7 Accreditation Committee. Section 40K Provides for the election observer status of the Zimbabwe Human Rights Commission (ZHRC) as represented by its commissioners or employees is given. ZHRC provides draft report on any election or electoral related process that it observes to ZEC first and must consider the comments that may be made by ZEC on the draft.  Section 40H Observers Accreditation Committee still includes employees within the executive arm of government  Section 40I Accreditation of Observers is decentralised to provinces, provides who applications are received and passed on to accreditation committee, the Minister of Foreign Affairs can invite foreign observers      Representation of persons with disabilities Section 155 (2) State must take appropriate measures Section 45 Requires that the two candidates to represent persons with disability must consist of a woman and a man. 7th Schedule Election of Senators to represent persons with disabilities This is progressive as ZEC is mandated to accredit any employee or commissioner of ZHRC who wishes to observe an election or electoral process. Given the wide mandate of the ZHRC this provision could greatly improve transparency of elections and by ensuring that the ZHRC is able to conduct its operations unhindered, however, the requirement that a draft report be provided to ZEC which makes comments that must be considered erodes the independence of ZHRC. ZEC has function of accrediting observers (section 239). Those disqualified from being appointed to ZEC is clear in terms of section 240 of the Constitution, with members and employees of statutory body, councils and government controlled entities not eligible. Provisions of section 40H must be repealed so that no one who is disqualified from being part of ZEC is part of the Accreditation Committee. While accreditation is decentralised to the provinces, there is no clear timelines for Chief Elections Officers to communicate with Observers Accreditation Committee and the applicants. They must be clear short timeframes of communication between the date of receiving the application and communicating the outcome. ZEC has function of accrediting observers; it must therefore call for all applications. Minister of Foreign Affairs, an employee of a statutory body and interested party in elections must not invite have leeway to invite certain individuals to observe the elections. Accreditation Committee must be composed of personnel from ZEC with no politicians for it to be independent as envisaged in section 235 of the Constitution on independence of Commissions – specifically that they are not subject to direction or control of anyone. The law must explicitly provide for long term observation by domestic and international observers. In addition the law must waiver accreditation fees particularly for local observers as the case in other jurisdictions in the region.  Ensure that the needs of women with disabilities will be represented in the Senate.  The majority of the board members are appointed by the Minister and there is too much executive control in the composition of the Board that is supposed to sit as the Electoral College.