OSCE/ODIHR Opinion on the Draft Amendments to the Act on Establishment of the Slovak National Centre for Human Rights separate line within the national budget, and this should be specifically stated in the Draft Amendments.65 46. Additional safeguards against unwarranted cutbacks of the SNCHR’s budget which could unduly interfere with the institution’s independence are recommended to be considered. According to long-standing recommendations of the OSCE/ODIHR, the Draft Amendments could, for example, include the principle that compared to the previous year, any reductions in the SNCHR’s fund allocation need to be objectively justified and should not exceed the percentage of reduction of the budgets of the Parliament or the Government. 66 A general provision highlighting that the budgetary process should not be used to allocate/reduce funds from the budget in a manner that interferes with the NHRI’s independence is also recommended.67 47. Additionally, the NHRI has responsibility to ensure it complies with proper accountability practices to show coordinated, accountable and transparent management of its funds “through regular public financial reporting and a regular annual independent audit”. However, accountability requirements should “not compromise the capacity of the NHRI to function independently and effectively”. 68 The Explanatory Report indicates that this is to regulate the financial management of the SNCHR from public sources and donors. § 2 (4) is also potentially of concern in this regard, referencing as it does a ‘special regulation’ for the control of managing financial resources by the Centre. The Explanatory Report indicates that this relates to regular governmental audit in line with public bodies in Slovakia. While NHRIs can and should be subject to ordinary financial controls – such as audit - in the same way as state bodies, NHRIs must be in control of their operational budget. They should not be subject to interference from a government ministry in their financial affairs. Ministers or other government officials should also not have discretion (on paper or in practice) over the allocation of funds,69 or their usage.70 Auditing should performed by a body of auditors independent of the government.71 65 See e.g. OSCE/ODIHR Opinion on the Draft Act on the Independent National Human Rights Institution of Iceland (6 February 2017), Key Recommendation I and par 74, available at http://www.legislationline.org/documents/id/20241; OSCE/ODIHR Opinion on the Draft Law Amending and Supplementing the Ombudsman Act of Bulgaria, Key Recommendation F and pars 31 and 3, available at http://www.legislationline.org/documents/id/20552; OSCE/ODIHR Opinion on the Draft Federal Law on the Support to the National Human Rights Institution of Switzerland (31 October 2017), Key Recommendations A and G and pars 30-34, available at http://www.legislationline.org/documents/id/21411. 66 Ibid par 88 (OSCE/ODIHR Opinion on the Draft Federal Law on the Support to the National Human Rights Institution of Switzerland); par 76 (OSCE/ODIHR Opinion on the Draft Act on the Independent National Human Rights Institution of Iceland); see also Venice Commission Opinion on the draft Constitutional Law on the Human Rights Defender of Armenia, adopted by the Venice Commission at its 109th Session (Venice, 9-10 December 2016), CDL-AD(2016)033, par 28, available at http://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2016)033-e; 67 See e.g. ibid (OSCE/ODIHR Opinion NHRI Switzerland) par 88 and (OSCE/ODIHR NHRI Iceland) par 76; see also Venice Commission, Opinion on the Law on the People's Advocate (Ombudsman) of the Republic of Moldova, adopted by the Venice Commission at its 103rd Plenary Meeting (Venice, 19-20 June 2015), CDLAD(2015)017, pars 74-75, available at http://www.venice.coe.int/webforms/documents/?pdf=CDLAD(2015)017-e. 68 SCA Report, Mali, March 2012 p. 13; SCA Report, Cote d’Ivoire, May 2016 p. 13. 69 SCA Report, Ireland, November 2015 p. 10, quotation marks in original 70 SCA Report, Cyprus, November 2015 pp. 8-9. 71 Op. cit. fn 9, General Observation 1.10. 16