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INSIGHTi
Voluntary Voting System Guidelines (VVSG):
An Overview
February 5, 2021
States and localities make most decisions about the voting systems used in U.S. elections, from what
equipment to acquire to how to pay for it. Since 1990, however, the federal government has issued
voluntary guidance states and localities may use to inform their choices. This Insight examines the current
iteration of that guidance, the Voluntary Voting System Guidelines (VVSG).
Origins of the VVSG
Issues with voting systems contributed to delays in the resolution of the 2000 presidential election.
Congress responded, in part, by including benchmarks for voting systems in the Help America Vote Act of
2002 (HAVA; 52 U.S.C. §§20901-21145).
Title III of HAVA defined and set some mandatory standards for the voting systems states use in federal
elections. The act also provided for development of more detailed voluntary federal guidelines—the
VVSG—and creation of a federal program to test and certify voting systems to the guidelines.
Responsibility for these tasks was assigned primarily to the U.S. Election Assistance Commission (EAC),
with roles for the general public, the National Institute of Standards and Technology (NIST), and three
EAC advisory bodies (see Table 1). The EAC largely inherited these responsibilities from the Federal
Election Commission (FEC), which issued voluntary federal voting system guidelines in 1990 and 2002,
and the National Association of State Election Directors, which oversaw a program to test and qualify
systems to the FEC guidelines.
As with the FEC guidance—and in contrast to the mandatory standards in Title III—states are not
required to use voting systems that meet the VVSG. Voting systems must comply with the guidelines to
receive federal certification, however, and states may choose to make some or al of the federal
guidelines, testing, or certification mandatory under their own state laws.
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Table 1. Voluntary Voting System Guidelines (VVSG): Roles and Responsibilities
Roles in Developing or Adopting
Roles in Testing or Certifying
the VVSG
Voting Systems to the VVSG
U.S. Election Assistance Commission
Provide for publication of final VVSG
Provide for testing, certification,
(EAC) Commissioners
and notice of proposed VVSG in Federal
decertification, and recertification of
Register
voting systems
Provide for public comment and hearing
Vote on accreditation and revocation of
on proposed VVSG
accreditation of voting system test
Vote on adoption of VVSG
laboratories (VSTLs)
EAC Technical Guidelines
Assist EAC executive director with
—
Development Committee (TGDC)
developing VVSG
Provide for publication of VVSG
recommendations in Federal Register
EAC Board of Advisors
Review proposed VVSG and submit
Provide consultation on VSTL
comments and recommendations
performance
EAC Standards Board
National Institute of Standards and
Chair TGDC and provide technical
Recommend VSTLs for accreditation
Technology (NIST)
support upon request
Monitor VSTL performance and make
recommendations about continuing
accreditation
Source: CRS, based on review of the U.S. Code.
Notes: Roles are as specified in statute. For more on the EAC’s implementation of the federal voting system testing and
certification program, see here. For more on the composition and duties of the EAC’s three advisory bodies, see here.
Changes for the VVSG 2.0
The EAC issued the first version of the VVSG (VVSG 1.0) in 2005 and a modification (VVSG 1.1) in
2015. Work on another update (VVSG 2.0) official y started in 2015, and a vote on adoption of the update
was scheduled for February 10, 2021.
The VVSG 2.0 has a different structure than previous versions of the VVSG. It includes high-level
principles and guidelines in addition to more detailed technical requirements for use primarily by voting
system manufacturers and testing information for use primarily by voting system test laboratories.
Its content also differs. The VVSG 1.1 was a relatively limited modification of the VVSG 1.0. The VVSG
2.0, by contrast, represents a more thoroughgoing revision. The final draft lists a number of major
changes from the VVSG 1.1 to the VVSG 2.0, with emphasis on updates related to usability, accessibility,
security, and interoperability.
Selected Issues
According to the FEC, the federal government first started issuing voting system guidelines in response to
requests for assistance from the states. The guidelines were intended to help states and localities, which
might have limited resources and technical expertise, make informed decisions about increasingly
complex voting technology.
State and local election officials have reported some obstacles to achieving that objective, however,
including the following:
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Delays in updating the VVSG. Due partly to the lack of a policymaking quorum of EAC
commissioners for much of the past decade, the VVSG was only updated once between
its initial adoption in 2005 and 2021.
Lack of coverage of “nonvoting” election systems. The scope of the VVSG is based on
the definition of “voting system” in Title III of HAVA, so election systems that do not
meet that definition, such as voter registration databases, are not covered by the VVSG or
the federal testing and certification program.
The change in the structure of the VVSG 2.0 was intended to address the first of these reported issues;
authority to adopt and modify the principles and guidelines was to be reserved to the EAC’s
commissioners while other documents could be updated by agency staff according to commissioner-
approved policies. Following an internal legal opinion questioning that approach, the EAC has considered
the possibility of alternatives, such as annual review of the VVSG.
The EAC has also partnered with the Center for Internet Security on a pilot program for security testing of
election systems that are not covered by the VVSG. Other proposed approaches to covering nonvoting
election systems—offered in legislation in the 117th and previous Congresses—include establishing new
guidelines for such systems and expanding the HAVA definition of voting systems.
Whether or how to pursue such proposals is likely to continue to be a subject of debate as the EAC
commissioners vote on adoption of the VVSG 2.0 and work official y begins on the next update to the
guidelines.
Author Information
Karen L. Shanton
Analyst in American National Government
Disclaimer
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