corruption by providing greater transparency and accountability on the part of parties, candidates and “other persons engaged in election activities”.51 [51] This second concern was not limited to those who spend substantial sums on advertising. There is no floor on expenditure below which a person who instigates or initiates an election advertisement is not a promoter. Put another way, a person can be a promoter without spending any money at all on advertising expenses. There is no room for an assumption that election advertisements always involve expenditure as defined in s 3E. In the 2010 amendments the legislature took care to extend the legislation to electronic media, excluding only the dissemination of personal political views, and it must be taken to have appreciated that, as the video illustrates, a brochure or other publication can be put together and disseminated electronically to a mass audience without incurring any direct costs of preparation, design and publication. For this reason we do not think that the term election advertisement can be restricted to paid advertisements. [52] Third, if interpreted liberally the definitions of promoter — anyone who initiates an election advertisement to be published — and publish — bring to the notice of a person in any manner — together mean that the disclosure and accounting obligations of a promoter may attach to a great deal of political discourse among citizens via electronic and other media. It may be that, as the Commission contends, the obligations of a promoter are not especially onerous, but that is true only for those in the promotion business. We share Clifford J’s opinion that for anyone else these obligations may well have a chilling effect that cannot be justified by the legislative objectives.52 Effect [53] The legislation seeks to limit over-inclusiveness in a number of complementary ways. The first is effect. We have mentioned that an election advertisement must be reasonably regarded as encouraging voters to vote, or not to vote, for a type of candidate or party by reference to views or positions adopted or not adopted. We observe that: 51 52 Electoral Finance Act, s 3. High Court judgment, above n 1, at [167].