Federal Guidelines, Testing, and Certification for Electronic Poll Books (E-Poll Books)

INSIGHTi

Federal Guidelines, Testing, and Certification
for Electronic Poll Books (E-Poll Books)
Updated December 15, 2023
The U.S. Election Assistance Commission (EAC) oversees a program to test and certify voting systems to
a set of voluntary federal guidelines known as the Voluntary Voting System Guidelines (VVSG). No
similar federal guidelines, testing, or certification have been available for other systems used to
administer elections, such as electronic poll books (e-poll books) used to check voters in at the polls.
That is changing, however, with the EAC’s development of an Election Supporting Technology
Evaluation Program (ESTEP). ESTEP was established in 2022 to explore federal testing of election
systems that are not covered by the EAC’s voting system testing and certification program. The agency’s
commissioners voted to adopt it as a permanent EAC program at a public meeting on December 4, 2023.
ESTEP’s first major project, which concluded shortly before the December 4 vote, was a program to pilot
testing and certification of e-poll books. A revised version of the guidelines used in the e-poll book pilot
was available for public comment from November 14 through December 14, 2023. The final version of
the guidelines will form the basis for a formal e-poll book testing and certification program at the EAC.
What Are E-Poll Books?
Election workers use lists of registered voters to verify voter eligibility at the polls and track who has cast
a ballot. Those lists were traditionally kept on paper, but states and territories have increasingly replaced
paper poll books with electronic equipment, such as tablets and laptops, that can be used to access digital
voter registration records. According to the EAC, the number of states and territories that use e-poll books
in some or all jurisdictions has increased from 23 the first year it tracked the data, in 2008, to 40 in 2022.
Part of the appeal of e-poll books over their paper counterparts is that they can help election workers
perform the same tasks more accurately and efficiently. For example, e-poll books can be used to scan
voters’ IDs and autogenerate voter turnout reports, speeding up voter check-in and tracking processes and
reducing the potential for human error.
Another part of the appeal is that e-poll books can be used for other tasks, beyond those available with
paper poll books. Local officials have reported using e-poll books to track ballot inventory and
provisional voting rates, for example, to help prevent ballot shortages and identify workers who might
need additional training on proper procedures. Some states link e-poll books to networks, facilitating real-
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time updates to voter information that can be used to run multiprecinct vote centers and safeguard against
double voting. E-poll books can also be used to share election-related updates with poll workers, such as
court-ordered extensions to voting hours, and redirect voters who have arrived at the wrong polling place.
Why Have Federal Guidelines, Testing, and Certification Been Proposed
for E-Poll Books?
E-poll books, like other electronic equipment, can malfunction and be difficult to use, either in general or
for members of certain groups such as individuals with disabilities. They can be targets for intentional
interference and, if connected to a network, susceptible to a wider range of attacks than air-gapped
systems.
Problems with e-poll books—whether intentional or unintentional—can have significant consequences.
For example, e-poll book glitches like crashing and failing to sync have reportedly caused slowdowns at
the polls in multiple states in recent years, forcing many voters to wait hours to vote or leave without
casting a ballot. Loss or modification of voter data could also disenfranchise eligible voters, by making it
appear as if they have already cast a ballot or are not eligible to vote, and diminish voters’ confidence in
the legitimacy of the election.
Some states have their own guidelines, testing, or certification for e-poll books. The potential for
problems with e-poll books—combined with variations in states’ capacities to address those problems
themselves and possible cost or efficiency advantages of setting a national baseline—have prompted
some to also propose federal involvement. For example, bills have been introduced to direct the EAC to
develop guidelines for e-poll books (e.g., American Confidence in Elections Act, H.R. 4563, 118th
Congress) and provide for e-poll book testing and certification (e.g., Freedom to Vote Act, H.R. 11/S. 1/S.
2344, 118th Congress).
How Has the EAC Developed Its E-Poll Book Testing and Certification
Program?
The EAC started development of its e-poll book testing and certification program with a pilot program. It
worked with the cybersecurity firm Mandiant to draft security guidelines for the e-poll book pilot and the
National Institute of Standards and Technology (NIST) on guidelines for e-poll book usability and
accessibility. The draft guidelines were reviewed by—and revised in response to feedback from—NIST;
the VVSG Subcommittee of an EAC advisory body composed of state and local election officials; and the
two private laboratories that are accredited by the EAC to test voting systems to the VVSG.
Five commercial e-poll book manufacturers participated in the pilot program, along with a local elections
department and state elections board that use e-poll books they developed in-house. Each of the seven
participants—Election Systems & Software, KNOWiNK, Robis Elections Inc., Tenex Software Solutions,
VOTEC Corporation, Maricopa County Elections, and the North Carolina State Board of Elections—
submitted an e-poll book to be tested to the EAC’s guidelines by the EAC-accredited labs.
Drawing on the test results and feedback from the pilot program participants and testing labs, ESTEP
recommended some changes to the pilot materials, including revising the existing guidelines, adding new
guidelines for basic e-poll book functionality, and developing a manual that outlines administrative
processes and requirements for participating in ESTEP programs. It also recommended expanding the
pilot into a formal testing and certification program and launching a second pilot program for another
nonvoting election system.
The director of ESTEP provided an update on those recommendations at the EAC’s December 4 meeting,
including announcing

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• a second pilot program for testing the blank ballot delivery systems used to deliver ballots
to certain voters, such as some voters with disabilities and military and overseas voters;
• revisions to the e-poll book guidelines, including addition of guidelines for basic
functionality; and
• development of an ESTEP program manual.
The revised guidelines and ESTEP program manual were released for public comment on November 14.
Following the close of the public comment period on December 14, they were scheduled to go to the
EAC’s commissioners for further review.

Author Information

Karen L. Shanton

Analyst in American National Government




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