-174 on Financing of the Political Parties19 Law No. 03/L-174 on Financing Political Parties, Articles 10. 2.1 and 10.2.220 European Commission: Kosovo 2010 Progress Report, Anti-Corruption policy, p 1221 Law No.04/L-058 on “Amending and Supplementing the Law No. 03/L-174 on Financing of the PoliticalParties1}22 Law No. 04/L-058 On Amending and Supplementing The Law No. 03/L-174 on Financing Political Parties,Article 2.3.23 European Commission: Progress by Kosovo towards visa Liberalization Report, Asset Confiscation, p 14


ing political finance again. The new draft lawtakes into consideration the EC remarks andis expected to go on the Assembly floor for avote in October 2013.24

Besides all the laws mentioned above (ex-cluding UNMIK regulations) that regulate po-litical finance, the CEC has adopted its ownrules.25 The new CEC rules have bolsteredpolitical finance legislation even further. Theadditional rules among other things holdparty leaders and accountants legally re-sponsible for all the information submitted tothe CEC. They also set limits on expendituresby allowing only 500 EUR (US $641) per1000 voters (0.50 cents per voter) to be spentduring elections. According to the CEC rules,political parties cannot accept donations frompeople or entities that cannot provide their fullname, address, and their personal identifica-tion number.

Unfortunately, the series of laws in placecause confusion; they do not harmonize andsometimes even contradict one another. Agood example of this muddle is the CEC rulewhich states that political parties can acceptcontributions of “no more than 20,000 EUR(US $25,815) per calendar year26 and the lawon financing political parties which states thatpolitical parties can accept donations from“legal entities, in the amount of, no more thanten thousand (10.000) Euro [US $12,907] perone (1) calendar year.”27 Future adjustmentsto laws in place must incorporate all previouslaws regulating political finance into one sin-gle law that brings all activities of political par-ties into line, including finance.

The CRINIS methodology entails an assess-ment of two different types of political financ-ing: non-electoral finances of political partiesand election campaign funding for legislativeand where applicable, presidential elections.This report looks at the assessment of cam-paign election funding in Kosovo in 2010,whereby resources were mobilized by politi-cal parties to run the eltion campaign.

The methodology involves examining theregulatory framework on transparency of po-litical financing; so as to compare it to inter-nationally recognized principles. Throughdifferent research methods, it also examineswhat happens in practice. By providing athorough diagnosis of the legal frameworkand actual practice, it provides strong empir-ical evidence to create a clear picture ofareas in need of reform. The information col-lected during the research was used to buildan index on the transparency of politicalparty funding.

The level of transparency is quantified bytaking into consideration the following ten di-mensions (Table 1).

24 Based on the current Assembly practices, the EC recommendations go on the Assembly floor for a votemore rapidly than other issues. KDI/TIK has a copy of the proposed draft law, which is not yet public.25 CEC Rule No. 01/2008 on Registration and Activities of Political Parties CEC Rule No. 12/2009: CampaignSpending Limit and Financial Disclosure, and the CEC Rule No. 14/2009 on Violations and Sanctions26 CEC Rule No. 01/2008 on Registration and Activities of Political Parties, Article 17.1 (a)27Law No-03/L-174 on Financing Political Parties, Articles 5.1.1 and 5.1.2

IV. Methodology


Internal bookkeeping (dimension 1) ties into the way in which political parties internallymanage their financial resources. Report-

ing to the state oversight agency (dimen-sion 2) evaluates the extent to which partiesor candidates report to a government over-sight body. Three dimensions – comprehen-

siveness of reporting (dimension 3), depth

of reporting (dimension 4) and reliability of

reporting (dimension 5) – center around thenature of data furnished in the financial re-ports and help to determine the quality of theinformation submitted to the oversight bod-

ies. These evaluate crucial areas like all rel-evant finance activity, including cash, in-kindand other transactions, identity of the donor,credibility of submitted data and the percep-tion of credibility of reports by key actors.Disclosure of information to the public

(dimension 6) takes a look at the public’s ac-cess to political finance information. A thirdgroup of dimensions encompassing preven-

tion (dimension 7), sanctions (dimension 8)and state oversight (dimension 9) ad-dresses monitoring compliance with estab-lished rules and regulations. This includes

13

Dimensions Generic questions for building indicators

1. Internal bookkeeping of

parties

Is bookkeeping mandatory by law? How professional is staff inpractice?

2. Reporting to state over-

sight agency (Central

Election Commission)

By law, do political parties and media render accounts on their rolein political finance? When and in what format?

3. Comprehensiveness or

scope of reporting

Do reports include public and private sources?

Do they cover income and expenses?

Do they cover monetary contributions, in-kind contributions etc?

4. Depth of reportingBy law, do reports include information on individual donations?

Do they clearly identify the donor of each donation?

5. Reliability of reportingDo different actors disclose all resources in reports?How accurate are reports, to the knowledge of stakeholders?

6. Disclosure to the public

Is it mandatory for state agencies/parties to disclose informationon political finance?In practice, how accessible is such information to experts, journal-ists and ordinary citizens?

7. Preventive measures

Are donations channeled exclusively through official bank ac-

counts?

Are there any loopholes for anonymous donations?

8. Sanctions

What are the existing sanctions - civil, criminal and political –ac-

cording to the law? In practice, are the existing laws strictly en-

forced?

9. State oversight

(Central Election Commis-

sion)

Do experts evaluate institutions of state oversight as independent?

Are they considered efficient? From the perspective of self-evaluations, do they lack human re-sources? Do they lack training?

10. Public oversight

Do civil society organizations monitoring political finance exist? Inwhich areas of political finance do they develop activities? Do experts evaluate organizations of public oversight as inde-pendent?

Table 1: Ten Dimensions of Transparency in Political Finance


preventive measures to facilitate effectiveoversight, the existence of sanctions that canbe imposed and the institutions and actors incharge of performing oversight functions. Fi-nally public oversight (dimension 10) ad-dresses monitoring and oversight role of thecivil society and media irrespective of the for-mal state oversight body with regard to polit-ical financing issues.

The information collected through the in-volvement of a broad spectrum of sourcesand different research methods, brings to-gether over 75 evaluation indicators (law andpractice). Questions feeding into each indica-tor have different range of answers, whichtranslates into different weights for the finalscore for each indicator. The scale for eachindicator ranges from 0 to 10, where 10 indi-cates that a country has met all criteria ex-

pected in terms of transparency and account-ability and 0 indicates that none of these cri-teria has been met. Scores between 0 and10 are grouped into three evaluation cate-gories: insufficient (0 to 3.3), average (3.4 to6.7) and good (6.8 to10).

In accordance with the Crinis methodologyused for this report, the legislation and theimplementation of laws for financing politicalparties during campaign elections receivedan average score of 5.5 out of 10. The resultsposition Kosovo in the average category,however when the averages for legislationand implementation of laws are calculatedseparately, we get a different picture. The av-erage score for the legislation that regulatespolitical finance is 7.2, placing Kosovo in thecategory of ‘good’ in regard to its laws. How-ever the average score for implementingthose laws in place is 4.6 out of 10, highlight-ing the need for the government to proac-

Dimensions Number of indicators Weight Law/Practice

1. Internal bookkeepingTotal 53 Law2 Practice

50% Law50% Practice

2. Reporting to state oversight agency(Central Election Commission)

Total 63 Law3 Practice

50% Law50% Practice

3. Scope of reportingTotal 42 Law2 Practice

50% Law50% Practice

4. Depth of reportingTotal 53 Law2 Practice

50% Law50% Practice

5. Reliability of reporting Total 3 100% practice

6. Disclosure to the publicTotal 146 Law8 Practice

50% Law50% Practice

7. Preventive measuresTotal 105 Law5 Practice

50% Law50% Practice

8. SanctionsTotal 126 Law6 Practice

50% Law50% Practice

9. State oversight (Central Election Commission)

Total 52 Law3 Practice

50% Law50% Practice

10. Public oversight Total 5 100% practice

Table 2. Quantitative index of transparency in political party funding Dimensions, indicatorsand weighting of law and practice


tively monitor the implementation of laws andsanction violations properly.

The categories that received the lowestscore, both for law and implementation, arethe following: reporting (to the CEC in thiscase) with an average score of 5.2, disclo-sure (4.8), sanctions (3.3) and public over-sight (4.9).28 The results clearly show thatKosovo still has legal loopholes, poor stateand public oversight and weak implementa-tion of the laws in place.

Data Sources

This study utilized both primary and second-ary sources for collecting data. Relevant lawsand regulations were examined for the as-sessment of the legislative framework. Foranalyzing the practice, the research team ex-amined the reports from political parties andoversight bodies and interviewed variousstakeholders to get insights into the operationof the party financing system and its over-sight. Key actors surveyed included six polit-ical parties, selected based on the number ofseats obtained in the last legislative election(see Appendix A), and their accountants/trea-surers. Two parliament members from eachof the six parties represented in the Parlia-ment were also surveyed. The Central Elec-tions Commission (CEC), as the major stateoversight body, served as a primary sourcewhich also provided access to some of thesecondary sources such as the 2010 AuditReport and their views on the current legisla-tion and practices of campaign finance. How-ever the CEC has not published the originalfinancial statements, the sanctions that theyhave issued and the up-to-date Audit Report.The CEC blames its non-transparency ontechnical issues, such as a lack of staff.

Field tests were conducted to measure howeasy it is for citizens to access information onthe funding of political parties and therebyevaluate rates of response from different in-stitutions, including parties, CEC, anddonors. Access to information tests was con-ducted by a research team using a standardprocedure to contact various actors. The sec-

ond tests were conducted by a group of vol-unteers of average citizens and journalists.The aim was to contrast the ability to accessthe same set of information by actors with dif-ferent levels of knowledge and contacts.

Data Collection Methods

Stakeholders, including the CEC, party ac-countants and donors contributing money tothe election campaigns were personally inter-viewed based on the survey questionnaires.Media companies, donors and parties wereprimarily contacted through letters, request-ing income and expenditure reports and de-tails of airtime given or sold to parties. In thecitizen experiment mentioned above, partici-pants were given a list of specific informationto be obtained regarding political party cam-paign funding, using different mediums ofcommunication including the internet, phoneor official letters requesting information.

Table 3 summarizes the type of informationcollected, the source of information and thedata collection method used.

28 For a visual presentation, see graph 1 and 2 on page 19

15


Limitations of the Study

There are several limitations of this study, in-cluding challenges that the research teamfaced during the project. For example, thearea of study - political financing - is ex-tremely new in Kosovo and there is limitedpublic dialogue on the issue. No previousthorough research regarding campaign fi-nance has been carried out; only research onregular annual party finance, completed byKDI/TIK. This led to various challenges asthe research team had a limited number ofsecondary data sources and had difficultiesin contacting the key respondents. Further-more, the research team was not able to ver-ify the information collected from some keystakeholders because the CEC did not givethe researchers access to the campaign fi-nance reports. The CEC is obligated by lawto publish the original reports received frompolitical parties and the audit reports. Cam-paign reports for 2010 elections have not yetbeen published (March 2013). Political par-ties (except VV, although their finance reportsdo not have a detailed list of all their donors)refused to give the researchers access totheir financial statements. The leading partyin Kosovo (PDK) and the biggest minorityparty (SLS) refused to cooperate with the re-

search team completely, they did not respondto any of our requests.

Type of Information Source of Information Data Collection Method

Legal FrameworkRelevant laws and regulations

Legal review

Internal party practices on fi-

nancial issues

Party reports, officialrecords and public infor-mation

Team analysis, comple-mented by interviews of partyaccountants and experts

Disclosure of information

Political parties, over-sight agencies, donors,media agencies

Research of publicly avail-able information

Testing availability of informa-tion from various stakehold-ers through written requests

Income and expenditure of po-

litical parties

Parties, oversight agen-cies, donors, watchdogs

Interviews

General Practice on political

finance

Parties, MPs, CEC,CSOs, experts

Interviews

Table 3: Type and Sources of Information


Dimension 1: Internal bookkeeping

The first stage of reporting by political partiesis internal bookkeeping. Legal obligations inthe area of bookkeeping and the political cul-ture of the parties are factors that can influ-ence this dimension. For parties to complywith legal regulations and uphold their ownvalues and principles, it is essential for them

to have a functioning administration, with thenecessary capabilities.

In this study, the internal book keeping of par-ties was measured with five general indica-tors. These include legal requirements forparties to keep books on income, expendi-ture and assets and their actual practice in

17

10

98.8

5.2

8.3

7.5

2.2

4.84.4

3.3

6.2

4.95.5

8

7

6

5

4

3

2

1

Boo

k - k

eepi

ng

Rep

ortin

g

Sco

pe

Dep

th

Rel

iabi

lity

Dis

clos

ure

Pre

vent

ion

San

ctio

nsS

tate

- O

vers

ight

Non

Sta

te -

Ove

rsig

ht

Tota

l

10

9

10

7.5

4.6

5.7 5.8

9

7.5 7.57.6

7.5

2.22.2

5

7

3.7

5.34.9

4.6

7.28

7

6

5

4

3

2

1

Boo

k - k

eepi

ng

Rep

ortin

g

Sco

pe

Dep

th

Rel

iabi

lity

Dis

clos

ure

Pre

vent

ion

San

ctio

nsS

tate

- O

vers

ight

Non

Sta

te -

Ove

rsig

ht

Tota

l

Table 1: Crinis Index: Graph showing overall findings with aggregated averages

Crinis Index: Aggregated Averages

Table 2: Graph showing overall results Law and Practice

LAW PRACTICE

Crinis Index: Law vs. Practice

1. Research Findings

this regard. Other indicators address ques-tions of disclosure of this information to partymembers, the standard of accounting proce-dures followed, authorized individuals to signfinancial accounting reports and whether fi-nancial records are kept for a prescribedlength of time.

Although the provisions in the law concerninginternal bookkeeping are adequate, imple-mentation remains weak as one can see fromthe graph above.

The law29 and the CEC rules30 require polit-ical parties to keep books on income, expen-diture and assets. According to some partyaccountants31 included in this research, theyupdate their accounting books quarterly,though the research team was not able toverify if political parties implement this legalrequirement because they were not grantedaccess to their accounting books.

However, looking at the 2010 audit report,32

one can clearly see that in practice almostall political parties did not comply with thelaw. The majority of parties do not reveal alltheir donors; supporters themselves are dis-creet because “they fear blackmail from theopposition party, whether in the form of fre-quent inspections, sanctions, or hitches inpublic procurement process.”33

Most political parties have accepted dona-tions that exceed the legal limit allowed.34

Regarding expenditures, reporting is not suf-ficiently detailed. For instance, according toan article in the daily newspaper Zëri, in 2012the Democratic Party of Kosovo (PDK) spent

52,252 EUR (US $66,961.5) on cars, but didnot reveal the types of cars purchased.35

The principal problem with internal book-keeping relates to “in-kind contributions”which are underestimated or not reported atall.36 In-kind contributions, usually defined asgoods or services of any value offered free ofcharge, is an area where political parties hidetheir donors the most. For example, in the2010 audit report most political parties hadunderestimated their expenses in the follow-ing categories: office rent, salaries and utili-ties. Only some political parties claim to holdoffice of any kind.37

All main political parties have branches andsub-branches throughout Kosovo; however,they have not declared expenses for branchoffices or their headquarters.38 Therefore onemust assume that their offices are providedfree of charge by members or supporters ofpolitical parties, yet they do not report this asan in-kind contribution as required by law.

Graph 1:


29 Law No-03/L-174 on Financing Political Parties, Article 6.230 CEC Rule No. 01/2008 on Registration and Activities of Political Parties, Article 2031 Accountants of LDK, AKR, and KDTP32 Audit Report 2010 http://www.kqz-ks.org/SKQZ-WEB/al/materiale/raportiiauditmit2010.pdf33 Questionnaire 11, question 124, Answered by an academic who wished to remain anonymous.34 Audit&Conto 2010 Audit Report: http://www.kqz-ks.org/SKQZ-WEB/al/materiale/raportiiauditmit2010.pdf35 Zëri (Kosovo), “Kryeministri Nuk i Deklaron Financuesit e Partisë” [The Prime Minister Does Not Reveal hisParty’s financiers], 18 March 201336 Audit Report 2010: http://www.kqz-ks.org/SKQZ-WEB/al/materiale/raportiiauditmit2010.pdf37 Audit Report 2010: http://www.kqz-ks.org/SKQZ-WEB/al/materiale/raportiiauditmit2010.pdf38 Personal interview with an Anonymous political party accountant on 22.11.2012 and a local branch partyleader in one of the municipalities of Kosovo on 12.01.2013

Practice

Law

7.5

10

1086420

Internal Book-Keeping

Law: 10Practice: 7.5

According to party accountants39 the informa-tion regarding campaign and regular financeis disclosed to party delegates only duringannual party conventions. Some party mem-bers interviewed for this report have admittedthat they do not know how their campaignsare financed.40

In most cases, even the person running forlegislative elections does not know howhis/her campaign is financed by the politicalparty he/she is representing. Ardian Gjini, aMember of Parliament (MP) and a memberof Alliance for the Future of Kosovo (AAK),said, “I assure you that not even political par-ties themselves know where the donationsare coming from.”41

According to the law,42 the party accountantsand the party leader must sign every ac-

counting report. Since the financial reports for2010 campaign election are not available, theresearch team could not verify if this require-ment is implemented. However, according tothe party accountant for Democratic LDK, Mr.Lutfi Zharku, party leaders and accountantsdo not have to sign the reports because evenif they do not, they are still legally liable for allthe information provided in the reports.43

The law does not require the party account-ants to be certified; it only states that theyshould be properly trained.44

As a result most of the staff managing the fi-nances of parties is unqualified and unpro-fessional.45

Lastly, the law requires political parties tokeep records of all documents for a period ofseven years.46

According to party accountants, this part ofthe law is implemented.47

Dimension 2: Reporting to the OversightAgency

For this dimension, the study focused on fiveindicators that covered both the legal frame-work and reporting to the designated govern-ment oversight agency. These indicatorsincluded questions regarding whether partiesmust render accounts to a state agency,whether media companies are required to re-port, whether there is a specific standardized

format for submitting information and howoften reporting is required.

Besides annual reporting, the CEC rules re-quire political parties to submit financial cam-paign election reports after elections takeplace.48

The law does not require political parties tosubmit their accounting reports in a standard-ized format.

Graph 2:


39 Lutfi Zharku, Ilir Cacaj, and Enis Kervan accountants for LDK, VV and KDTP Party respectively40 Naser Osmani, Safete Hadergjonaj41Zëri (Kosovo), “Kryeministri Nuk i Deklaron Financuesit e Partisë” [The Prime Minister Does Not Reveal hisParty’s financiers], 18 March 2013.42 Law No. 03 L-073 On General Elections in the Republic of Kosovo, Article 14.243 Personal Interview with Lutfi Zharku; November 12 2012.44 Law No. 03 L-073 On General Elections in the Republic of Kosovo, Article 40.745 Audit&Conto 2010 Audit Report: , pg 7 “Almost all political subjects do not have professionals (official staff)certified as accountants who are competent in accounting and financial reports”47 Enis Kervan, Lutfi Zharku, Ilir Cacaj48 CEC Rule No.12/2009 On Campaign Spending Limits and Financial Reporting, Article 4.3

19

Practice

Law

4.6

5.7

1086420

Reporting to Atate Oversight Agencies

Law: 5.7Practice: 4.6


The law also does not require donors to sub-mit details of their donations to the CEC. TheCEC officials reason this by explaining thatpolitical parties are required by law to recordall details of their donors and submit them tothe CEC, thus it is unnecessary for donors toreport to the CEC as well, doubling thework.49 Donors were the most difficult for theresearch team to contact because they arevery secretive and like to remain anonymous.This fact is also confirmed by academics thatcompleted the questionnaires.50

The research team tried different methods ofcontact (post, emails, phone calls, and visitsto their headquarters) but only managed tointerview a few donors after assuring themthat they would remain anonymous. Thedonors interviewed described the need to re-main discreet about their political contribu-tions for fear of retaliation from whateverparty is in power. To avoid this, some donorsdonate to all political parties including theirlocal offices so as not to “interfere with dailybusiness affairs.”51 One donor in particularcited many examples, where only after do-nating big sums to the local party branch, didhygiene inspectors leave him alone. Accord-ing to the donor, it is impossible to do busi-ness in this particular municipality if you donot donate to whichever party is in power atthe moment. Furthermore, he cited exampleswhere he had to pay money, on top of whathe regularly pays to the public garbage pick-up company for them to collect the waste.After donating to the party in power, thegarbage pick-up company began to collectthe waste regularly.52

Due to the lack of relevant legal provisions,media companies do not report details of ad-vertisements to the CEC, whether paid or un-paid during campaign elections, they onlyreport to the Independent Media Commission(IMC), however in the 2009 local elections,most media companies failed to report dailylogs to the IMC53 as they are required to doby law during elections.54

Media companies are required to submit an-nual reports to the IMC, but not to the CEC.The IMC does not make these reports public.The research team requested them in writing,but they were not provided.55

The research team used an old annual reportof the IMC (2009)56 to try to examine howcampaign finance advertisement time is re-ported, but it was very difficult to understand,given that campaign advertising and regularadvertising were not specified and or sepa-rated. Furthermore, the report did not ac-count for indirect advertising the politicalparties get, such as; coverage during cam-paigns and talk shows dedicated to politicalparties.

Although donors and media companies donot report directly to the CEC, they normallyreport to other regulatory bodies, like the taxauthorities,57 as required by tax regulation.The media also reports to the IMC, an arearegulated by broadcasting laws. It is impor-tant to mention that the research team couldnot find any evidence where the CEC re-quested information from the tax authoritiesto verify details of donors and from the IMCto verify advertisement time. An IMC membersaid that they are not obligated by law to re-

49 Roundtable debate meeting at Rings Restaurant, Pristina on 22.01.2013 with Safete Hadergjonaj, Naser Os-mani, Agim Kuleta (MPs), Miradije Mavriqi (head of the Political Party Registration Certification Office at theCEC) and the KDI/TIK research team.50 Questionnaire 11, completed by an anonymous professor who is an expert on the topic of political financeand political parties in general51 Answered by an anonymous political party donor who is a major businessman in one of the municipalities ofKosovo52 Anonymous businessman who owns a multimillion dollar business and operates in one of the municipalitiesof Kosovo was interviewed by the research team.53 http://www.kpm-ks.org/materiale/dokument/1283523293.5373.pdf pg.2654 Law no. 03/L-73 on General Elections, Article 49.755 Letter sent to the IMC office on 12/08/2012 and writing via email on 10/08/2012, for which we received an an-swer confirming the acceptance of the email and that the request was going to be followed up by the responsibleperson.56 http://www.kpm-ks.org/materiale/dokument/1283523293.5373.pdf 57 Tax Administration of Kosovo

port to the CEC, thus they do not collabo-rate.58

In most countries the use of a standardizedformat when reporting is required. However,this is not the case in Kosovo. At the time ofwriting this report, The International Founda-tion for Electoral System (IFES), is workingwith the CEC to develop a standardized for-mat with which political parties must reporttheir regular and campaign election funding.59

KDI/TIK has a copy of the Request for Pro-

posal and Quotation, Political Finance Re-

porting Form from IFES, which outlines thework with the CEC to develop a new stan-dardized format for reporting electronically orin hardcopy

Dimension 3: Scope of Reporting

Scope of reporting looks into two main indi-cators: what types of funding sources are in-cluded in the reports (e.g., donations andpublic funding) and what expenses are in-cluded in the reports (e.g., expenses from pri-vate donations and expenses from publicsubsidies).

he legislation in place regarding the extent towhich political parties are required to reportis in line with international recognized stan-dards.60 The legislation requires political par-ties to include in their campaign reports thefollowing: individual/corporate monetary do-nations, private donations in kind, and moneyfrom fundraising activities.61 Furthermore, thelaw compels parties to record all campaignexpenses for the election period, and a bal-ance of payments sheet, which shows assetsand liabilities 90 days prior, and 45 days afterelections. The political parties that partici-pated in elections must save all invoices andreceipts above 100 EUR (US $128) for a pe-riod of seven years. The law, however, doesnot require political parties to include in thecampaign reports discounts on goods andservices.

The law also demands political parties to re-port all expenses and sets a spending limit of1000 EUR (US $1,281) for every 500 voters(50 cents per voter) during elections. Allmajor political parties significantly violatedexpenditure limits during 2010 elections.62

Graph 3:


58 Phone call with Drita Begolli, Member of IMC, 02/01/201359 KDI/TIK has a copy of the Request for Proposal and Quotation, Political Finance Reporting Form from IFES,which outlines the work with the CEC to develop a new standardized format for reporting electronically or in hard-copy60 Financial Reporting Standards (IFRS)61 Law No-03/L-174 on Financing Political Parties, Law No. 04/L-058 On Amending and Supplementing theLaw on Financing Political Parties, Law No. 03/L-072 On Local Elections, CEC Rule No. 01/2008 on Registra-tion and Activities of Political Parties, and the CEC Rule No. 12/2009 on Campaign Spending Limit and Finan-cial Disclosure62 Kosova Democratic Institute and Transparency International Kosova: (November 2010) Monitorimi i Kostos

së Fushatës Parazgjedhore, Zgjedhjet e Përgjithsme Për Kuvending e Republikës së Kosovës; The report ana-lyzed the actual expenses incurred (a group of people, split in teams, attended the events of the political par-ties being researched and estimated the cost of the event, or the cost of some other activity) with the expensesreported. The report found that almost all major parties underestimated their expenses.

21

Practice

Law

7.6

9

1086420

Scope of Reporting

Law: 9|Practice: 7.6

Dimension 4: Depth of Reporting

The detail or depth of information provided isjust as important as the comprehensivenessof the reporting. The usefulness of financialreports depends largely on the information in-cluded in them. Therefore, reports shouldidentify each donor, the amount and the dateof each donation, and similarly itemize ex-penditures. This depth of information allowsoversight bodies, civil society groups and vot-ers in general to examine the accuracy of in-formation provided, identify parties whodepend excessively on a few selected donorsand monitor future representatives for anypotential action that may benefit their donorsat the expense of the public. This dimensionwas measured by aggregating multiple indi-cators such as how detailed income and ex-penditure reports are and whether there is athreshold for reporting income in financial re-ports.

The legislation on the depth of reporting isrelatively strong since all the information oneach donation and expenditure must beproperly identified and itemized. Currentlegislation has a threshold of 100 EUR (US$128), and anything exceeding this amountmust be reported.63 The threshold is detri-mental to transparency and creates a loop-hole for illicit donations, by creating asituation whereby political donors can givelarge totals to a party through small dona-tions distributed to different individuals with-out having to report them.64 The reports on

income must include the following details onall donations exceeding 100 EUR (US$128) during the regular and election periodof reporting: the date, amount of each dona-tion, and the name and official registrationsof each donor.

Legal requirements for reporting expensesare satisfactory as well because reports mustinclude information such as: the date of eachexpense, the amount of each expense, thename of each vendor and official registrationfor each vendor. The implementation of thelaw in practice however is weak because de-tails regarding expenses are missing, or veryoften huge amounts of expenses are re-ported as “other expenses.”

The current legislation allows for the CEC,NGOs and voters to check the accuracy of in-formation provided in the reports. However,in practice political parties do not reveal the

full details of their donors and other relevantdetails.65 This makes it difficult to identify par-ties who depend greatly on a few selecteddonors and to monitor future work of politicalparties for any potential action that the partymay take for the benefit of its donors.

Graph 4:


63 Law No-03/L-174 on Financing Political Parties, Article 15.3.4 AND CEC Rule No. 01/2008 on Registration andthe Activities of Political Parties, Article 20.3.d & 21.1.b64 The threshold creates a possibility for political donors to distribute the total amount to different people anddonate it discreetly.65 Audit Report 2010 http://www.kqz-ks.org/SKQZ-WEB/al/materiale/raportiiauditmit2010.pdf, pg 8

Practice

Law

7.5

7.5

1086420

Depth of Reporting


Dimension 5: Reliability of Reporting

One key element of reporting - due to itsclose ties to transparency - is its reliability, orthe belief that the data that a report containsis accurate. This dimension, therefore, is per-ception based and there are no law indicators(see graph below). The reliability of a reportis related to how accessible it is to the publicand to what extent the public controls its ve-racity. If the reliability of the data is question-able, the public’s interest in monitoring willnaturally wane. Multiple indicators processedthe responses to questions such as how ac-curate reports are (for example, what per-

centage of donations is likely to be reported)and whether it is possible to obtain an accu-rate idea of the financing of parties by lookingat the official accounting statements.

Measuring the reliability of data is difficult.The Crinis methodology relies on data fromsurveys with key actors working in andknowledgeable about party financing, suchas party accountants, officials of oversightagencies and members of civil society. InKosovo, the key actors missing from this sur-vey are the election auditors as the CECdoes not have auditors that audit campaignfinances. Therefore the research team could

not rely on their opinion of the reliability of fi-nancial reports. After recommendations fromthe General Auditor’s Office, the CEC hiredan internal auditor, who does not audit theparty finances, but only the internal financesof the CEC.66 According to some Members ofParliament (MPs),67 in the newly amendedlaw they did not want to politicize the financesof political parties by authorizing auditorswithin the CEC to audit the financial reports,yet the current CEC members are represen-tatives of political parties at the CEC. The in-ternal auditor of the CEC also stated that theaccuracy and reliability of reports is difficultto measure.68

Reliability of reporting received a very lowscore because the CEC relies entirely onprivate auditing firms to ensure the accu-racy of information, and there is a lack ofscrutiny from the General Auditors office.69

Party accountants and the internal auditor ofthe CEC, have admitted that this institution isnot competent to verify the information thatthey receive.70 The fact that the CEC has ac-cepted several incomplete reports from polit-ical parties,71 which is a violation of the law,is further proof of their incompetency and lackof professionalism. Members of the CEC alsoconfirm the lack of professionalism.72 Due to

Graph 5:


66 Questionnaire #8 completed by the internal Auditor of the CEC, Mr. Sylejman Gashi, 10.12.201267 Naser Osmani and Safete Hadergjonaj68 Questionnaire 8, question# 122 completed by the internal Auditor of the CEC, Mr. Sylejman Gashi, 10.12.201269 The General Auditor’s Office audits the public subsidies but they do not audit private donations as they arenot obligated to by law.70 Interview with Enis Kervan, accountant for Kosova Demokratik Türk Partisi (KDTP) party, 05/10/2013 KDTP isa minority party representing the Turkish community. 71 The General Auditor’s Office: (May 2012) Annual Financial Auditor’s Report For the Central Election Commis-

sion For the Year ended on 31 December 2011:“most of the reports submitted by political subjects to the CEC,are not properly filed” page 2172 Questionnaire #8, question 343, Answered by Mr. Sylejman Gashi, the Internal Auditor at the CEC who wrote:“The frequent movement of the CEC employees, no doubt impacts the performance of the CEC.” AND Question-naire #9, question 122, answered by Mr. Alban Krasniqi, member of the CEC who commented that “ Irregularitiesthat appear in the financial reports can be a result of: a) the lack of proper legislation b) the lack ofprofessional/skilled employees preparing the accounting reports C) the lack of political will to be more transparentin the relationship between politics and business”

23

Practice

Law

2.2

1086420

Reliability

Practice: 2.2

the lack of auditors within the CEC whosefunction would be to thoroughly analyze thefinances of political parties; this institutionoften fails to stretch its oversight beyond ver-ifying the information received from politicalparties. In short, it lacks teeth to make politi-cal parties submit reliable reports.

The accuracy of reports is difficult to measurebecause income and expenses,excluding thepublic subsidy fund, are hard to verify, and

calculate accurately. In the 2010 Audit report,some parties did not reveal any informationregarding their donors, whereas other partiesdid not record the personal registration num-ber required by law with which donors couldbe identified.73 Therefore the research teamwas not able to identify many donors.

Dimension 6: Public Disclosure

The disclosure of financial information is akey element in ensuring that the media, civilsociety organizations, citizens and aspirantsto public office can engage in monitoringparty finances. This dimension is based onindicators which describe the types of re-quirements to which parties are subject: thedisclosure of information on public subsidies;the disclosure of information received on pri-vate financing, the frequency of disclosure;and the channels through which the public ismade aware of such information (visits to theparty, the electoral management body, inter-net access etc.)

Furthermore, additional indicators based onthe findings of field tests were used to meas-ure practices of disclosure. This included thecitizen test, in which a group of citizens, jour-nalists and students requested informationaddressed to various stakeholders (such aspolitical parties, donors, TV stations). Theseindicators are based on the following ques-tions: what information was obtained by wayof field tests conducted by volunteers? Whatwas the rate of response achieved with re-

quests for information submitted by local re-search teams? Do parties voluntarily disclosefinancial information?

Legislation in Kosovo obliges public institu-tions – in this case the CEC – to publish fi-nancial reports of political parties, but the lawdoes not specify an exact time frame and thechannels for publication.74

Thanks to these legislative loopholes, theCEC does not publish financial reports of po-litical parties.

To evaluate the willingness of political partiesto be open and transparent, the researchteam requested the campaign financial re-ports directly from them, but only Self Deter-mination Movement Vetëvendosje (VV)handed them over. The other political partiesreferred us to the CEC. The CEC directed theresearch team and citizens to their website,but this contains very little information and noannual or campaign financial reports are pub-lished (except the campaign reports for 2012local elections in Kaçanik and Ferizaj), and itfrequently does not work.75 Despite recom-

Graph 6:


73 Audit Report 2010 http://www.kqz-ks.org/SKQZ-WEB/al/materiale/raportiiauditmit2010.pdf74 Law No. 03/L-174 on Financing Political Parties, Article 15.4 “CEC should publish all annual financial reportstogether with auditing declaration of political parties in its official page”75 At the time of the writing of this report, we had difficulties accessing the CEC web- page. Recently, IFES hassupported the CEC to develop a new and more sophisticated web-page which is more user-friendly and containsmore documents.

Practice

Law

2.2

7.5

1086420

Public Disclosure



mendations that the research team made lastyear to amend the law to specify a precisetimeframe for making the finances of politicalparties public, annual finance and campaignelection reports have still not been pub-lished.76 This year again, the research teamfaced many difficulties in obtaining financialreports and other relevant documents thatthey requested. The lack of a precise time-frame does not justify the non-publication ofreports by the CEC.

The law mandating the CEC to disclose pub-lic documents is well-defined and not com-plex. It clearly states that “the CEC shallpublish all annual financial reports togetherwith auditing declarations of political partieson its official website.”77 The CEC and otherpublic institutions have formed a complex bu-reaucratic system for obtaining financial re-ports that an ordinary citizen is unlikely to beable to navigate in order to find these reportsor related information.78

The citizens’ test79 showed that a random cit-izen in Kosovo is not able to get up-to-dateinformation on party funding. For example, bymultiplying the total central budget by 0.34%,and then dividing this figure by the number ofseats in the parliament that each party con-trols, one can calculate how much each partyreceives through public subsidies. Duringelections, the percentage of public subsidiesincreases to 0.39% (0.34% for regular fi-nance and 0.05% for elections) of the totalcentral budget. However, the process of col-lecting information is difficult for citizens be-cause the amount of subsidies that eachpolitical party receives is not clearly defined.Only VV party publishes its financial reportsonline. In a roundtable discussion organizedby the research team,80 Ms. Miradije Mavriqi,

Chief of the Office of Political Parties Regis-tration and Certification (PPRO), said that thereason for the non-disclosure of documentsis the lack of staff and resources. However,the Assembly has always approved any ad-ditional funds that the CEC requested andthus far it has not lacked financial resources,a fact confirmed by the internal auditor of theCEC.81

The channels through which the public canget information on campaign finances arevague to most people because it is unclearwhere to direct requests. The law on Accessto Public Documents82 obliges all public insti-tutions (the CEC included) to appoint a spe-cial employee responsible for processingdisclosure requests. The CEC does not havean employee responsible for processing thedisclosure requests and for publishing the fi-nancial and audit reports. Furthermore, theirwebsite has a poor archive (at the time ofwriting this report, it has nothing) and thepublic cannot access the parties’ financialrecords.

Dimension 7: Preventive measures

This study assesses the dimension of pre-ventive mechanisms in political party fundingusing indicators that look at the existence ofa centralized system of bank transactions(known as a “single account”) and a ban oncash deposits which could prevent identifica-tion of the origin of donations. Furthermore,this dimension looks into the existence of pre-ventive measures against abuse of govern-ment resources and whether fiscal incentivesare present for disclosure of donations. An-other indicator focuses on whether there aremedia regulations preventing potential abuseof political influence.

76 Except the campaign financial reports for municipal elections in Kaçanik and Ferizaj77 Law No-03/L-174 on Financing Political Parties, Article 15.4 78 In the citizens’ test undertaken by 13 citizens (2 journalists, 6 students, and 5 random citizens), none of themwas able to receive the financial reports of political parties. The research team had a similar experience.79 The Test was organized by KDI/TIK and undertaken by (13 citizens 2 journalists, 6 students, and 5 randomcitizens)80 The roundtable debate was held at Restaurant Rings on 22.01.2013, present were: Naser Osmani, Agim Kuleta,Safete Hadergjonaj (MPs), Miradije Mavriqi (CEC), Merita Mustafa (Program Manager at KDI/TIK) and the au-thor.81 Questionnaire #8, question 343, Answered by Mr. Sylejman Gashi, the Internal Auditor at the CEC who statedthat “ layoffs and cut backs on financial resources have not happened”82 Law No. 03/L-215 on Access to Public Documents

25

Legislation and practice on preventive meas-ures has improved since our last report,where it received a low score of 3.0 (Law) 3.3(Practice) out of 10,83 but not significantly.This year again, it received a very low score(see graph 9 on Preventive Measuresbelow), reflecting the lack of legislative im-provements and the non-implementation ofthe current laws in place.

The latest law regulating political finance,states that all “donations of natural and legalpersons to political parties should be done ina transparent manner through a bank ac-count and should be included in financial re-ports of beneficiary political parties.”84

However it does not outlaw cash donations(lending a hand for anonymous donations) orrequire political parties to have one singlebank account. According to experts and partyaccountants, only a small amount of financialtransactions are executed via banks. In mostcases, the accountants blame economic op-erators for the poor infrastructure system ofpayments they offer and have no choice butto use cash, especially for small transac-tions.85 However the consumer part of the

banking system in Kosovo has improved a lotand bank-to-bank transfers can be done al-most instantaneously.87

There are some legal provisions for preven-tive measures against the abuse of govern-ment resources during election campaigns,such as the use of public buildings, publicemployees, etc. Nonetheless they are notreaching far enough. The law prohibits civil

servants to use state offices and other statassets for the benefits of the parties.88

Allegations of abuse of government re-sources are many,89 but they are difficult toverify as the public employees are very cau-tious and do not talk about them.

Unlike some other countries in the region, likeCroatia90 there are no fiscal incentives forcontributors or political parties to disclose do-nations. To prevent the potential abuse of po-litical influence, there are laws regulating themedia by setting limits on advertisement, freeairtime, guaranteed access etc.90 The re-search team has communicated with the IMCofficials to inquire about the level of coopera-tion between their institution and the CEC.91

These two institutions do not cooperate with

Graph 7:


83Kosova Democratic Institute KDI/ and Transparency International Kosova/ TIK: (November 2011) Legislation

and Practices in the Finances of Political Parties p 2684 Law No. 04/L-058 On Amending and Supplementing the Law on Financing Political Parties, Article 5.385 Personal Interview with: Ilir Cacaj, accountant for VV on 12.01.2012, and Enis Kervan, accountant for KDTPon 02.10.201286 Central Bank of the Republic of Kosovo (2012). Financial Stability Report, No. 3, Prishtina 2012: http://www.bqk-kos.org/repository/docs/2012/Financial%20Stability%20Report%202012.pdf87 Law No. 03/L-073 On General Election in the Republic of Kosovo, Article 3588 The use of government owned vehicles, public buildings, and even public employees for campaign purposes89 In Croatia legal entities can claim up to 2 per cent of their gross income as tax deductions on donations to po-litical parties90 Law No. 03/L-073 On General Elections in the Republic of Kosovo, Chapter VIII MEDIA DURING THE ELEC-TORAL CAMPAING, Article 47, General Provisions 47.1 “The Code of Conduct for Broadcast Media and theCode of Conduct for Print Media as issued by the Independent Media Commission, shall be applicable to all as-pects of campaign coverage and advertising”91 Personal interview with Miradije Mavriqi, the head of the Political Party Registration Office department at theCEC, on 7 November 2012 AND Phone call with IMC board member Drita Begolli, on 02/01/2013

Practice

Law

3.7

5

1086420

Preventive Measures

Law: 5 Practice: 3.7

one another to verify free airtime, paid adver-tisements or whether the distribution of freeairtime on the radio and television gave lee-way to manipulation by political parties duringelections.

Dimension 8: Sanctions

Sanctions play an important role for enforcingthe current laws in place and are a great in-centive to stop violations. As with most otherdimensions, multiple indicators that focusedon both the legal framework and practiceswere used to evaluate the dimension of sanc-tions. Questions included: are existing lawson financing of election campaigns of politicalparties adhered to in practice? Is current leg-islation in this area adequate? Are sanctionsfor violation of established rules appropriate?In order to verify if sanctions are applied, theCEC report for the annual work and the ac-tivities of the CEC to the Assembly of the Re-public of Kosovo was reviewed for the periodof January-December 2011.92

The legislation regarding sanctions is poorand needs improving, and the implementa-tion of the law is even poorer. The current lawholds the party leaders and the party ac-countants responsible for non-compliancewith the rules of political finance. Penalties

for failure to implement the law include thesuspension of parties running for elections.93

In the 2010 audit report, many irregularitieswere found, for which the law holds partyleaders and accountants liable.94

In practice, no party leader or accountant hasever been held personally responsible for vi-olations of the law.

In the 2010 audit report,many violations madeby political parties wereuncovered but were notsanctioned.95 The total

amount of sanctions issued in 2011, was 2700EUR (US $3,475), which averages to about451 EUR (US $578) fine per political party thatwas sanctioned.96 If political parties gain10.000 (US $12,823.2) EUR by breaking thelaw, 451 EUR is not a good incentive sincethey are left with 9.549 EUR (US $12,245).The CEC did not issue any fines for non-com-pliance with major accounting rules (except forthe reports submitted late), plus the CECrarely issues fines for minor offences, allowingpolitical parties to be unpressured to improve

the capacity and resources of their adminis-trative staff who prepare the financial reports.97

Graph 8:


92Annual Work and Activities of the Central Election Commission (CEC) December 2011 http://www.kqz-ks.org/en/annual-work-reports/Index93 Law No-03/L-174 on Financing Political Parties, Article 21.294 CEC Rule No.01/2008 on Registration and Activities of Political Parties, Article 19.295 Audit Report 2010 http://www.kqz-ks.org/SKQZ-WEB/al/materiale/raportiiauditmit2010.pdf96Aleanca për Ardhmërine e Kosovës (AAK), Crnogorska Demokratska Stranka (CDS), Nova DemokratskaStranka (NDS), Kosova Turk Birligi (KTB), Partia Liberale e Kosovës (PLK), AND Partia Demokristiane e Kosovëspër Intergrim (PDKI) 97 The Annual Report for the Work and Activities of the Central Election Commission (CEC), January-December2011, Pristina, January 2012, page 24

27

Practice

Law

0.5

5.8

1010

Sanctions

"The CEC is an

institution without

teeth"

Law: 10 Practice: 5.8

Dimension 9: State Oversight

State oversight is an indispensable elementin strengthening the systems that regulatepolitical financing. The independence andclear mandate of the oversight body is nec-essary for its effective functioning. It is alsovital that the institution has sufficient re-sources and the technical capacity to carryout its duties. The two indicators for this di-mension include questions on the legal man-date and institutional arrangement toevaluate whether the body has the necessarylegal powers to carry out independent over-sight of political party funding. Other indica-tors focus on examining actual practices suchas how independent is the electoral manage-ment body, as evaluated by relevant actorsin the field? What are its capacities and short-comings in terms of its resources?

The powers of the CEC are outlined in theConstitution98 and the law on general elec-tions regulates the functioning of the CEC.99

There are prerequisites for professional qual-ifications of the candidates heading theagency but the “Chairman of the CEC is ap-pointed by the President of the Republic ofKosovo from among the judges of theSupreme Court and courts exercising appel-late jurisdiction.”100 The selection process forthe top position at the CEC does notstrengthen the institutions’ independence be-cause open competition for the position ofChairman is effectively eliminated. The mem-

bers of the CEC represent their political par-ties proportionally. One can argue that partyaffiliation among members of the CEC canserve as a good check and balance by al-ways trying to pinpoint the violations made byopposing parties. The CEC has the authorityto hire an external auditor to perform ac-counting investigations of parties and candi-dates, in practice however, the CEC onlyappoints a private accounting firm to audit theannual and campaign reports, but they do notsystematically check or verify the accuracy ofreports. The last audit report was done in2010 (June 2013).

Recent analysis has shown that the legisla-tion is stronger than the practical implemen-tation. This year again, the effectiveness ofthe CEC and the implementation of laws bythe CEC remain weak. Sources who wish toremain anonymous believe that, “the CEC is

an institution without teeth” and can be easilydeceived by modifying the accounting booksaccording to their needs.101 According to an-other high-ranking official of the party, whoalso wishes to remain anonymous, the CEClacks the ability to analyze the reports sub-mitted by political parties in depth, and theyoften fail to extend the examination of ac-counting books beyond the information sup-plied by the political parties.102 Questionnaire#8, question 122, Answered by Mr. SylejmanGashi, the Internal Auditor at the CEC whostated that “In terms of the accuracy of thepresentation of reports, there exists defi-

Graph 9:


98 The Constitution of the Republic of Kosovo, Article 139: Central Election Commission (CEC)99 Law No. 03/L-073 On General Elections in the Republic of Kosovo, Article 64: Responsibilities and Functionsof the CEC100 The Constitution of the Republic of Kosovo, Article 139.3101 Anonymous political party accountant, Personal Interview. 14 November 2012.102 Questionnaire #8, question 122, Answered by Mr. Sylejman Gashi, the Internal Auditor at the CEC who statedthat “In terms of the accuracy of the presentation of reports, there exists deficiency of accuracy of reports becauserevenues and expenses, excluding Kosovo budget funds are hardly verifiable and can not be calculated accu-rately”

Practice

Law

5.3

7

100

State Oversights

Law: 7Practice: 5.3

ciency of accuracy of reports because rev-enues and expenses, excluding Kosovobudget funds are hardly verifiable and cannot be calculated accurately” In terms of re-sources, the CEC has never had any cut-backs and the Assembly has alwaysapproved requests for additional funds.103

Moreover, the OSCE has continuously pro-vided assistance to the CEC.104 Nevertheless,the CEC does not manage its funds effec-tively, a fact mentioned by the Internal Auditorof the CEC and the respondents to question-naires.105 Their claims are also confirmed bythe fact that the CEC was not able to spendall the financial resources for the fiscal yearof 2010.106

The main problem with the CEC remains itsinaction when violations are found by privateaccounting firms (the CEC rarely imposesfines for underreporting).107 The lack of audi-tors at the CEC whose sole function would bethe audit the reports of political parties alsodiminishes the capacity of the CEC to take

action, a fact confirmed by the CEC officials,observers, experts, respondents, with a lowscore of 5.3 for the implementation of laws inplace.108

Dimension 10: Public oversight

In addition to the oversight functions performedby state bodies, other actors such as themedia, academics, civil society organizationsand citizens, and at times, political partiesthemselves may engage in monitoring fundingof political parties. Proactive monitoring of po-litical finance by civil society and the media canlead to a better and more accountable govern-ment. Monitoring may include activities such asreporting irregularities to government bodies,analyzing finance reports to inform the publicand pressuring authorities to ensure that theiroversight is functioning and effective. This studyaddressed this dimension by focusing on theoversight activities performed mostly by civil so-ciety organizations and media. The specificquestions included: whether there are organi-zations that oversee election financing, whetherthey are independent, active and influential intheir activities. Another indicator also looks intothe question of whether civil society, citizens orpolitical parties report irregularities in electionfinancing to the state oversight body.

Public oversight in our last analysis was inade-quate and remains so again this year, receivinga low score of 4.9 out of 10 (see graph 10below).

NGOs play an important role in detecting flawsin the legislation, identifying holes in the imple-

Graph 10:


103 Roundtable debate held at Restaurant Rings on 22.01.2013, present were: Naser Osmani, Agim Kuleta, SafeteHadergjonaj (MPs), Miradije Mavriqi (CEC), Merita Mustafa (Program Manager at KDI/TIK) and the author104 Trainings, logistical support, etc105 Questionnaire #8, question 426, Answered by Mr. Sylejman Gashi, the Internal Auditor at the CEC who statedthat: “We are constantly seeking ways to improve the use of funds but we still lack a good/concrete plan to managethe expenditures and the quality of spending. The absence of a good plan is also highlighted in the reports of theauditor General and the internal auditor”106 The Office of Auditor General 2010 Report107 Personal interview with: Anonymous political party accountant, 14.11.2012108 Questionnaire #8, Answered by Mr. Sylejman Gashi, the Internal Auditor at the CEC. Personal interview with:Valmir Ismaili, CEC observer from KDI. In addition, IFES under the USAID funded Strengthening Election Ad-ministration in Kosovo (SEAK II) project, assisted the revision/development of forms used to report political entityfinances to the CEC.

29

Practice

Law

4.9

1086420

Public Oversight

Practice: 4.9


mentation, as well as proposing solutions. Mon-itoring is therefore essential to achieve trans-parency and accountability in political finance.

Apart from NGOs like KDI/TIK and ÇOHU,109

public oversight by other civil society elementsremains weak. Results from the citizen’s testsignify that most of the public do not know thattheir taxes fund various activities of political par-ties.110 There is a need for greater public educa-tion on the subject of political finance, as mostof them are uninformed, which leads to inade-quate supervisions, and in turn spearheads aclimate where the CEC and the political partiesdo not feel any pressure for change. The re-search team scans all newspapers daily; thesubject of political finance is rarely covered asjournalists pay more attention to other topics,such as the dialogue between Kosovo and Ser-bia and the internal party clashes, subjectswhich are covered continuously. It is worth not-ing that transparency in political finance is a rel-atively new phenomenon in Kosovo.

KDI/TIK has been involved in promoting trans-parency in political finance since 2009. The re-search team has previously maderecommendations for improving the legal frame-work on transparency of political party funding,111

and was also the first to identify gaps betweenthe legal framework and the actual practices ofpolitical parties.

According to the CEC officials, NGOs report themajority of irregularities. Next are political par-ties, and the media. Citizens hardly ever reportirregularities.112 The media plays an importantrole in uncovering violations in other countriesof the region as is verified by the discovery of acorrupt scandal involving political finance inCroatia.113 However, the media in Kosovo doesnot carry out investigative reporting; they arelargely reactive and do not uncover or report onviolations of legal provisions.

Central Elections Commission

1. The CEC must cultivate better

transparency

Transparency in party finance is important toprevent corruption and protect the rights ofvoters. The CEC must make available to thepublic all financial reports of the political par-ties (campaign and annual), audit reports,and the fines issued. Transparency in report-ing requires a timely publication of parties’ fi-nancial reports that are publicly available onthe internet.

2. The CEC must define a standardized

format that political parties are required to

use when reporting. The standardized for-

mat must itemize all relevant categories

The CEC must define a standardized formatfor reporting with which political parties dis-close all required information to allow thepublic to compare reports. The reports mustbe easily understandable for an average cit-izen, and should distinguish between incomeand expenditure. In addition, the reports mustproperly itemize private and public donationsinto standardized categories. The reportsshould include annual party finance and cam-paign finance (where applicable). Reportsmust detail if the expenses where used forthe benefit of the party or the candidate andprovide an explanation for all expenditures.

3. The CEC must hire professional/certi-

fied auditors to check the reports that po-

litical parties submit

The current practice of outsourcing the auditof financial reports is not sufficient becausethe contracted accounting firms do not proac-tively audit the reports or carry out investiga-tion. The CEC thus must hire a certifiedaccountant whose function would be to sys-

109Another NGO based in Pristina, The Organization for Democracy, Anticorruption and Dignity (ÇOHU)110 In the citizens’ test, 15 random citizens were asked if they know how political parties are financed, none ofthem knew that political parties are partially financed with tax-payer money.111Kosova Democratic Institute and Transparency International Kosova: (November 2011) Legislation and Prac-

tices in the Finances of Political Parties p 31,32112 Meeting with CEC officials (Fehmi Ajvazi and Miradije Mavriqi) on 8.10.2012113 See: http://www.gong.hr/news.aspx?newsID=3529&pageID=1

V. Recommendations


tematically audit and monitor financial reportsof political parties.

Government of the Republic of Kosovo

4. All transactions must be executed via

one bank account, and the 100 EUR

thresholds must be reduced or elimi-

nated.

The government must amend the law to re-quire all political parties to execute all trans-actions via one bank account. In addition, allcash donations must be outlawed to avoiddiscreet donations.

5. Toughen sanctions.

If a political party does not pay its obligations,such as fines, taxes, and court rulings, theyshould be banned from participating in theelections until all obligations are cleared. Ad-ditionally, a daily interest rate for all unpaidfines equal to, but not lower than current mar-ket interest rates should be imposed.

6. Harm onize and consolidate all the laws

that regulate political finance into one law.

To avoid confusion and misinterpretation, alllegal provisions related to political finance, in-cluding campaign finance, should be in-cluded in one single law.

7. Provide tax incentive for donors

Kosovo needs a tax system where the sys-tem can be used to attract contributions ofvarious means, but to also discourage illicitfunding. Making contributions tax-exempt inpart or in whole may do this.

Political Parties

8. Professionalize the administration in

preparing reports

Taking into consideration the recommenda-tions of the 2010 Audit Report, where the lackof professional staff was identified as themain cause for filling reports incorrectly. Po-litical parties are recommended to hire pro-fessional, certified accountants.

9. Assign an individual responsible for

disclosure

Political parties and the CEC must assign anindividual who is responsible for replying toinformation requests.

Civil Society and Media

10. Media organizations and NGOs must

address the topic of political finance more

frequently

Media organizations must be proactive andnot only reactive to developing news regard-ing political finance. Investigative reportingand constant coverage in print and broadcastmedia can pressure the CEC and politicalparties to reform. NGOs must constantlypressure legislators to reform political fi-nance.

31


tic Institute(KDI)

TransparencyInternationalKosova (TIK)

Bajram Kel-mendi St, No38

Pristina , 10000 Kosovo+381-38-248-038www.kdi-kosova.orgwww.ti-kosovo.org

Name of

Political Party

in its Original

Language

Name of

Political Party

in English

Acronym

Number

of MPs

in the

Assembly

Ruling /

Opposition

party

1

PartiaDemokratike eKosovës

DemocraticParty of Kosovo

PDK 34 Ruling

2

LidhjaDemokratike eKosovës

DemocraticLeague ofKosovo

LDK 27 Ruling

3LëvizjaVetëvendosje

Self Determina-tion Movement

VV 12 Opposition

4

Aleanca përArdhmërinë eKosovës

Alliance for theFuture ofKosovo

AAK 12 Opposition

5

Samostalna LiberalnaStranka

ndependent Liberal Party

ISLS 9 Ruling

6KosovaDemokratikTurk Partisi

Kosovo Demo-cratic TurkishParty

KDTP 3 Ruling

No Dimension Law Practice

1 Internal Book-keeping 10 7.5

2 Reporting to the Oversight Agency 5.7 4.6

3 Scope of Reporting 9 7.6

4 Depth of Reporting 7.5 7.5

5 Reliability of Reporting - 2.2

6 Public Disclosure 7.5 2.2

7 Preventive Measures 5 3.7

8 Sanctions 5.8 0.5

9 State Oversight 7 5.3

10 Public Oversight 4.9

VI. Annexes

Appendix 1: Political Parties

Appendix 2a: Overview of scores by dimension


List of graphs

Graph 1 Internal Book-keeping

Graph 2 Reporting to Oversight

Graph 3 Scope of Reporting

Graph 4 Depth of Reporting

Graph 5 Reliability of Reporting

Graph 6 Public Disclosure

Graph 7 Preventive Measures

Graph 8 Sanctions

Graph 9 State Oversight

Graph 10 Public Oversight

Appendix 2b) List of Graphs



Kosova Democratic Institute (KDI)

Transparency International Kosova (TIK)

Bajram Kelmendi St, No 38

Pristina , 10000 Kosovo

+381-38-248-038

www.kdi-kosova.org

www.ti-kosovo.org