An assessment of the issue was requested by Center Party member and MP Anastassia Kovalenko-Kõlvart. Center Party chair and former Tallinn mayor Mihhail Kõlvart has also previously criticized the reduction in the number of polling places in the Estonian capital, arguing that the decision will make it more difficult for voters who wish to cast a paper ballot to exercise their right to vote.

In her response, Madise pointed out that over the past decade, the number of polling places has been reduced in most municipalities and cities.

"The main reason for reducing the network of polling places is the increase in the number of people voting outside their place of residence during the early voting period," she explained. "Maintaining each polling place in proper working order is a burden on the local government's budget."

The justice chancellor noted that according to the Local Government Council Election Act, at least one polling place must be opened in every city — and in Tallinn, in each city district — and municipality.

"Voters can choose between different voting times and methods," she continued. "In case of health concerns or other serious obstacles, it is also possible to request a ballot box be brought to your home. Opportunities for advance voting outside one's residence-based precinct have expanded significantly. The population register's data controller is required to send eligible voters information notices containing information about voting options in the municipality or city and other essential voter-related information."

According to Madise, this means that the importance of the number and location of polling places has diminished, as voters can choose the voting method and time that suits them best, including casting a paper ballot at a polling place near work, school, store or some other location nearby.

She pointed out that the Tallinn city government, in the letter of explanation accompanying its Regulation No. 11, and the Tallinn city secretary, in their response to the justice chancellor's inquiry, both referenced statistics and explained that the previous reduction in polling places had not led to a decrease in voter turnout, either in Tallinn or in other municipalities.

The Tallinn city government clarified the guidelines used to decide what polling places will be opened for the 2025 city council elections this fall.

"Some polling places will not be opened this time because few voters used them in the last elections," Madise said, relaying the justifications provided by the city. "Some polling places were located in very close proximity to one another, and it is reasonable to merge them. Some polling stations did not meet accessibility requirements, i.e. it was not possible to enter them with a wheelchair, walker or stoller. Tallinn has extensive free public transport with many stops."

She added that according to the Tallinn city government, in the 2025 elections, a polling place will be within walking distance of every voter's registered place of residence.

"In the opinion of the chancellor of justice, the reduction in the number of polling places is not unjustified and is not in violation of the principle that there must be enough voting options and methods that voters can participate in elections with reasonable effort," Madise wrote.

"The Tallinn city government's response to the chancellor of justice shows that the polling places to be opened under Regulation No. 11 meet accessibility requirements: they are located near public transport stops, it is possible to park a personal vehicle nearby, and the polling station can be independently entered using a wheelchair, stroller or mobility aids," she continued. "If a polling station is located on the second floor of a building, it is accessible by elevator or escalator upon request."

Madise further wrote that based on the above, it can be generalized that although some voters may need to make additional efforts to find a new polling place to replace one that will not be reopening, the Tallinn city government's Regulation No. 11 is still not unconstitutional or in violation of the law.

On April 8, the Tallinn city government confirmed the locations of the city's polling places for the 2025 local elections this October, where voters will have 44 polling places at which to cast their ballots in person — 33 fewer than during the European Parliament elections last summer and about half as many as during the previous local elections in 2021.

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