Campaign finance laws in Myanmar remain insufficient. Even when strong campaign finance laws exist, election management bodies must ensure the laws to be fully and fairly monitored and enforced. While the election laws prohibit vote buying, some voters interviewed by ANFREL revealed that incidents of political parties giving out money in exchange for votes are frequent. Complaints related to vote-buying and excessive campaign spending should be thoroughly investigated. UEC Neutrality & Transparency The Union Election Commission of Myanmar (UEC) is a permanent institution tasked with handling all election-related matters in the country. It is composed of a minimum of five members (currently 15, all male), all appointed by the President. The UEC is assisted in its duties by 15 state and regional sub-commissions (including one for the Nay Pyi Taw Union Territory), 82 district sub-commissions, 326 township sub-commissions, and 17,067 ward/village tract sub-commissions. Much of the staff required by the UEC around election times to conduct its duties is provided by other government agencies. All members of the current commission were appointed in or after March 2016, which means that the UEC’s entire composition has changed since the 2015 general elections. While the UEC is nominally neutral, the fact that its members are all political appointees of the incumbent government makes the institution vulnerable to accusations of bias. Such claims were widespread throughout the 2020 general elections, with most political parties accusing the election management body of preferential treatment in favour of the ruling party. One often-cited example was the start of the campaign period; many parties and candidates reported that they were made aware the campaign would start on 8 September 2020 through an announcement by the UEC only two days before. However, they claimed that the NLD had been given a head start so that they would have enough time to organise flag-raising ceremonies across the country to mark the start of the election campaign. While such allegations are of course impossible to verify, they damage the perception of the UEC regarding its purported neutrality. Other UEC decisions that have stirred criticism among opposition parties for their alleged pro-NLD bias include the timing of the general elections amid a COVID-19 outbreak, postponements of the polls in selected areas of the country, and the late dissolution of the Union Democratic Party (UDP). ANFREL’s review of these issues seem to indicate that at least some of these claims hold up against scrutiny and that the ruling party indeed seems to have enjoyed an edge over its competitors ahead of the polls. However, ANFREL also believes that much of the criticism against the election management body is fueled by a lack of consultation in its decision-making process. Although the UEC regularly held press conferences and published announcements through state and mainstream media, it has also provided little information as to how exactly those decisions were reached and on what basis. The security-related election postponements are a good example of this, as they were criticised not only for their lack of consistency but also because the UEC failed to consult local stakeholders ahead of its announcements. Many civil society organisations interviewed by ANFREL considered the current election commission harder to reach out to, and to obtain information from, than its predecessor. Election management bodies worldwide have a responsibility to make their decisions as open as possible to foster trust in democratic processes. The UEC could also consider promoting open election data, regular stakeholder consultations or outreach programs in order to implement more inclusive and consensual policies. Finally, we invite the UEC to communicate in a clear and timely manner, which would go a long way in getting election stakeholders informed and supportive of the commission’s work. 38