Two Moyne Shire candidates have received official warnings from the Local Government Inspectorate for failing to submit campaign donation declarations in the 2020 election.
A summary of donation returns on the council website shows the two errant candidates were Colin Ryan and Arthur Hoey, who were not successfully elected.
All candidates in local government elections must submit a return declaring any gifts or donations they received. If a candidate didn't receive anything, they must still submit a return declaring "no disclosable gifts".
There were 109 candidates across the state who failed to submit a declaration.
Chief Municipal Inspector Michael Stefanovic said "it is vital to our democracy that electoral candidates in council elections declare any donations, gifts or support they receive".
A spokesman for the inspectorate said all candidates were informed of the reporting requirements in the lead up to the 2020 election and received a further reminder after voting closed.
When contacted by The Standard, Mr Ryan - a former police detective who also served as Moyne Shire mayor from 2014 to 2016 - said he didn't realise he was supposed to submit a declaration.
"I had nothing to declare," he said.
"I've never accepted any sort of gift or donation in my 12 years as a councillor, so that's the end of it."
Mr Ryan said the inspectorate was trying to "big note" itself.
Like Mr Ryan, Mr Hoey said he found the requirement confusing.
"I didn't receive any donations, so I didn't fill out the form," he said.
"I suppose we should've done it, but I didn't think it was necessary."
Mr Hoey said he had received a reminder letter from the inspectorate after the election, but not long after that he had required emergency heart surgery and forgot about it.
"At that point I couldn't care less about filling out some form," he said.
He agreed with Mr Ryan that it was administrative overkill.
"Really it's just some bureaucrat trying to flex their muscles and give themselves something to do," he said.
The inspectorate said it had "opted not to pursue prosecution", but was issuing an official warning that would be taken into account if any of the offending candidates breached the electoral provisions in future.
"The disclosure of campaign donations by all candidates is fundamental to the electoral process - and maintains the integrity of future decision making and governance by Victorian councils," Mr Stefanovic said.
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