Gaps in the regulations Some issues that have been raised by ZESN have been entirely ignored in these promulgations. These issues (set out below) should be considered: o The Electoral Regulations should provide for ZEC to collect and analyse baseline data that informs how many voters the Commission will be targeting for the voter registration processes. This information should be availed to electoral stakeholders as it is critical. o The Regulations should specify the steps for the voter registration exercise including key processes such as the Biometric Voter Registration (BVR) equipment tendering and procurement. Procurement is one of the most critical steps in BVR deployment therefore the Regulations should ensure that adequate time is allocated for it and that the process is open to a public tender process and public scrutiny of the decision-making process and engagement of the service provider. o The Regulations should provide for the need for ZEC to conduct comprehensive stakeholder consultations with political parties, the media and CSOs on pertinent information on the BVR system such as feasibility and administrative procedures to enhance accountability, confidence and trust. o The Regulations should ensure that readable, analyzable and up to date election information is availed at the finest possible level of detail such as copies of voters’ rolls at the polling station level. The provision of analyzable electoral information at the granular level is essential for promoting transparency and accountability. o The Regulations should include provisions that allow for the inclusion of young voters who will turn 18 in 2018 o The Regulations should provide for the training of registration staff on all processes, procedures and laws pertaining to the compilation of the voters’ rolls before and during the voter registration process. o Provisions should be made in the Regulations with regards to the establishment of voter registration centres specifying the general locations where registration centres shall be established and not established e.g. army barracks or chiefs’ homesteads. Citing of registration centers should be in consultation with electoral stakeholders such as electoral contestants. o The procedures for voter registration inside the voter registration centres must be clearly spelt out in the Regulations. For instance the BVR kits and other equipment that will be used during registration should be clearly identified. 8|Page