An amendment promoted by MP Vasile Gradinaru, which removes citizens’ ability to submit recommendations verbally during public consultation meetings, has drawn strong criticism from civil society organizations.
Promo-LEX and several other NGOs argue that the amendment restricts citizens’ effective participation in the decision-making process and represents a “significant democratic regression.”
The amendment was proposed on August 24, 2026, and incorporated into the draft Law on Public Participation in the Decision-Making Process. The bill was subsequently approved in its second reading on August 25, with 59 votes.
Under the current rules, recommendations made verbally during public consultations can be recorded and considered by authorities. The new provision would remove this possibility, meaning that simply expressing an opinion during a public meeting would no longer constitute an official recommendation.
Civil Society Warns of Restrictions on Public Participation
The organizations have also criticized the arguments reportedly used to justify the amendment.
During a meeting of Parliament’s Legal Committee, the amendment’s author reportedly cited the risk that verbal recommendations could be recorded inaccurately, as well as the significant workload involved in documenting them.
The Parliament’s General Legal Directorate also cited the argument that accepting verbal recommendations “could provide an unjustified advantage” to people who do not make the effort to submit a coherent legislative proposal in writing.
Promo-LEX considers these arguments disproportionate and says they reflect a misunderstanding of the purpose of public participation.
According to the organizations, oral participation is not a privilege, but one of the ways citizens exercise their freedom of expression and their right to contribute to public decision-making.
Critics warn that the changes could particularly affect people who have difficulties preparing written documents, including elderly people, people with certain disabilities, those with limited literacy or digital skills, as well as residents of rural areas with limited access to technological means of communication.
“Oral participation is not a privilege, but a way of exercising freedom of expression and the right to participate,” the organizations said.
They argue that keeping public consultation meetings while removing the possibility for opinions expressed there to be recognized as recommendations and examined by authorities could turn such meetings into a mere formality.
NGOs Also Challenge Rules on Repeated Consultations
Civil society organizations are also criticizing a second amendment that would narrow the circumstances in which public consultations must be repeated after substantial changes are made to a draft law.
According to the NGOs, the new wording conflicts with Law No. 100/2017, which provides for repeated endorsement, expert review and public consultation procedures when more than 30% of a draft’s text is amended.
The organizations further note that the amendments were not subjected to consultations with civil society, despite directly affecting the rights of participants in public consultation processes.
“These changes represent a significant democratic regression,” Promo-LEX said together with the Center for Policies and Reforms, the National Platform of Youth for Active Participation, LID Moldova and IPRE.
The organizations say the amendments are particularly concerning given Moldova’s commitments under the EU integration process to strengthen transparency and civil society participation.
They point to the EU’s common position on Cluster 1 – Fundamentals, which emphasizes the need for public consultation processes to become “more systematic and meaningful.”
Similar Amendment Made to Draft Parliamentary Code
A similar amendment was also introduced into the draft Code on the Organization and Functioning of Parliament, at the initiative of MP Radu Marian.
The amendment likewise removes the possibility of submitting verbal recommendations during public consultations. The draft Code was approved in its second reading on August 24, with 52 votes.
Promo-LEX also notes that the draft Parliamentary Code had previously been sent to the Venice Commission in a version that allowed verbal recommendations.
The organization argues that the Venice Commission will therefore be unable to assess the latest changes because it was not informed about the updated version of the draft.
NGOs Call for Amendments to Be Reconsidered
The civil society organizations are calling on the parliamentary majority to reconsider the amendments, restore citizens’ ability to make verbal recommendations and require authorities to record and examine them.
They are also calling for parliamentary amendments affecting public participation to be subjected to public consultation and sent to the Venice Commission for review.
The organizations are additionally asking President Maia Sandu not to promulgate the Law on Public Participation in its current form and to return it to Parliament for revision.