June 30, 2026

Mr. Duncan Stowe
Chairman, Electoral Commission

Ms. Anthea Joseph
Chief Elections Officer

Dear Mr. Stowe and Ms. Joseph,

It is long overdue that the Electoral Commission and the Chief Elections Officer address, in a full public meeting and press conference, the serious legal and administrative questions that continue to arise in relation to the implementation of Dominica’s 2025 electoral legislation. 

These questions concern the Commission’s statutory duties, the Chief Elections Officer’s administrative responsibilities, and the public’s legitimate expectation that the electoral framework enacted in 2025 will be implemented lawfully, transparently and independently.

The Registration of Electors Act, 2025 establishes, among other things, a system of continuous registration, a confirmation process for existing electors, powers to investigate residency, duties concerning voter identification cards, and rules governing the composition and closure of the register. The House of Assembly Elections Act, 2025 likewise establishes legal duties concerning the official list of electors, the conduct of polling, access to state-owned media, election offences, and the accreditation of observers.

Against that statutory background, the following 20 questions require direct public answers. 

Regarding voter registration, local elections and voter identification cards

1. Does the Commission accept that section 17 of the Registration of Electors Act, 2025 establishes a regime of continuous registration, and if so, on what legal and operational basis was voter registration suspended from 19 March 2025 to 9 March 2026, and why was the public not advised in advance that the Commission was not ready to implement the Act? 
2. In light of section 3 of the Registration of Electors Act, 2025, which applies that Act to elections for City, Town, Urban, Village and Kalinago Territory Councils, does the Commission accept that the interruption of continuous registration was capable of affecting local government elections held during that period, and what legal assessment has the Commission made of that consequence? 
3. Does the Commission accept that section 11 of the Registration of Electors Act, 2025 requires the Chief Registering Officer to cause voter identification cards to be issued to persons who have been duly registered, and that oath-based mechanisms at the poll are intended only as limited exceptions and not as substitutes for the ordinary statutory system of issuing voter identification cards; if so, what is the legal explanation for the continuing non-issuance of cards to approved voters? 
4. At the time the 2025 electoral legislation came into force, was the Commission in a position to implement the registration, confirmation and identification-card requirements created by the Registration of Electors Act, 2025 and the House of Assembly Elections Act, 2025, and if not, why did the Commission not publicly advise Parliament and the people of Dominica of its lack of operational readiness?

Regarding political interference and institutional independence

5. Did the Commission itself request that the Prime Minister seek assistance for the Commission from the Commonwealth Secretariat, the OAS, the OECS and CARICOM, and if so, by what formal resolution, correspondence or decision was that request authorised?
6. Does the Commission accept that, under section 50 of the Registration of Electors Act, 2025, the authority to determine and extend the confirmation period is vested in the Commission subject to the statutory limits established by Parliament, and if so, what objective criteria will it apply in deciding whether the confirmation period should be extended, including the number of persons confirmed, the administrative readiness of the system, and the need to secure an accurate, lawful and inclusive register?
7. In relation to changes permitting the birth certificate to be used as an alternative form of identification in certain cases, did those changes originate from the Commission’s own initiative and formal decision, or were they prompted by the Prime Minister, and how were they documented? 

Regarding future elections and longstanding concerns

8. Does the Commission accept that offences such as bribery, treating and undue influence under the House of Assembly Elections Act, 2025 directly affect the fairness and legality of elections, and what proactive measures within its remit will the Commission adopt to detect, deter and report such conduct before the next election? 
9. Does the Commission accept that the House of Assembly Elections Act, 2025 imposes obligations concerning access to state-owned media services during the electoral period, and what measures will the Commission take to ensure that such access is equal, fair and effective in practice? 
10. Does the Commission accept that residence in the relevant polling district is a continuing legal requirement for remaining lawfully on the register, and what concrete procedures has it put in place, through the Chief Registering Officer, registering officers, assistant registering officers and other authorised officers, to investigate whether persons on the register, including persons who reside predominantly overseas, remain ordinarily resident in Dominica and in the polling district for which they are registered? 
11. How does the Commission intend to use its statutory powers of investigation and deletion to ensure that persons who are not lawfully entitled to remain on the register are identified and removed only through lawful procedures, notice and an opportunity to respond, and can it assure the public that, going forward, only persons who satisfy the legal requirements for registration, including the residency requirement, will remain on the register and be permitted to vote, save for the limited statutory exceptions expressly recognised by law? 

Regarding the Roseau North by-election

12. If a writ for the Roseau North by-election is issued during the confirmation period, does the Commission accept that the Registration of Electors Act, 2025 prescribes the register to be used for that election, namely the register published under section 13(3), together with the monthly confirmation lists and the supplementary lists last published under section 17(2)? 
13. In practical terms, what exact register or combination of lists does the Commission intend to treat as the official list for the Roseau North by-election, how will that list be compiled, certified and made available to candidates, political parties and the public in a transparent and intelligible manner, and up to what date will approved new registrations be included in that by-election?
14. Since the Registration of Electors Act, 2025 provides that the register is closed to amendments immediately upon the issuance of a writ, what steps will the Commission take to ensure that the public clearly understands the legal cut-off date for additions, deletions, claims, objections and appeals affecting the Roseau North by-election?
15. Given that the presentation of a voter identification card is central to the polling process under the House of Assembly Elections Act, 2025, how does the Commission propose to manage the legal and operational risk that widespread non-issuance of cards could convert an exceptional oath-based mechanism into the norm at the Roseau North by-election?
16. What special measures will the Commission adopt to ensure that the Roseau North by-election, as the first practical test of the new electoral regime, is conducted in strict compliance with the statutory rules relating to the official list, voter identification, oaths, residency verification, bribery, treating and media fairness, and will the Commission accredit independent domestic observers and, where appropriate, reputable international observer missions so that the conduct of the election may be independently observed and publicly assessed?
17. How will the Commission ensure that any technical assistance from external bodies is requested, framed and used in a manner that visibly preserves the Commission’s independence, rather than appearing as an extension of executive influence?

Regarding progress on confirmation and registration

18. Does the Commission accept or reject the estimate that Dominica’s resident voting-age population is approximately 55,000, and if it rejects that estimate, will it publish its own estimate together with the methodology used so that the public may assess whether the emerging register is broadly consistent with the population lawfully eligible to vote?
19. Having regard to section 50 of the Registration of Electors Act, 2025 and to the public figures stated as at 26 June 2026, does the Commission consider it realistically possible to complete confirmation and registration to a level sufficient to inspire public confidence by 14 October 2026, or by any lawful extension thereafter?

And finally…..

20. When, and in what format, does the Commission intend to give the country a full public account of these matters — the suspension of voter registration, local government elections during that suspension, the non-issuance of voter identification cards, the Roseau North by-election arrangements, the enforcement of residency rules, and the role of external assistance — so that citizens may assess whether the Commission is discharging its constitutional and statutory responsibilities with transparency, competence and independence?

These questions go to the heart of whether the Commission is fulfilling its constitutional and statutory role with the independence, competence and transparency that the Dominican people are entitled to expect.

The public remains deeply concerned about the integrity of the voters’ list, the enforcement of the residency requirement, the non-issuance of voter identification cards, the fairness of electoral competition, and the ability of the Commission to administer upcoming elections in a manner that is both lawful and credible.

Those concerns are not abstract. In its judgment of 5 July 2022 arising from litigation over Dominica’s 2019 general elections, the Caribbean Court of Justice, Dominica’s apex court, stated that there remain “areas of grave concerns about how the process of these elections was conducted” and emphasised that future elections in Dominica “ought not to proceed with these or similar taints.”

That warning should have prompted a culture of urgency, legal discipline and public accountability. Instead, the country has experienced prolonged uncertainty on registration, confirmation, identification cards, and the practical implementation of the very reforms that were said to be necessary to restore confidence in the system. 

The people of Dominica are entitled to clear answers. They are entitled to know whether the Commission understands the scope of its legal duties, whether it intends to exercise its powers independently, and whether it will ensure that the next election is conducted on the basis of a lawful register, fair procedures and public confidence.

A prompt and substantive public response to these questions would therefore be in the interests not only of transparency, but of the legitimacy of the electoral process itself. 

Respectfully,

Gregor Nassief