- 21 - CDL-AD(2020)025 the possibility for voters and candidates to complain against the conduct of election day. In a number of electoral laws, record books allow observers and/or candidate/party proxies to write observations, objections they may have on an aspect of the election day. This does not allow them subsequently to challenge irregularities they may have detected in most of the countries analysed but provides elements for challenges by other electoral stakeholders. 72. Election results – In 49 countries, candidates and voters can complain on the validity of election results.105 In 20 countries, voters cannot complain on the validity of election results.106 73. Election results are the most crucial, visible and sensitive element of any electoral process, since they determine who is elected. They thus lead to satisfaction or on the contrary dissatisfaction of electoral stakeholders. This is why electoral disputes are often limited to complaints and appeals on election results. This is not necessarily restrictive despite it focuses all complaints related to any step of an electoral process on its election results. The importance of the issue implies to have a broad approach of the potential categories of electoral stakeholders able to challenge election results. However, opening too broadly the possibility for challenging election results may lead to abusive complaints with the only aim to block the system and prevent the relevant authority to announce the election results on time. In countries where the public trust in public authorities and in electoral processes is still fragile, a delayed announcement of election results may even lead to the contrary effect by raising suspicion against the electoral process and the electoral authority. For sure, candidates and voters are the primary categories of citizens directly impacted by potential frauds or irregularities that can drastically change the results. According to the data analysed, a small number of countries allow candidates to challenge election results, which seems surprising and may be explained by the absence of explicit provision in the law rather than by a ban for candidates to challenge the results. More countries – albeit a minority of those analysed – allow for voters to challenge election results. This is surprising as voters, and citizens as a whole, directly suffer from potential irregular election results. In this respect, the Code of good practice in electoral matters underlines that “[a]ll candidates and all voters registered in the constituency concerned must be entitled to appeal” and that “[a] reasonable quorum may be imposed for appeals by voters on the results of elections.”107 74. In summary, most of the countries provide the right to lodge electoral complaints to the main stakeholders, namely the voters and the candidates, and a small number of countries provide such a possibility for other categories of persons. Developing in the law the categories of persons entitled to lodge complaints could be a way to reinforce procedures with regard to the settlement of electoral disputes and increase trust in electoral processes overall. This broader approach should be considered, although such additional categories of electoral stakeholders are not indicated as entitled categories to lodge complaints by international standards and specifically the Code of good practice in electoral matters, and provided that safeguards are in place to prevent frivolous complaints aimed at blocking the relevant bodies from accomplishing their duties and ultimately issuing election results in a timely manner. 105 Andorra, Azerbaijan, Bosnia and Herzegovina, Chile, Canada, Costa Rica, Czech Republic, Denmark, Estonia, Finland, France, Germany, Hungary, Iceland, Ireland, Italy Republic of Korea, Kosovo, Lithuania, Luxembourg, Malta, Mexico, Republic of Moldova, Monaco, Montenegro, Morocco, the Netherlands, Norway, Poland, Portugal, Russian Federation, San Marino, Slovenia, Sweden, Switzerland, Ukraine (unlike other potential claimants, a voter has to prove that his or her rights or interests have been violated by an infringement during a voting, counting or tabulation operation), United Kingdom, United States of America. 106 Albania, Algeria, Armenia, Austria, Belgium, Brazil, Bulgaria, Croatia, Czech Republic, Georgia, Kyrgyzstan (and observers), Latvia, Liechtenstein, North Macedonia, Peru, Romania, Russian Federation, Serbia, Spain, Tunisia. 107 Guideline II 3.3. f.