The bill would require signage to warn drivers of impending mobile speed cameras, but the Police and Border Guard Board (PPA) says drivers could argue that these were not visible, or the signs could even be blown over in high winds.

The absence of a warning sign would, under the bill, invalidate mobile speed camera readings, including those where a driver was speeding.

An anonymous response submitted by PPA criticized the bill, saying if it were implemented in its current form, the use of mobile and automated monitoring devices would effectively be illegal.

"The bill as submitted, accompanied by an extremely brief explanatory memorandum, is based on superficial emotion rather than expert and thoroughly considered argumentation that takes into account the complexity of the issue (including legally)," the PPA stated.

"It remains completely unclear what the bill's authors mean by the declarative claims in the memorandum that the amendment would increase legal clarity and the reliability of procedures," the PPA later added.

The bill itself said that not having signage or forewarning of mobile PPA speed cameras "has led to situations where speed measurements are carried out secretly, which undermines the sense of justice and reduces trust in law enforcement."

However, the PPA noted: "Since a movable sign is not and cannot be fixed in a location-specific manner, it is not at all possible for an officer operating the monitoring device to ensure at all times — or even verify — that the sign is indeed still in place, given the distance required for the sign to have its intended effect."

This would mean the authority having to check whether a driver contesting a measurement actually noticed the traffic sign or not.

The PPA further found that the draft may be unconstitutional, as it unjustifiably limits the police's ability to detect and prevent violations.

Traffic signs can be affected by weather conditions, too, the PPA added. "We have experienced cases where a sign is removed, knocked over, blown away by the wind, etc. If in these cases the driver did not see the warning sign, the warning fine becomes invalid," the statement noted.

The bill calls for movable monitoring devices including speed cameras to be marked with a traffic sign. These should be placed 150–300 meters ahead of the stretch of road where the readings will be taken in built-up areas, rising to 300–500 meters ahead of that point in areas outside settlements.

If no such traffic sign is present at the measurement location, the speed measurement would be invalid.

The initiators of the bill, MPs Madis Timpson and Valdo Randpere (both of the Reform Party) and Marek Reinaas (Eesti 200), argued current law lacks a uniform and binding obligation to inform drivers about the use of automated traffic monitoring systems.

The draft bill's explanatory memorandum states its purpose is to ensure transparency, a preventive character, and legality in traffic monitoring.

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