Federal Standards and Guidelines for Voting Systems: Overview and Potential Considerations for Congress

Federal Standards and Guidelines for Voting Systems: Overview and Potential Considerations for Congress

Federal Standards and Guidelines for Voting
June 12, 2023
Systems: Overview and Potential
Karen L. Shanton
Considerations for Congress
Analyst in American
National Government
States and localities choose the voting systems used in elections in the United States. They decide

which systems to use and contract with vendors as necessary to acquire and maintain them.

The federal government plays a role, though, in shaping the systems available for states and
localities to choose from. First, federal law sets some mandatory standards for voting systems, including standards for their
functionality and their accessibility to individuals with disabilities, older individuals, and members of language minority
groups.
Second, federal law provides for a program, overseen by the U.S. Election Assistance Commission (EAC), to develop and
update voluntary federal guidelines for voting systems and test and certify systems to the guidelines. The federal voting
system testing and certification program was designed as a service to states and localities, and use of systems that conform to
the EAC’s Voluntary Voting System Guidelines (VVSG) is voluntary under federal law. However, widespread adoption of
the program by states under their own state laws means that the VVSG have significant influence in practice, shaping the
kinds of voting systems vendors develop and market.
The EAC’s Technical Guidelines Development Committee is charged by the Help America Vote Act of 2002 (HAVA) with
helping the agency’s executive director develop draft VVSG, with technical support from the National Institute of Standards
and Technology (NIST). The draft VVSG are shared with the public and the EAC’s Board of Advisors and Standards Board
for review and comment before they are submitted to the agency’s commissioners for a vote on adoption. The commissioners
have adopted three versions of the guidelines to date: VVSG 1.0 in 2005, VVSG 1.1 in 2015, and VVSG 2.0 in 2021.
Testing and certification of voting systems to the VVSG is also overseen by the EAC. The agency’s commissioners, with
assistance from NIST, accredit laboratories to test voting systems to the guidelines. Confirmation by an EAC-accredited lab
that a vendor’s voting system conforms to the VVSG is the main requirement for federal certification. However, vendors also
have to meet other requirements before their systems are certified, such as depositing voting system software in an EAC-
approved repository, and after certification, such as notifying the EAC of any malfunctions of their fielded voting systems
and participating in the agency’s Quality Monitoring Program.
HAVA established general procedures for developing the VVSG and for testing and certifying voting systems to the
guidelines, but, as is often the case with statutory language, it did not specify all the details of how the procedures should
work or what they should cover. Those specifics have been filled in by the EAC, its advisory bodies, and NIST, with input
from the public. Some Members of Congress have introduced legislation to codify, change, or supplement those choices,
offering bills on the VVSG development, testing, and certification processes or the scope of the guidelines.
Some Members have also proposed expanding the scope of mandatory federal standards for voting systems. As noted above,
the VVSG have significant influence in practice because many states have adopted some or all of the federal voting system
testing and certification program. However, there are relatively few actual federal mandates for voting systems. While some
Members favor limited involvement by the federal government in this area, others have seen a role for new federal
requirements. They have introduced bills that would limit foreign ownership or control of voting system vendors, for
example, or require voting systems to produce individual paper records that can be verified by voters and manually audited
by election officials.
Setting standards and guidelines is perhaps the most direct way Congress can influence choices about voting systems. Voting
system policymaking comes with some complexities, however, due to (1) the multiple objectives voting systems are expected
to meet, and (2) practical constraints on voting system production and implementation. Members who are interested in
engaging with voting system policy might choose to consider whether or how to account for those complexities when
designing new standards and guidelines. Alternatively, they might consider exploring other avenues for advancing voting
system priorities. For example, Members might choose to consider other legislative tools—such as funding, research, or
technical assistance—or other congressional authorities, such as oversight or appointment authorities.
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Contents
Introduction ..................................................................................................................................... 1
Scope of the Report ................................................................................................................... 1
Background ..................................................................................................................................... 3
Origins and Overview of Federal Standards and Guidelines .......................................................... 5
Mandatory Standards ................................................................................................................ 6
Voluntary Guidelines ................................................................................................................. 8
Development and Maintenance ........................................................................................... 9
Testing and Certification ................................................................................................... 15
Legislative Activity ....................................................................................................................... 18
VVSG Development, Testing, and Certification Processes .................................................... 18
Scope of the VVSG ................................................................................................................. 20
Scope of Mandatory Standards ............................................................................................... 21
Potential Considerations for Congress .......................................................................................... 22

Figures
Figure 1. Process for Developing the Voluntary Voting System Guidelines ................................. 14
Figure 2. Process for Certifying Voting Systems to the Voluntary Voting System
Guidelines................................................................................................................................... 17

Tables
Table 1. Federal Definitions of “Voting System” ............................................................................ 2
Table 2. Main Types of Voting Systems Used for In-Person Voting in Federal Elections
Since the Early 20th Century ......................................................................................................... 5
Table 3. Memberships of the U.S. Election Assistance Commission’s Statutory Advisory
Bodies ........................................................................................................................................... 9
Table 4. Federal Responsibilities for Voluntary Voting System Guidelines, Testing, and
Certification ................................................................................................................................ 15

Table A-1. Principles and Guidelines of Voluntary Voting System Guidelines 2.0 (VVSG
2.0) ............................................................................................................................................. 27

Appendixes
Appendix. Principles and Guidelines of Voluntary Voting System Guidelines 2.0 (VVSG
2.0) ............................................................................................................................................. 27

Contacts
Author Information ........................................................................................................................ 29
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Federal Standards and Guidelines for Voting Systems

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Federal Standards and Guidelines for Voting Systems

Introduction
States and localities choose the voting systems used in elections in the United States. They decide
which systems to use and contract with vendors as necessary to acquire and maintain them.
The federal government plays a role, though, in shaping the systems available for states and
localities to choose from. First, federal law sets some mandatory standards voting systems must
meet, including standards for their functionality and their accessibility to individuals with
disabilities, older individuals, and members of language minority groups.1
Second, federal law provides for a program, overseen by the U.S. Election Assistance
Commission (EAC), to develop and update voluntary federal guidelines for voting systems and
test and certify systems to the guidelines. The federal voting system testing and certification
program was designed as a service to states and localities, and use of systems that conform to the
EAC’s Voluntary Voting System Guidelines (VVSG) is voluntary under federal law.2 However,
widespread adoption of the program by states under their own state laws means that the VVSG
have significant influence in practice,3 shaping the kinds of voting systems vendors develop and
market.4
This report provides an overview of the federal standards and guidelines that shape the voting
systems used in U.S. elections. It starts by describing how those federal standards and guidelines
fit into a broader system of checks on voting systems, then summarizes the current standards and
guidelines and related legislative activity. The report closes by introducing some considerations
that may be of interest to Members who are considering whether or how to engage with federal
voting system policy.
Scope of the Report
This report focuses on federal standards and guidelines for systems that are used for in-person
voting on Election Day and covered by the definition of “voting system” in the Help America
Vote Act of 2002 (HAVA; P.L. 107-252; 52 U.S.C. §§20901-21145) or VVSG 2.0, the current

1 Prior to enactment of the Help America Vote Act of 2002 (HAVA), “standards” was used to refer to voluntary federal
guidelines for voting systems. HAVA set requirements for voting systems that it referred to as “voting systems
standards” and, perhaps to distinguish the voluntary guidelines from those mandatory standards, renamed the voluntary
guidelines “voluntary voting system guidelines.” This report follows the usage in HAVA, using “standards” for
requirements voting systems must meet and “guidelines” for voluntary guidance. 52 U.S.C. §21081; and 52 U.S.C.
§§20961-20962.
2 The federal voting system testing and certification program is intended to help set a baseline for voting systems, offer
an alternative to state-by-state testing to that baseline, and officially recognize voting systems that meet it. See, for
example, U.S. Election Assistance Commission (EAC), Reforming the Testing and Certification Process, June 12,
2014, pp. 38-40, at https://www.eac.gov/sites/default/files/event_document/files/EAC%20Roundtable%206-12-14.pdf;
EAC, Requirements for the Voluntary Voting System Guidelines 2.0, February 10, 2021, p. 9, at https://www.eac.gov/
sites/default/files/TestingCertification/Voluntary_Voting_System_Guidelines_Version_2_0.pdf; and EAC, Voting
System Testing and Certification Program Manual Version 3.0, November 15, 2022, p. 15, at
https://www.eac.gov/sites/default/files/TestingCertification/Testing%20and%20Certification%20Program%20Manual
%20Version%203.0%20(2).pdf.
3 According to a 2020 EAC report, 37 states and the District of Columbia (DC) have adopted some or all of the
program. EAC, State Requirements and the U.S. Election Assistance Commission Voting System Testing and
Certification Program, September 4, 2020, at https://www.eac.gov/sites/default/files/TestingCertification/
State_Requirements_for_Certification09042020.pdf.
4 See, for example, National Institute of Standards and Technology (NIST), “VVSG Introduction,” at
https://www.nist.gov/itl/voting/vvsg-introduction; and U.S. Congress, Senate Committee on Rules and Administration,
Oversight of the U.S. Election Assistance Commission, 116th Cong., 1st sess., May 15, 2019, p. 15.
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version of the VVSG (for details of those definitions, see Table 1). Specifically, it focuses on (1)
mandatory federal standards for features of the equipment and materials used in those systems,
including features and practices of the private-sector vendors and laboratories that produce and
test them, and (2) the VVSG and the federal voting system testing and certification program.
Table 1. Federal Definitions of “Voting System”
Help America Vote Act of 2002 (HAVA)
Voluntary Voting System Guidelines (VVSG) 2.0
(1) the total combination of mechanical,
Equipment (including hardware, firmware, and
electromechanical, or electronic equipment (including
software), materials, and documentation used to enact
the software, firmware, and documentation required to
the fol owing functions of an election:
program, control, and support the equipment) that is
1. define elections and ballot styles,
used—
2. configure voting equipment,
(A) to define ballots;
3. identify and validate voting equipment configurations,
(B) to cast and count votes;
4. perform logic and accuracy tests,
(C) to report or display election results; and
5. activate ballots for voters,
(D) to maintain and produce any audit trail
information; and
6. record votes cast by voters,
(2) the practices and associated documentation used—
7. count votes,
(A) to identify system components and versions of
8. label ballots needing special treatment,
such components;
9. generate reports,
(B) to test the system during its development and
10. export election data including election results,
maintenance;
11. archive election data, and
(C) to maintain records of system errors and
12. produce records in support of audits.
defects;
(D) to determine specific system changes to be
made to a system after the initial qualification of
the system; and
(E) to make available any materials to the voter
(such as notices, instructions, forms, or paper
ballots).
Sources: 52 U.S.C. §21081(b); and U.S. Election Assistance Commission (EAC), Requirements for the Voluntary
Voting System Guidelines 2.0, February 10, 2021, p. 10, at https://www.eac.gov/sites/default/files/
TestingCertification/Voluntary_Voting_System_Guidelines_Version_2_0.pdf.
Notes: HAVA does not extend its definition of “voting system” to the provisions of the act related to the
VVSG, and there was some discussion during development of VVSG 2.0 about expanding the scope of the
guidelines to include election systems not covered by the act’s definition of the term. According to the adopted
version of the guidelines, however, the definition of “voting system” ultimately chosen to set the scope of VVSG
2.0 was not intended to expand on HAVA’s definition. EAC, Requirements for the Voluntary Voting System Guidelines
2.0, p. 11.
With the exception of some of the discussion of proposals to expand the scope of current federal
standards and guidelines in the “Legislative Activity” and “Potential Considerations for
Congress” sections, this report does not generally aim to address (1) election administration
processes, such as chain of custody procedures and poll worker training;5 (2) voluntary federal

5 Election administration processes play an important role in the overall functioning of voting systems. For example,
different choices about how voting systems are deployed, such as how poll workers are trained and how many systems
are available at each polling place, can introduce or prevent voting system problems. As a result, election experts have
often encouraged attention to the policies and procedures associated with voting systems in addition to voting system
equipment and materials. See, for example, U.S. Congress, House Committee on Government Reform, Subcommittee
on Technology, Information Policy, Intergovernmental Relations and the Census, The Science of Voting Machine
Technology: Accuracy, Reliability and Security, 108th Cong., 2nd sess., July 20, 2004, p. 17; and U.S. Congress,
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guidance other than the VVSG, such as the best practices for securing voting systems issued by
the U.S. Department of Homeland Security’s (DHS’s) Cybersecurity and Infrastructure Agency
(CISA);6 (3) election systems other than voting systems, such as voter registration databases and
election management software; or (4) voting methods other than in-person Election Day voting,
such as early and mail voting. For more on some of those topics, see CRS In Focus IF11285,
Election Security: Voter Registration System Policy Issues, by Sarah J. Eckman; and CRS In
Focus IF11477, Early Voting and Mail Voting: Overview & Issues for Congress, by Sarah J.
Eckman and Karen L. Shanton.
Background
Policymaking about voting systems includes choices about
• how voting systems are intended to function, and
• how to check that they function as intended.
Federal voting system standards and guidelines fall into the first of those categories, and testing
and certification of systems to the guidelines falls into the second. Both types of federal
involvement primarily play a role early in the lifecycle of voting systems, helping shape the types
of systems vendors develop and market.
Other public- and private-sector stakeholders play roles throughout the voting system lifecycle
and each election cycle. First, states and localities may set their own standards for how the voting
systems they use are intended to function, in addition to the mandatory federal standards and any
voluntary federal guidelines they choose to follow.
Second, states, localities, and voting system vendors take various steps to check that their voting
systems function as intended. Depending on the system and jurisdiction, those steps might
include
• Vendor testing. Voting system vendors typically conduct internal tests of their
systems during development and before submitting them for state and federal
certification or use by states and localities.7 Vendors may also take advantage of
voluntary technical assistance offered by federal agencies, such as the open-

Committee on House Administration, Subcommittee on Elections, The Importance of Poll Workers: Best Practices and
Recommendations, 110th Cong., 1st sess., October 3, 2007.
6 See, for example, Cybersecurity and Infrastructure Security Agency (CISA), Best Practices for Securing Election
Systems, November 11, 2022, at https://www.cisa.gov/news-events/news/best-practices-securing-election-systems. This
kind of guidance plays a fundamentally different role in federal voting system policy than the VVSG. As noted in the
“Introduction” to this report, although use of systems that conform to the VVSG is voluntary under federal law,
widespread adoption of the federal testing and certification program by the states means that the VVSG have
significant influence in practice.
7 See, for example, EAC, United States Election Assistance Commission Public Meeting: Voting Systems Manufacturer
Roundtable Discussion, February 29, 2008, p. 43, at https://www.eac.gov/sites/default/files/event_document/files/
transcript%20public%20meeting%20february%2029%202008.pdf. Voting system vendors also often have coordinated
vulnerability disclosure policies, which offer a way for good-faith researchers to help them identify and address
vulnerabilities in their systems. See, for example, Information Technology-Information Sharing and Analysis Center
Elections Industry-Special Interest Group, “EI-SIG Members’ Vulnerability Disclosure Policies,” at https://www.it-
isac.org/ei-sig. The EAC’s commissioners indicated in testimony for a June 2023 hearing that the agency is working
with CISA and NIST to develop its own voluntary coordinated vulnerability disclosure policy for voting systems.
Testimony of EAC Commissioners, in U.S. Congress, Senate Committee on Rules and Administration, Hearing on
Oversight of the U.S. Election Assistance Commission, 118th Cong., 1st sess., June 7, 2023, pp. 9-10, at
https://www.rules.senate.gov/imo/media/doc/EAC_Testimony1.pdf.
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ended vulnerability assessments available under CISA’s Critical Product
Evaluation program.8
• State testing and certification. State-level testing and certification works
similarly to federal testing and certification. It typically involves checking
sample voting systems for conformance to state-specific requirements.
• Acceptance testing. Acceptance testing is conducted on the actual equipment
that will be used in elections when it is initially delivered to a jurisdiction by the
vendor or returned to the jurisdiction after leaving election officials’ control, such
as for servicing. It is intended to check that the equipment works correctly and
meets all the conditions in the jurisdiction’s contract with the vendor.9
• Logic and accuracy (L&A) testing. L&A testing is carried out before an
election, after the election, or both. It is designed to ensure that the equipment
used in the election works correctly and has been configured with the right
information for the election, such as the correct candidate names, precinct
boundaries, and ballot counting logic. It typically involves casting a known
pattern of test votes and confirming that the results reported by the voting system
match the expected outcomes.10
• Parallel testing. Parallel testing, which is conducted during an election, involves
testing randomly selected equipment in conditions that are as similar as possible
to the conditions in the polling place. It is intended to help catch problems that
might not be identified by checking the equipment in test mode or before or after
an election, such as malicious code that is programmed to run only when the
polls are open.11
• Post-election audits. Post-election audits, which typically involve checking a
sample of paper records of votes against the election outcomes reported by the
voting system, are intended to check whether the equipment accurately captured
and counted voters’ selections. Some types of post-election audits, such as risk-
limiting audits, offer a specific degree of confidence that the outcomes reported
by the voting system are the outcomes officials would get if they counted all of
the paper records by hand.12

8 See, for example, CISA, “Election Security Services,” at https://www.cisa.gov/election-security-services; and
Testimony of Matthew Masterson, in U.S. Congress, House Committee on Homeland Security, Subcommittee on
Cybersecurity, Infrastructure Protection, and Innovation, Securing Democracy: Protecting Against Threats to Election
Infrastructure and Voter Confidence, 117th Cong., 2nd sess., January 20, 2022, pp. 11-12, at https://www.congress.gov/
117/meeting/house/114343/witnesses/HHRG-117-HM08-Wstate-MastersonM-20220120.pdf.
9 EAC, Election Management Guidelines, 2023, pp. 60-67, at https://www.eac.gov/sites/default/files/electionofficials/
EMG/EAC_Election_Management_Guidelines_508.pdf.
10 EAC, Election Management Guidelines, pp. 73-75.
11 EAC, Election Management Guidelines Chapter 6: Pre-Election and Parallel Testing, at https://www.eac.gov/sites/
default/files/eac_assets/1/6/Chapter_6__Pre-Election_and_Parallel_Testing.pdf. For discussion of some possible
limitations of parallel testing and logic and accuracy testing, see Andrew W. Appel, Richard A. DeMillo, and Philip B.
Stark, “Ballot-Marking Devices Cannot Ensure the Will of the Voter,” Election Law Journal: Rules, Politics, and
Policy, vol. 19, no. 3 (September 2020).
12 EAC, Election Management Guidelines, pp. 124-126; and EAC, Election Audits Across the United States, October 6,
2021, at https://www.eac.gov/sites/default/files/bestpractices/Election_Audits_Across_the_United_States.pdf. For more
on risk-limiting audits, see CRS In Focus IF11873, Election Administration: An Introduction to Risk-Limiting Audits,
by Karen L. Shanton.
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Federal standards, guidelines, testing, and certification are, therefore, part of a broader system of
checks on voting systems.
Origins and Overview of Federal Standards and
Guidelines
Voting in the early 20th century was a relatively low-tech process. Voters marked their selections
by hand on paper ballots that were counted by hand, for example, or by pulling levers on a
machine that advanced a physical counter for each selection.13
The second half of the century, however, saw the introduction of computerized voting systems.
Computers were first used—as part of the punch card and optical scan voting systems introduced
in the 1960s—to count votes marked on paper ballots. Direct-recording electronic (DRE) voting
machines, which debuted the following decade, record voter selections directly into computer
memory.14 For more on the main types of voting systems that have been used for in-person voting
in federal elections since the early 20th century, see Table 2.
Table 2. Main Types of Voting Systems Used for In-Person Voting in Federal Elections
Since the Early 20th Century
In Use in Federal Elections
Type
Description
as of November 2022
Hand-counted paper ballots
Selections are marked by hand or using a ballot-
Yes
marking device (BMD), and counted by hand
Lever machine
Selections are marked by pul ing a lever that
No
advances a physical counter
Punch card system
Selections are marked by punching out pieces of
No
card, and counted by an electronic scanner
Optical scan system
Selections are marked by hand or using a BMD,
Yes
and counted by an electronic scanner
Direct-recording electronic
Selections are recorded directly into computer
Yes
(DRE) machine
memory using a button, dial, or touchscreen
Sources: CRS, based on review of U.S. Election Assistance Commission, Election Administration and Voting Survey
2020 Comprehensive Report, August 16, 2021, pp. 23-26, https://www.eac.gov/sites/default/files/document_library/
files/2020_EAVS_Report_Final_508c.pdf; and Verified Voting, “The Verifier—Election Day Equipment—
November 2022,” at https://verifiedvoting.org/verifier/#mode/navigate/map/ppEquip/mapType/normal/year/2022.
Concerns about reports of problems with computerized systems prompted a 1975 study of
computerized vote tallying by the National Bureau of Standards (NBS; now known as the
National Institute of Standards and Technology, or NIST). Among other recommendations, the
study proposed establishing federal guidelines to help states and localities ensure the accuracy
and security of their systems.15

13 Douglas W. Jones, “A Brief Illustrated History of Voting,” Voting and Elections web pages, University of Iowa
Department of Computer Science, at https://homepage.cs.uiowa.edu/~jones/voting/pictures/.
14 Douglas W. Jones, “A Brief Illustrated History of Voting,” Voting and Elections web pages, University of Iowa
Department of Computer Science.
15 Roy G. Saltman, Computer Science & Technology: Effective Use of Computing Technology in Vote-Tallying,
National Bureau of Standards, April 1978, at https://nvlpubs.nist.gov/nistpubs/Legacy/SP/nbsspecialpublication500-
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Congress followed up on that recommendation by first directing the Federal Election Commission
(FEC) and NBS to study voluntary guidelines for voting systems and then providing the FEC
funding to develop such guidelines.16 The FEC issued the first voluntary federal guidelines for
voting systems in 1990, with an update in 2002.17 The National Association of State Election
Directors (NASED), a professional association for state election officials, launched a program in
1994 to test and certify systems to the guidelines.18
The 1975 NBS report and 1990 FEC guidelines focused primarily on the basic functionality of
voting systems—whether they were secured against errors and interference, accurately and
reliably capturing and counting voters’ selections—and public confidence in their functionality.
The period from 1975 to 1990 also saw federal interest in access to voting systems. Federal
legislation enacted during that period aimed to ensure that voting systems were accessible to
members of language minority groups and to individuals with disabilities and older individuals.
Both functionality and accessibility also featured in the most recent major federal statute on this
topic, HAVA. A decade after the federal government had first issued voluntary guidelines for
voting systems, problems with voting systems contributed to controversy over the 2000
presidential election. Congress responded to those problems, in part, by revisiting federal
involvement in voting system standards and guidelines. Its primary legislative response to the
problems with the administration of the 2000 elections, HAVA, specified mandatory federal
standards for voting system functionality and accessibility and established new federal processes
for developing voluntary voting system guidelines and testing and certifying systems to them.19
Mandatory Standards
Some voters voted in the 2000 elections on punch card voting systems, punching out pieces of
card known as “chads” that corresponded to their selections. Accidental marks or incomplete
punches resulted in some ballots with chads that were dimpled or partially removed instead of
fully detached. Difficulty discerning voter intent from those “pregnant” and “hanging” chads

30.pdf. This report was originally published in 1975 and republished in 1978. Roy G. Saltman, Requirements for
Evaluation of Voting System Security, September 20, 2004, p. 1, at https://www.nist.gov/system/files/documents/itl/
vote/NISTpaper-040920.pdf.
16 P.L. 96-187; and Federal Election Commission (FEC), Performance and Test Standards for Punchcard, Marksense,
and Direct Recording Electronic Voting Systems, January 1990, p. xviii, at https://www.eac.gov/sites/default/files/
eac_assets/1/28/FEC_1990_Voting_System_Standards1.pdf.
17 FEC, Performance and Test Standards for Punchcard, Marksense, and Direct Recording Electronic Voting Systems;
FEC, Voting Systems Standards Volume 1 – Performance Standards, April 2002, at https://www.eac.gov/sites/default/
files/eac_assets/1/28/Voting_System_Standards_Volume_I.pdf; and FEC, Voting Systems Standards Volume II – Test
Standards, April 2002, at https://www.eac.gov/sites/default/files/eac_assets/1/28/
Voting_System_Standards_Volume_II.pdf.
18 U.S. Congress, Committee on House Administration and House Committee on Science, Voting Machines: Will the
New Standards and Guidelines Help Prevent Future Problems? 109th Cong., 2nd sess., July 19, 2006, p. 110. The FEC
and NASED referred to the latter process as “qualifying” systems to the guidelines. HAVA renamed the process
“certification,” and this report follows that usage. As noted by EAC staff in a 2005 public meeting, the two terms refer
to the same basic process and can be used interchangeably in this context. EAC, United States Election Assistance
Commission Public Meeting, August 23, 2005, p. 33, at https://www.eac.gov/sites/default/files/event_document/files/
transcript%20public%20meeting%20august%2023%202005.pdf.
19 For more on Congress’s response to problems with the 2000 elections, see CRS Report R46949, The Help America
Vote Act of 2002 (HAVA): Overview and Ongoing Role in Election Administration Policy, by Karen L. Shanton.
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contributed to disputes over the Florida vote count that delayed resolution of the 2000 presidential
election for weeks.20
The layout of the ballots in Florida’s Palm Beach County added further complications in 2000. In
an effort to make ballots more readable for older voters, the county’s clerk increased the font size
and spread the presidential candidates’ names across two pages with a column of punch holes in
the middle. Some county voters, confused by the “butterfly” layout of the ballot, marked their
ballots for a different presidential candidate than the one they intended to support.21
The problems with Florida’s punch card systems were the highest-profile problems with voting
systems in 2000, but post-election investigations also flagged others. Lever machines and DREs
without a voter verifiable paper audit trail (VVPAT) could jam or malfunction, for example, and
did not produce paper records that could be used to reconstruct votes cast on a jammed or
malfunctioning machine. Some types of voting systems registered higher rates of uncounted
ballots, overvotes (more selections for a given contest than permitted), and undervotes (fewer
selections for a given contest than permitted) than others.22
Post-2000 election investigations also highlighted problems with voting system accessibility.
Federal statutes and regulations had established some accessibility standards for voting systems
before the 2000 elections. A 1975 amendment (P.L. 94-73) to the Voting Rights Act of 1965
(VRA; P.L. 89-110) introduced requirements for certain states and localities to provide voting
materials in the languages of applicable language minority groups.23 The Voting Accessibility for
the Elderly and Handicapped Act of 1984 (VAEHA; P.L. 98-435; 52 U.S.C. §§20101-20107)
required states to make voting aids like large print instructions and telecommunications devices
available for federal elections.24 The Americans with Disabilities Act of 1990 (ADA; P.L. 101-
336; 42 U.S.C. §§12101-12213) included a broad prohibition on excluding individuals with
disabilities from public services that had various implications for voting systems.25
However, representatives of those groups reported encountering continued obstacles to voting in
2000. Some voting systems were inaccessible to individuals with disabilities, for example,

20 See, for example, Samantha Levine, “Hanging Chads: As the Florida Recount Implodes, the Supreme Court Decides
Bush v. Gore,” U.S. News & World Report, January 17, 2008, at https://www.usnews.com/news/articles/2008/01/17/
the-legacy-of-hanging-chads.
21 ABC News, “Butterfly Ballot Designer Speaks Out,” December 21, 2000, at https://abcnews.go.com/Politics/story?
id=122175&page=1.
22 See, for example, R. Michael Alvarez et al., Voting—What Is, What Could Be, Caltech/MIT Voting Technology
Project, July 2001, at https://vote.caltech.edu/reports/1; and U.S. General Accounting Office (GAO), Elections:
Statistical Analysis of Factors that Affected Uncounted Votes in the 2000 Presidential Elections, October 2001, at
https://www.gao.gov/assets/gao-02-122.pdf.
23 A 1982 amendment to the act (P.L. 97-205) also provides for voters who need help voting due to a disability or
inability to read or write to receive assistance from the person of their choice.
24 VAEHA also requires states and localities to ensure that polling places for federal elections are accessible to
individuals with disabilities and older individuals or, if there is an emergency or no accessible polling places are
available, to offer an alternative means of casting a ballot.
25 For more on some of those implications, see U.S. Department of Justice (DOJ), The Americans with Disabilities Act
and Other Federal Laws Protecting the Rights of Voters with Disabilities, September 2014, at https://archive.ada.gov/
ada_voting/ada_voting_ta.htm. The Rehabilitation Act of 1973 (P.L. 93-112; 29 U.S.C. §§701-796l) contains a similar
prohibition on excluding individuals with disabilities from programs or activities receiving federal funding. For more
on federal funding for election administration, see CRS Report R46646, Election Administration: Federal Grant
Funding for States and Localities, by Karen L. Shanton; and CRS Report WPD00035, Federal Role in Elections
Funding, by Karen L. Shanton.
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leaving them unable to cast a secret ballot or, in some cases, any ballot at all.26 The bilingual
voting materials mandated by the VRA were not always available.27
Congress responded to the reports of problems with the administration of the 2000 elections, in
part, with mandatory federal standards for voting systems. Title III of HAVA requires states to
specify what counts as a vote for each type of voting system they use in federal elections and
election officials to post certain federal election materials, such as voting instructions and sample
ballots, at the polls.28 Title III also requires voting systems used in federal elections to
• offer voters the opportunity to check and correct their ballots before they are cast
and counted,
• notify voters about overvoting,
• produce a manually auditable permanent paper record,
• provide for accessibility for individuals with disabilities,
• provide for accessibility for members of language minority groups as required by
Section 203 of the VRA, and
• comply with the error rate standards specified by the FEC guidelines that were in
effect when the act was enacted.29
HAVA reserved discretion about exactly how to meet its Title III requirements to the states but
directed the EAC to issue guidance for implementing them and provided for enforcement through
state-based administrative complaint procedures and civil action by the U.S. Department of
Justice (DOJ).30
Voluntary Guidelines
Congress helped fund development of the FEC’s voluntary voting system guidelines, but it did
not explicitly assign the agency authority for developing or maintaining them.31 It also did not
charge the FEC—or any other federal agency—with overseeing testing or certification of systems
to the guidelines. That responsibility was undertaken, instead, by NASED.32
Investigations into the problems with voting systems in 2000 prompted proposals to revisit the
federal role in voting system guidance. A 2001 report from the U.S. General Accounting Office
(GAO; now known as the U.S. Government Accountability Office) found that the FEC guidelines
were not sufficiently comprehensive or current, for example, and suggested assigning federal

26 See, for example, U.S. Commission on Civil Rights, Voting Irregularities in Florida During the 2000 Presidential
Election Chapter 6: Accessibility Issues, at https://www.usccr.gov/files/pubs/vote2000/report/ch6.htm.
27 See, for example, U.S. Congress, Senate Committee on Rules and Administration, Election Reform, 107th Cong., 1st
sess., March 14, 2001, pp. 44, 183.
28 52 U.S.C. §§21081-21082.
29 52 U.S.C. §21081.
30 52 U.S.C. §21003; 52 U.S.C. §§21101-21102; and 52 U.S.C. §§21111-21112. For more on the EAC, see CRS Report
R45770, The U.S. Election Assistance Commission (EAC): Overview and Selected Issues for Congress, by Karen L.
Shanton. For information about DOJ settlements and cases raising claims under HAVA, see DOJ, “Voting Section
Litigation,” at https://www.justice.gov/crt/voting-section-litigation#hava.
31 GAO, Elections: Status and Use of Federal Voting Equipment Standards, October 2001, p. 6, at
https://www.gao.gov/assets/gao-02-52.pdf.
32 U.S. Congress, Committee on House Administration and House Committee on Science, Voting Machines: Will the
New Standards and Guidelines Help Prevent Future Problems? 109th Cong., 2nd sess., July 19, 2006, p. 110.
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agencies explicit responsibility for voting system guidelines, testing, and certification.33 A
commission led by former Presidents Gerald Ford and Jimmy Carter endorsed similar federal
authorities in a report released the same year, with specific recommendations to consult with state
and local officials and reserve a role for NIST.34
Congress took up those recommendations in HAVA. HAVA created a new federal agency
dedicated to election administration, the EAC, and authorized it to (1) develop and maintain the
VVSG, and (2) oversee testing and certification of voting systems to the guidelines. The act
provided for consultation on those processes with state and local officials—as well as a range of
other elections stakeholders—and technical assistance from NIST with carrying them out.
Development and Maintenance
The EAC consists of an appointed commission, a professional staff led by an executive director
and general counsel, an Office of Inspector General (OIG), an agency-created Local Leadership
Council (LLC), and three statutory advisory bodies: the Technical Guidelines Development
Committee (TGDC), the Board of Advisors, and the Standards Board. For details of the
memberships of these three statutory advisory bodies, see Table 3.35
Table 3. Memberships of the U.S. Election Assistance Commission’s Statutory
Advisory Bodies
Advisory Body
Number of Members
Composition of Membership
Technical Guidelines
15
Chaired by the director of the National Institute of
Development
Standards and Technology, who works with the U.S.
Committee (TGDC)
Election Assistance Commission’s commissioners to
appoint 14 other members that include
•
an equal number of members of each of the Board of
Advisors, Standards Board, and Access Board;
•
a representative of each of the American National
Standards Institute and Institute of Electrical and
Electronics Engineers;
•
two representatives of the National Association of
State Election Directors who are not members of the
Board of Advisors, the Standards Board, or the same
political party; and
•
other individuals with technical and scientific expertise
related to voting systems
Standards Boarda
110
One state election official and one local election official
from different political parties for each of the 50 states, the
District of Columbia, American Samoa, Guam, Puerto Rico,
and the U.S. Virgin Islandsb

33 GAO, Elections: Status and Use of Federal Voting Equipment Standards, October 2001, pp. 11-12, 16.
34 The National Commission on Federal Election Reform, To Assure Pride and Confidence in the Electoral Process,
August 2001, p. 57, at https://www.verifiedvoting.org/wp-content/uploads/2012/10/NCFER_2001.pdf.
35 For more on the structure of the EAC, see CRS Report R45770, The U.S. Election Assistance Commission (EAC):
Overview and Selected Issues for Congress, by Karen L. Shanton.
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Advisory Body
Number of Members
Composition of Membership
Board of Advisors
35c
Two members appointed by each of the
•
National Governors Association;
•
National Conference of State Legislatures;
•
National Association of Secretaries of State;
•
National Association of State Election Directors;
•
National Association of Counties;
•
International Association of Government Officials;
•
United States Conference of Mayors;
•
Election Center;
•
United States Commission on Civil Rights; and
•
Access Board
Chiefs of the U.S. Department of Justice’s Office of Public
Integrity and its Civil Rights Division’s Voting Section or
their designees
Director of the U.S. Department of Defense’s Federal
Voting Assistance Program
Four members representing science and technology
professionals, of whom one is appointed by each of the
majority and minority leadership of the House and Senate
Eight members representing voters, of whom two are
appointed by each of the chairs and ranking members of
the Committee on House Administration and Senate
Committee on Rules and Administration
Source: CRS, based on review of the U.S. Code.
Notes:
a. The Standards Board has a nine-member Executive Board that is appointed by the membership of the ful
board. No more than five members of the Executive Board may be either state officials, local officials, or
members of the same political party. 52 U.S.C. §20943.
b. The Commonwealth of the Northern Mariana Islands (CNMI) is not represented on the Standards Board
because it did not hold federal elections when the act that established the board, the Help America Vote
Act of 2002, was enacted. Testimony of the Honorable Gregorio Kilili Camacho Sablan, in U.S. Congress,
Committee on House Administration, Subcommittee on Elections, Voting Rights and Election Administration in
the U.S. Virgin Islands and Other Territories, hearing, 116th Cong., 2nd sess., July 28, 2020, p. 2.
c. The Board of Advisors originally had 37 members, but its membership dropped to 35 with the 2016 merger
of two of the organizations responsible for appointing its members. The National Association of County
Recorders, Election Officials, and Clerks and the International Association of Clerks, Recorders, Election
Officials, and Treasurers merged to form the International Association of Government Officials. Doug
Chapin, “Fewer Letters in the Alphabet Soup: NACRC, IACREOT to Merge,” Election Academy, July 7, 2015,
at http://editions.lib.umn.edu/electionacademy/2015/07/07/fewer-letters-in-the-alphabet-soup-nacrc-iacreot-
to-merge/.
The TGDC is charged by HAVA with helping the executive director of the EAC develop draft
VVSG (for an illustration of the process for developing the VVSG and an overview of federal
responsibilities for the process, see Figure 1 and Table 4, respectively). The act directs NIST to
provide technical support for that work on request, including through research on topics such as
voting system security, fraud prevention and detection, voter privacy protections, human factors,
and remote access voting.36

36 52 U.S.C. §20961. HAVA lists the security of statewide voter registration databases as a possible subject of this
(continued...)
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Once developed by the TGDC, the draft VVSG are shared with the Board of Advisors, the
Standards Board and its Executive Board, and the general public for review and comment before
they are submitted to the EAC’s commissioners for a vote on adoption. HAVA specifically
mandates opportunities for public comment and a public hearing on the VVSG, as well as
publication in the Federal Register of the TGDC’s recommendations, notice of proposed
guidelines, and the final guidelines.37 Adoption of the VVSG requires approval by a three-vote
quorum of the EAC’s four-member commission.38
Selected Work by NIST on Voting Systems
NIST supported development of the most recent iteration of the VVSG, in part, by helping lead public working
groups. HAVA provides for opportunities for input into the VVSG by elections stakeholders and the general public
through roles for the EAC’s statutory advisory bodies and requirements for public notice and comment. The EAC
and NIST expanded on those opportunities for VVSG 2.0 with two sets of working groups that were open to
anyone: (1) three election cycle groups, focused on the preelection, election, and post-election periods; and (2)
four constituency groups, addressing issues related to cybersecurity, human factors, interoperability, and testing.39
Other NIST work on voting systems has included
•
Leading development of common data formats for elections data. Elections involve various types of
data, from precinct boundaries to candidate names to election results. Voting systems have historically
tended to store data in formats that are proprietary to the vendors who manufacture them, but elections
stakeholders saw some potential advantages of standardizing formats across systems. Common data formats
could increase the accuracy and efficiency of elections work, for example, by making it easier to transfer data
between election systems or export it for federal, state, or local reporting purposes. They might help reduce
costs by making it possible to combine components of voting systems from different vendors and to test and
certify those components independently.40

Starting with the TGDC’s work on the 2007 recommendations for the VVSG and continuing through work
with the Institute of Electrical and Electronics Engineers (IEEE) and the VVSG 2.0 public working groups,
NIST has led efforts to develop common data formats for elections data.41 VVSG 2.0 requires federally
certified voting systems to support those common data formats, and the EAC’s testing and certification
program manual provides for a pilot program to test and certify individual voting system components.42
•
Collaborating on soliciting, evaluating, and approving protocols for end-to-end verifiable (E2E-
V) voting systems. Voting systems are expected not only to report accurate election outcomes but also to
offer the public confidence that they do so. One approach many have proposed to achieving those objectives
is verifying the reported outcomes. A key component of that approach is a feature of voting systems known
as “software independence.” Sometimes compared to tamper-evident packaging, software independence is
when “an undetected error or fault in the voting system’s software is not capable of causing an undetectable

research. However, as noted in Table 1 and the “Scope of the Report” section of this report, voter registration databases
are not included in the scope of VVSG 2.0.
37 52 U.S.C. §§20961-20962.
38 52 U.S.C. §20928.
39 NIST, “Voting Working Groups—General Information,” at https://www.nist.gov/itl/voting/voting-working-groups-
general-information. The new working groups provided for input by a wide range of interested parties, but some
practitioners reported that the broader scope made the working groups less effective for their purposes. See, for
example, EAC, United States Election Assistance Commission Public Meeting, April 23, 2019, pp. 132-134, at
https://www.eac.gov/sites/default/files/event_document/files/EAC042319VerbatimPublicHearing.pdf; and EAC, VVSG
Public Hearing, May 20, 2019, at https://www.eac.gov/events/2019/05/20/vvsg-public-hearing-silver-spring.
40 See, for example, NIST, “An Introduction to the Common Data Format Project,” at https://www.nist.gov/itl/voting/
introduction-common-data-format-project; and NIST, “Voting System Interoperability Working Group,” at
https://www.nist.gov/itl/voting/voting-system-interoperability-working-group.
41 NIST, “Interoperability,” at https://www.nist.gov/itl/voting/interoperability.
42 EAC, Requirements for the Voluntary Voting System Guidelines 2.0, pp. 6, 116-117; and EAC, Voting System
Testing and Certification Program Manual Version 3.0, November 15, 2022, p. 79.
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change in election results.”43

VVSG 2.0 requires federally certified voting systems to be software independent and provides for two ways
to meet the requirement: (1) paper-based systems that produce paper records of votes that voters can verify
and election officials can check against the outcomes reported by the voting system, and (2) E2E-V systems
that use cryptography to enable voters to verify that their votes were cast as intended and anyone to check
that votes were tallied as cast.44 There were no E2E-V voting systems on the market as of the adoption of
VVSG 2.0, so the guidelines called for development of a separate approval process for E2E-V cryptographic
protocols.45 The EAC and NIST have started col aborating on establishing that process.46
•
Developing a Cybersecurity Framework Profile for election infrastructure. NIST works with
public- and private-sector partners to develop and maintain a Cybersecurity Framework that organizations
can use to help identify, assess, and manage their cybersecurity risks. The core of the framework is a set of
five functions—Identify, Protect, Detect, Respond, and Recover—that are divided into categories and
subcategories of desirable outcomes paired with references to sample standards, guidelines, and best
practices that organizations can use to achieve them.47

Some of the categories and subcategories of outcomes in the Framework Core may be more important for
certain types of work than others, and individual organizations or sectors can choose to prioritize them in an
organization- or sector-specific Framework Profile.48 NIST released a draft Election Infrastructure Profile in
March 2021 that is intended to be tailored to the specific needs of the election sector.49
•
Conducting research on voting system usability and accessibility. The accessibility of voting systems
to individuals with disabilities and older individuals has featured in various federal statutes, from VAEHA to
HAVA. Some of the catalysts for HAVA, such as Palm Beach County’s butterfly ballots, also highlighted the
importance of ensuring that voting systems are usable by voters in general and by pol workers and election
officials.50

NIST has conducted research into voting system usability and accessibility that has informed the sections of
the VVSG on those topics and has released some of its work in publicly available resources, including
guidance for testing voting systems to VVSG 2.0’s usability and accessibility requirements, writing instructions
and messages for voters and pol workers, and using color in voting systems.51

43 EAC, Requirements for the Voluntary Voting System Guidelines 2.0, pp. 181-182. For more on software
independence, see Ronald L. Rivest and John P. Wack, On the Notion of “Software-Independence” in Voting Systems,
July 28, 2006, at https://people.csail.mit.edu/rivest/pubs/RW06.pdf; and Matthew Bernhard et al., “Public Evidence
from Secret Ballots,” in Electronic Voting: Second International Joint Conference, E-Vote-ID 2017, eds. Robert
Krimmer et al. (Springer, 2017), pp. 84-109.
44 EAC, Requirements for the Voluntary Voting System Guidelines 2.0, pp. 181-182. For more on E2E-V voting
systems, see Josh Benaloh et al., End-to-End Verifiability, February 2, 2014, at https://arxiv.org/ftp/arxiv/papers/1504/
1504.03778.pdf.
45 EAC, Requirements for the Voluntary Voting System Guidelines 2.0, p. 186.
46 EAC, “End to End (E2E) Protocol Evaluation Process,” at https://www.eac.gov/voting-equipment/end-end-e2e-
protocol-evaluation-process; and NIST, “The Path to End-to-End (E2E) Protocols for Voting Systems,” October 6-7,
2022, at https://www.nccoe.nist.gov/get-involved/attend-events/path-end-end-e2e-protocols-voting-systems/post-
workshop-materials.
47 NIST, Framework for Improving Critical Infrastructure Cybersecurity, Version 1.1, April 16, 2018, p. 3, at
https://nvlpubs.nist.gov/nistpubs/CSWP/NIST.CSWP.04162018.pdf.
48 NIST, Framework for Improving Critical Infrastructure Cybersecurity, Version 1.1, p. 4.
49 Mary Brady et al., Cybersecurity Framework Election Infrastructure Profile, NIST, March 2021, at
https://nvlpubs.nist.gov/nistpubs/ir/2021/NIST.IR.8310-draft.pdf.
50 See, for example, U.S. Congress, House Committee on House Administration, Hearing on Oversight of the Election
Assistance Commission, 109th Cong., 2nd sess., June 8, 2006, pp. 68-69; and U.S. Congress, Committee on House
Administration and House Committee on Science, Voting Machines: Will the New Standards and Guidelines Help
Prevent Future Problems? 109th Cong., 2nd sess., July 19, 2006, pp. 78-79.
51 NIST, “Accessibility and Human Factors,” at https://www.nist.gov/itl/voting/research-and-projects/accessibility-and-
human-factors.
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The EAC’s commission adopted the first version of the VVSG, VVSG 1.0, in December 2005.52
The departures of commissioners in 2009 and 2010 and resulting loss of numbers for a quorum
contributed to delaying—and scaling back the agency’s ambitions for—an update to those initial
guidelines.53 VVSG 1.1, which was a relatively minor modification of VVSG 1.0, was adopted in
March 2015.54
The delay in updating the VVSG introduced challenges for states, localities, and voting system
vendors. Some reported that the delay made it more difficult for them to address emerging
security threats and vulnerabilities, for example, or limited their capacity or incentive to take
advantage of new technological innovations.55
Those challenges prompted exploration of a different approach to the next update. VVSG 1.0 and
VVSG 1.1 were lengthy documents that were intended to provide enough technical detail to
enable vendors to build voting systems to the guidelines. The project charter the TGDC released
for VVSG 2.0 in 2016 proposed replacing that detailed technical guidance with a set of high-level
principles and guidelines.56 Under the proposal, the EAC would still produce detailed technical
requirements to help guide manufacture of systems to the principles and guidelines, but those
requirements would not officially be part of the VVSG or subject to approval by the agency’s
commissioners.57 As a result, updates to the high-level principles and guidelines would require a
commission vote, but the more technical requirements could be maintained by the agency’s
professional staff.58
That proposed division of responsibilities between the EAC’s commission and its professional
staff was ultimately not implemented, following an internal legal opinion questioning its
permissibility under HAVA.59 The EAC did, however, retain the structure proposed by the TGDC.
VVSG 2.0, which the commissioners adopted in February 2021, is divided into high-level

52 EAC, “EAC Adopts 2005 Voluntary Voting System Guidelines,” press release, December 13, 2005, at
https://web.archive.org/web/20170327213819/https://www.eac.gov/assets/1/28/VVSG_1.0_Press_Release.pdf. HAVA
indicated that the 2002 FEC guidelines would be deemed to have been adopted by the commission as of the act’s
enactment, but VVSG 1.0 was the first set of guidelines the EAC’s commissioners voted to adopt. For discussion of
EAC adoption of the FEC guidelines, see EAC, United States Election Assistance Commission Public Meeting,
September 21, 2010, pp. 91-92, at https://web.archive.org/web/20210702213539/https://www.eac.gov/sites/default/
files/event_document/files/transcript%20public%20meeting%20september%2021%202010.pdf/.
53 EAC, Statement of Gracia M. Hillman on the Occasion of Her Resignation as Commissioner, U.S. Election
Assistance Commission, December 6, 2010, at https://www.eac.gov/sites/default/files/document_library/files/
GH%20Statement_12_06_10.pdf; and EAC, 2012 Activities Report, p. 2, at https://web.archive.org/web/
20170328053540/https://www.eac.gov/assets/1/6/FY-2012-EAC-Activities-Report-Website-Scanned.pdf.
54 EAC, “EAC Updates Federal Voting System Guidelines,” press release, March 31, 2015, at https://web.archive.org/
web/20170327213732/https://www.eac.gov/assets/1/28/
EAC%20Updates%20Federal%20Voting%20System%20Guidelines-News-Release-FINAL-3-31-15-website.pdf; and
EAC, United States Election Assistance Commission Standards Board Meeting, April 11-12, 2019, p. 86, at
https://www.eac.gov/sites/default/files/event_document/files/EAC0411-1219VerbatimStandardsBoard.pdf.
55 See, for example, EAC, United States Election Assistance Commission Public Meeting, April 23, 2019, pp. 119-120;
and EAC, United States Election Assistance Commission Board of Advisors Meeting, April 24-25, 2019, pp. 272-275,
at https://www.eac.gov/sites/default/files/event_document/files/EAC0419VerbatimBOA.pdf.
56 EAC Technical Guidelines Development Committee (TGDC), Project Charter, VVSG Version 2.0, June 26, 2016, p.
2.
57 “Requirements” in this context refers to requirements voting systems must meet in order to receive federal
certification, not mandatory federal standards for all voting systems. As noted in the “Introduction” to this report, use
of voting systems that conform to the VVSG is voluntary under federal law.
58 National Association of State Election Directors (NASED), NASED Executive Board Comment on the Voluntary
Voting System Guidelines, May 3, 2019, at https://www.nased.org/news/2019/5/3/comment-on-the-vvsg.
59 EAC, Technical Guidelines Development Committee Meeting, September 19, 2019, pp. 42, 304-305, at
https://www.eac.gov/sites/default/files/2020-01/EAC09192019VerbatimTGDC%20%282%29.pdf.
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principles and guidelines and more detailed technical requirements (for the list of high-level
principles and guidelines, see the Appendix).60
Figure 1. Process for Developing the Voluntary Voting System Guidelines
(as specified by the Help America Vote Act of 2002)

Sources: CRS, based on review of the U.S. Code.
Note: The process presented in this figure is as specified in statute.
The EAC also developed a lifecycle policy that agency leadership has described as intended to
help promote more regular updating of the VVSG.61 The policy, which was adopted by the
commissioners in April 2022 and updated in October 2022, establishes a 12-month review cycle
that includes opportunities for the EAC’s statutory advisory bodies and the public to propose
changes to the VVSG and culminates in a decision by the agency’s executive director about
whether to initiate an update.62

60 EAC, “U.S. Election Assistance Commission Adopts New Voluntary Voting System Guidelines 2.0,” press release,
February 10, 2021, at https://www.eac.gov/news/2021/02/10/us-election-assistance-commission-adopts-new-voluntary-
voting-system-guidelines-20; and EAC, Requirements for the Voluntary Voting System Guidelines 2.0, p. 5. Additional
guidance from the EAC on testing and certifying voting systems to VVSG 2.0 is available in test assertions and VSTL
and vendor program manuals. EAC, Voluntary Voting System Guidelines Version 2.0: Test Assertions Version 1.2, at
https://www.eac.gov/sites/default/files/TestingCertification/VVSG%202.0%20Test%20Assertions%20v1.2.pdf; EAC,
Voting System Test Laboratory Program Manual Version 3.0, November 15, 2022, at
https://www.eac.gov/sites/default/files/TestingCertification/VSTL%20Program%20Manual%20Version%203.0%20(3).
pdf; and EAC, Voting System Testing and Certification Program Manual Version 3.0, November 15, 2022.
61 EAC, VVSG Lifecycle Policy Vote Meeting, April 5, 2022, at https://www.eac.gov/events/2022/04/05/vvsg-lifecycle-
policy-10-vote-meeting. As NASED noted in a comment on a draft of the lifecycle policy, the policy does not appear to
address concerns some have voiced about the effects on the VVSG of loss of a quorum at the EAC. EAC, Public
Comments for VVSG Lifecycle Policy, at https://www.eac.gov/sites/default/files/TestingCertification/
Comments_Received_for_VVSG_Lifecycle_Policy_Final.xlsx.
62 EAC, “EAC Adopts Voluntary Voting System Guidelines Lifecycle Policy,” press release, April 5, 2022, at
https://www.eac.gov/news/2022/04/05/eac-adopts-voluntary-voting-system-guidelines-lifecycle-policy; EAC,
“Voluntary Voting System Guidelines,” at https://www.eac.gov/voting-equipment/voluntary-voting-system-guidelines;
and EAC, Voting System Testing and Certification: VVSG Lifecycle Policy, pp. 5-7, at https://www.eac.gov/sites/
default/files/TestingCertification/VVSG_Lifecycle_Policy.pdf.
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Testing and Certification
The EAC’s new lifecycle policy also aims to address another concern some have raised about the
VVSG. Although an update to VVSG 1.0 was adopted in 2015, vendors could continue to submit
voting system modifications for testing to the first version of the guidelines, and they generally
opted to do so; no voting systems were ever certified to VVSG 1.1.63 Under the new policy, by
contrast, most testing to previous iterations of the VVSG is supposed to be discontinued 12
months after the first voting system test laboratory (VSTL) is accredited to test systems to a new
version.64
The first VSTL was accredited to test systems to the current iteration of the VVSG, VVSG 2.0, in
November 2022.65 As with adoption of the VVSG, accreditation of labs to test voting systems to
the guidelines—and revocation of accreditation, if necessary—requires approval by a three-vote
majority of the EAC’s commissioners.66
Also as with the VVSG, HAVA assigns NIST a technical support role in lab accreditation. The act
directs NIST to make accreditation recommendations to the EAC’s commission and, in
cooperation with the commission and consultation with the Board of Advisors and Standards
Board, to monitor and review VSTL performance (for an overview of federal responsibilities for
voting system testing and certification, see Table 4).67
Table 4. Federal Responsibilities for Voluntary Voting System Guidelines, Testing, and
Certification
(as specified by the Help America Vote Act of 2002)
Responsibilities for Developing the
Responsibilities for Testing and
Voluntary Voting System
Certifying Voting Systems to the

Guidelines (VVSG)
VVSG
U.S. Election Assistance
Provide for publication of final VVSG and Provide for testing, certification,
Commission (EAC)
notice of proposed VVSG in Federal
decertification, and recertification of
Commissioners
Register
voting systems to the VVSG
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)

63 EAC, “Certified Voting Systems,” at https://www.eac.gov/voting-equipment/certified-voting-systems; and Matt
Masterson et al., Zero Trust: How to Secure American Elections When the Losers Won't Accept They Lost, Stanford
Internet Observatory, 2021, p. 17, at https://stacks.stanford.edu/file/druid:mf969dh7882/SIO_Zero_Trust_2021.pdf.
64 EAC, Voting System Testing and Certification: VVSG Lifecycle Policy, pp. 4-5. As the EAC emphasizes in the
policy, this deprecation of previous versions of the VVSG is not the same as decertification of systems certified to
previous iterations of the guidelines. States and localities can continue to use such systems, and the lifecycle policy
includes exceptions that are designed to enable them to maintain those systems. The policy permits testing of the
following types of changes to systems certified to deprecated guidelines: (1) security updates, (2) bug fixes, (3)
commercial-off-the-shelf (COTS) equipment replacements, (4) jurisdictional rule changes, and (5) updates or additions
of components that comply with the current version of the VVSG.
65 EAC, “EAC Commissioners Accredit First Voting System Testing Lab to Test Voting Systems to Voluntary Voting
System Guidelines 2.0,” press release, December 7, 2022, at https://www.eac.gov/news/2022/12/07/eac-
commissioners-accredit-first-voting-system-testing-lab-test-voting-systems.
66 52 U.S.C. §20971. The loss of a quorum that delayed an update to the VVSG also delayed lab accreditation.
Accreditation for at least one VSTL was pending when the EAC was without a quorum from 2010 to 2014, and the lab
could not receive accreditation or start testing voting systems to the VVSG until the quorum was restored. EAC,
Reforming the Testing and Certification Process, June 12, 2014, pp. 15-16.
67 52 U.S.C. §20971.
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Responsibilities for Developing the
Responsibilities for Testing and
Voluntary Voting System
Certifying Voting Systems to the

Guidelines (VVSG)
VVSG
EAC Technical Guidelines
Assist EAC executive director with
—
Development Committee
developing VVSG
(TGDC)
Provide for publication of VVSG
recommendations in Federal Register
EAC Board of Advisors
Review proposed VVSG, and submit
Consult on VSTL monitoring and review
and EAC Standards Board
comments and recommendations
National Institute of
Chair TGDC, and provide technical
Recommend VSTLs for accreditation
Standards and Technology support on request
Monitor and review VSTL performance,
(NIST)
and make recommendations about
continuing accreditation
Source: CRS, based on review of the U.S. Code.
Notes: A version of this table was first published in February 2021 in CRS Insight IN11592, Voluntary Voting
System Guidelines (VVSG): An Overview, by Karen L. Shanton. The responsibilities described in the table are as
specified in statute. For more on the composition and duties of the EAC’s statutory advisory bodies, see Table
3 of this report and CRS Report R45770, The U.S. Election Assistance Commission (EAC): Overview and Selected
Issues for Congress, by Karen L. Shanton.
NIST’s VSTL accreditation work, which is carried out by its National Voluntary Laboratory
Accreditation Program (NVLAP), is primarily aimed at ensuring VSTLs have the technical
competency to conduct the necessary testing.68 Other requirements for EAC accreditation address
other aspects of test labs’ operations, such as their finances and hiring practices. For example,
labs interested in accreditation must provide the EAC with recent annual reports and financial
statements and certify that they do not hire staff for roles related to voting system testing who
have been convicted of a felony or other criminal offense involving fraud, misrepresentation, or
deception.69
Vendors who are interested in submitting voting systems for federal certification also must
provide information about their operations, such as their organization and ownership, in order to
register with the EAC.70 Once registered, they can submit voting systems for certification. VSTLs
check that the systems that vendors submit are ready for testing, including by conducting
penetration testing and a preliminary source code review, and then test them for conformance to
the VVSG.71
Confirmation by an EAC-accredited VSTL that a vendor’s voting system conforms to the VVSG
is the primary requirement for federal certification. The vendor must also document to the EAC
that the system’s software has been subjected to a “trusted build” and deposited in an EAC-
approved repository and that it can be verified using the vendor’s system identification tools.72
Decisions about certification are made by the EAC’s executive director or the executive director’s

68 EAC, Voting System Test Laboratory Program Manual Version 3.0, November 15, 2022, pp. 4, 7.
69 EAC, Voting System Test Laboratory Program Manual Version 3.0, November 15, 2022, pp. 13, 24-26, 54.
70 EAC, Voting System Testing and Certification Program Manual Version 3.0, November 15, 2022, pp. 8-12.
71 EAC, Voting System Testing and Certification Program Manual Version 3.0, November 15, 2022, pp. 24-30.
Penetration testing was added to the process as part of the most recent update to the testing and certification program.
See, for example, EAC, “U.S. Election Assistance Commission Adopts New Voluntary Voting System Guidelines 2.0.”
72 EAC, Voting System Testing and Certification Program Manual Version 3.0, November 15, 2022, pp. 36-38. For
more on trusted builds, see EAC, Voting System Testing and Certification Program Manual Version 3.0, pp. 30-32; and
EAC, “What Is a Trusted Build and Why Is It Used?” September 16, 2021, at https://www.eac.gov/what-trusted-build-
and-why-it-used.
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designee and subject to appeal to an Appeal Authority consisting of two or more EAC
commissioners or commission appointees (for an illustration of the certification process, see
Figure 2).73
Figure 2. Process for Certifying Voting Systems to the Voluntary Voting System
Guidelines

Source: CRS, based on review of EAC, Voting System Testing and Certification Program Manual Version 3.0,
November 15, 2022, at
https://www.eac.gov/sites/default/files/TestingCertification/Testing%20and%20Certification%20Program%20Manua
l%20Version%203.0%20(2).pdf.
Vendors with certified systems must also meet program requirements after certification. For
example, they must notify the EAC of any malfunctions of their fielded voting systems and
participate in the agency’s Quality Monitoring Program.74 The Quality Monitoring Program,
which is intended to supplement but not substitute for vendor quality control, involves EAC
review of vendor manufacturing facilities and fielded voting systems, state and local reporting on
voting system anomalies, and vendor submission of technical bulletins and product advisories.75
Failure to comply with such requirements could potentially lead to decertification of a certified
system. The EAC’s testing and certification program manual lists the following as grounds for
decertification: (1) the voting system does not conform to the applicable VVSG; (2) the system
has been modified or changed without following the manual’s requirements; and (3) the vendor
did not follow the manual’s procedural requirements and the quality, configuration, or compliance
of the system is in question. Decertifying a voting system can have significant consequences—

73 EAC, Voting System Testing and Certification Program Manual Version 3.0, November 15, 2022, pp. 36-45.
74 EAC, Voting System Testing and Certification Program Manual Version 3.0, November 15, 2022, pp. 9-10.
75 EAC, Voting System Testing and Certification Program Manual Version 3.0, November 15, 2022, pp. 54-58. In
addition to the long-standing Quality Monitoring Program, the EAC has initiated a Field Services Program that is
aimed at helping local officials monitor election system quality. As part of that program, EAC Commissioner Donald
Palmer testified in March 2023, the EAC will deploy staff to local jurisdictions to help officials ensure that the
equipment they receive matches the system certified by the EAC and meets the conditions set out in the vendor
contract, conduct voting system site surveys, assess best practices, collect system census information, and analyze
anomaly reports. Testimony of EAC Commissioner Donald Palmer, in U.S. Congress, Committee on House
Administration, 2022 Midterms Look Back Series: Government Voter Suppression in Luzerne County, Pennsylvania,
118th Cong., 1st sess., March 28, 2023, pp. 1-2, at https://cha.house.gov/sites/evo-subsites/cha.house.gov/files/evo-
media-document/eac-commissioner-donald-palmer-testimony-3.28.2023.pdf.
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including for the states, localities, and voters that use it—so the EAC offers vendors opportunities
to resolve issues before proceeding with decertification.76
Legislative Activity
HAVA established general procedures for developing the VVSG and for testing and certifying
voting systems to the guidelines, but, as is often the case with statutory language, it did not
specify all the details of how the procedures should work or what they should cover. Those
specifics have been filled in by the EAC, its advisory bodies, and NIST, with input from the
public. Some Members of Congress have introduced legislation to codify, change, or supplement
those choices, offering bills on the VVSG development, testing, and certification processes or the
scope of the guidelines.
Some Members have also proposed expanding the scope of mandatory federal standards for
voting systems. The VVSG have significant influence in practice, as noted in the “Introduction”
to this report, because many states have adopted some or all of the federal voting system testing
and certification program. However, there are relatively few actual federal mandates for voting
systems. While some Members favor limited involvement by the federal government in this area,
others have seen a role for new federal requirements.
VVSG Development, Testing, and Certification Processes
HAVA provided for input by a range of elections stakeholders into VVSG development, testing,
and certification by assigning roles in the processes to the EAC’s statutory advisory bodies. The
TGDC is charged with helping develop draft VVSG, and the Board of Advisors and Standards
Board are responsible for reviewing the draft guidelines and consulting on VSTL monitoring and
review (see Table 4).
The act explicitly designated seats on one or more of the advisory bodies for representatives of
various types of interests and expertise (see Table 3 for details), but not all potential stakeholders
are guaranteed a seat. For example, none of the EAC’s advisory bodies is required by HAVA to
include representatives of voting system vendors or new stakeholders that have emerged since the
act’s enactment, such as DHS.77
Some of those stakeholders have been added to the advisory bodies in practice through
appointment in other capacities. Representatives of voting system vendors and DHS have each
been appointed to the TGDC in their capacities as technical experts, for example.78 However,

76 EAC, Voting System Testing and Certification Program Manual Version 3.0, November 15, 2022, pp. 46-53. See
also, for example, U.S. Congress, Committee on House Administration, 2020 Election Security—Perspectives from
Voting System Vendors and Experts, 116th Cong., 2nd sess., January 9, 2020, p. 286; and EAC, U.S. Election
Assistance Commission Voting Fraud-Voter Intimidation Meeting, October 26, 2006, pp. 56-59, at
https://www.eac.gov/sites/default/files/event_document/files/
transcript%20public%20meeting%20october%2026%202006.pdf.
77 The U.S. Department of Homeland Security (DHS) has taken on new responsibilities for election security following
foreign efforts to interfere in the 2016 elections and the department’s January 2017 designation of election systems as
critical infrastructure. DHS, “Statement by Secretary Jeh Johnson on the Designation of Election Infrastructure as a
Critical Infrastructure Subsector,” January 6, 2017, at https://www.dhs.gov/news/2017/01/06/statement-secretary-
johnson-designation-election-infrastructure-critical. For more on the critical infrastructure designation, see CRS In
Focus IF10677, The Designation of Election Systems as Critical Infrastructure, by Brian E. Humphreys.
78 See, for example, EAC TGDC, Technical Guidelines Development Committee (TGDC) Member Roster, December 8,
2022, p. 2, at https://www.eac.gov/sites/default/files/TechnicalGuidelinesDevelopmentCommittee/
TGDC_Member_Roster_Dec_8_2022.pdf.
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some legislation would formalize their participation. Some Members have proposed adding the
Secretary of Homeland Security or the Secretary’s designee to the Board of Advisors, for
example, or adding representatives of CISA or the voting system manufacturing industry and
voting system usability and accessibility sector to the TGDC.79
The bills described above focus on the participants in VVSG-related processes. Other legislative
proposals would address the processes themselves. First, Members have introduced legislation
related to development of the guidelines. The technical support function HAVA assigned NIST is
a central part of the VVSG development process. NIST’s research can inform choices about what
to include in the guidelines, for example, and help develop technologies or methodologies that
make them easier to implement.80 Some bills would direct the agency to conduct research on
particular topics related to voting systems, such as E2E-V systems and post-election audits, or to
provide for voting system research, such as by administering a voting system research grant
program or establishing a center of excellence in election systems.81
Second, Members have offered legislation related to voting system testing and certification. Some
of those bills have focused on the technical side of testing and certification, specifying certain
types or timing of testing. For example, some Members have proposed codifying inclusion of
penetration testing in the testing and certification process or requiring retesting of federally
certified systems for conformance to the VVSG before each regular federal general election.82
Other bills have addressed procedural aspects of testing and certification, such as conflicts of
interest and transparency. Vendors currently choose and pay VSTLs for testing to the VVSG.
Concerns about potential conflicts of interest have prompted some to propose a different funding
arrangement, in which vendors would pay into a revolving fund or escrow account that would be
used to fund testing, or codification of conflict-of-interest requirements for vendors or VSTLs.83

79 See, for example, the 110th Congress’s Bipartisan Electronic Voting Reform Act of 2008 (S. 3212/S. 3722), the 116th
Congress’s Voting System Cybersecurity Act of 2019 (S. 1454), and the 117th Congress’s For the People Act of 2021
(H.R. 1/S. 1/S. 2093).
80 For example, NIST’s research on usability and accessibility has shaped the content of guidelines on those topics and
its common data formats work helps facilitate the interoperability required by VVSG 2.0.
81 See, for example, the 116th Congress’s Election Technology Research Act of 2020 (H.R. 4990) and Securing and
Verifying Elections in America (SAVE America) Act (H.R. 8962) and the 117th Congress’s Election Security Act of
2022 (S. 5332). Some of those and other bills have also focused on general oversight of or funding for NIST’s voting
systems work. The Election Technology Research Act of 2020 would have directed GAO to report to Congress on
NIST’s work on voting systems, for example, and the For the People Act of 2021 (H.R. 1/S. 1/S. 2093) would have
prohibited the agency from using funding transferred from the EAC for that work unless it committed to reporting on
its use of the funds. HAVA did not explicitly authorize funding for NIST for its role in voting system guidelines
development, testing, and certification, but congressional appropriators have generally directed the EAC to transfer
funding or make funding available to the agency for that purpose. See, for example, the Consolidated Appropriations
Act, 2005 (P.L. 108-447) and the Consolidated Appropriations Act, 2023 (P.L. 117-328).
82 See, for example, the 116th Congress’s Nonpartisan Bill for the People Act of 2019 (H.R. 1612), the 117th Congress’s
Enhanced Election Security and Protection Act (S. 4574), and the 118th Congress’s Strengthening Election
Cybersecurity to Uphold Respect for Elections through Independent Testing (SECURE IT) Act (S. 1500). As noted in
the “Testing and Certification” section of this report, under the current version of the EAC’s testing and certification
manual, voting systems submitted for federal testing and certification are subject to penetration testing as part of a
pretesting test readiness review. EAC, Voting System Testing and Certification Program Manual Version 3.0,
November 15, 2022, pp. 24-26. For a brief discussion of considerations related to penetration testing in voting system
testing and certification, see EAC, United States Election Assistance Commission Board of Advisors Meeting, April 24-
25, 2019, pp. 223-225.
83 See, for example, the 109th Congress’s Improving Electronic Voting Standards and Disclosure Act of 2005 (H.R.
470), the 110th Congress’s Bipartisan Electronic Voting Reform Act of 2008 (S. 3722), the 113th Congress’s EAC
Improvements Act of 2013 (H.R. 2017), and the 114th Congress’s Election Integrity Act of 2016 (H.R. 6072). The EAC
is prohibited from collecting fees for this purpose by the Miscellaneous Receipts Act (31 U.S.C. §3302(b)). For
(continued...)
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Some Members have also proposed codifying access to information about voting system testing
and certification. For example, they have introduced measures that would require VSTLs to allow
the EAC to observe testing or require the EAC to disclose certain information about testing and
certification to election officials or the general public.84
Scope of the VVSG
The VVSG cover voting systems as defined by the EAC, its advisory bodies, and NIST (for
details of the definition of “voting system” used to set the scope of VVSG 2.0, see Table 1).85
That means many of the systems used to administer elections—from the databases that store voter
registration information to electronic poll books (e-poll books) used for voter check-in—are not
addressed by the guidelines or subject to federal testing and certification.86
Problems with those systems can have significant consequences. For example, inaccurate or
incomplete voter registration information could discourage or prevent eligible voters from casting
ballots.87 Reports of crashing or freezing e-poll books could be used to spread misinformation,
undermining voter confidence.88
Much as problems with voting systems spurred support for federal voting system guidelines,
concerns about such potential consequences have prompted some to propose federal guidance for
other election systems.89 Federal agencies have taken some action on such proposals under their

discussion of testing payment practices in other sectors, see EAC, U.S. Election Assistance Commission Voting Fraud-
Voter Intimidation Meeting, October 26, 2006, pp. 54-55, at https://www.eac.gov/sites/default/files/event_document/
files/transcript%20public%20meeting%20october%2026%202006.pdf.
84 See, for example, the 109th Congress’s Secure America’s Vote Act of 2005 (H.R. 3094), the 110th Congress’s
Bipartisan Electronic Voting Reform Act of 2008 (S. 3722), and the 113th Congress’s EAC Improvements Act of 2013
(H.R. 2017). The EAC’s current policy is “to make all documents, or severable portions thereof, [related to the voting
system testing and certification program] available to the public consistent with federal law (e.g. Freedom of
Information Act and the Trade Secrets Act).” EAC, Voting System Testing and Certification Program Manual Version
3.0, November 15, 2022, p. 62. The agency publishes information about its testing and certification program, including
the VSTLs it has accredited and voting systems it has certified, on its website. See, for example, EAC, “System
Certification Process,” at https://www.eac.gov/voting-equipment/system-certification-process; EAC, “Voting System
Test Laboratories (VSTL),” at https://www.eac.gov/voting-equipment/voting-system-test-laboratories-vstl; EAC,
“Withdrawn or Decertified Systems,” at https://www.eac.gov/voting-equipment/withdrawn-or-decertified-systems; and
EAC, “Certified Voting Systems.”
85 See, for example, EAC, United States Election Assistance Commission Board of Advisors Meeting, May 5, 2016, pp.
62-69, at https://www.eac.gov/sites/default/files/event_document/files/EAC.5.5.16.Board_of_Advisors.Verbatim.pdf;
and NIST, VVSG 2.0 Voting System Definition Update, p. 9, at https://www.eac.gov/sites/default/files/2019-12/
VVSGVotingSystemDefinition_TGDC_JohnWack_121819.pdf.
86 The primary function of e-poll books—enabling voters to check in electronically at the polls—is not covered by the
scope of VVSG 2.0. However, e-poll books can also be used to perform other tasks that are covered, such as ballot
activation. Therefore, although e-poll books are not generally subject to the federal voting system testing and
certification program, there are some circumstances in which they may be included in testing. EAC, Requirements for
the Voluntary Voting System Guidelines 2.0, p. 27.
87 See, for example, U.S. Congress, House Committee on the Judiciary, Securing America’s Elections, 116th Cong., 1st
sess., September 27, 2019, p. 40; and EAC, Roundtable Discussion: E-Poll Book Testing Pilot Program
Considerations, November 17, 2021, at https://www.eac.gov/events/2021/11/17/roundtable-discussion-e-poll-book-
testing-pilot-program-considerations. For more on the security of voter registration systems, see CRS In Focus
IF11285, Election Security: Voter Registration System Policy Issues, by Sarah J. Eckman.
88 See, for example, David Levine and Edward Perez, Enhancing the Security of Electronic Pollbooks Is Essential for
Election Integrity, Paper for Election Integrity Project Virtual Workshop on Delivering Trusted Elections: New
Challenges in Electoral Integrity, July 5-9, 2021, pp. 10-12, at https://trustthevote.org/wp-content/uploads/2021/06/
26Jun21_EPollbooks-Levine_Perez.pdf.
89 See, for example, National Academies of Sciences, Engineering, and Medicine, Securing the Vote: Protecting
American Democracy, 2018, pp. 72-73 and 83, at https://nap.nationalacademies.org/download/25120#.
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existing authorities. For example, various agencies have issued best practices for nonvoting
election systems,90 and the EAC has launched pilot programs to test and develop guidelines for
them.91
Some Members have also introduced bills to expand the scope of federal testing and certification
to include new systems. For example, they have offered legislation that would extend the VVSG
and federal testing and certification to e-poll books and remote ballot-marking systems.92
In addition to expanding the scope of the systems covered by the VVSG, some Members have
proposed codifying or expanding the scope of the guidelines’ subject matter. HAVA does not
explicitly say what the VVSG should cover. Floor proceedings on the act and the issues it lists as
possible subjects of research by NIST might offer a sense of the kinds of topics Congress had in
mind,93 but the text of HAVA leaves open choices about exactly what to address.94
Some legislative proposals would codify or add some specifics. Some Members have introduced
legislation to require the VVSG to include guidelines for securing data transmitted electronically
to or from voting systems, for example, or to direct the TGDC to issue election cybersecurity
guidelines and the EAC to provide for testing and certification to them.95
Scope of Mandatory Standards
Congress has used mandatory standards for voting systems to try to advance general objectives
for the administration of elections, such as in VAEHA and the VRA. It has also set requirements
for voting systems in response to developments in particular election cycles. HAVA’s voting
system standards, for example, were largely a response to problems highlighted by the 2000
elections.
Similar considerations have prompted proposals to add new standards. Some Members have
proposed setting new requirements for voting systems as part of attempts to advance long-

90 See, for example, CISA, “Election Security,” at https://www.cisa.gov/topics/election-security; and NIST, “Election
Security,” at https://www.nist.gov/itl/voting/research-and-projects/election-security.
91 See, for example, EAC, 2023 Election Supporting Technology Evaluation Program (ESTEP), January 2023, at
https://www.eac.gov/sites/default/files/2023-01/TGDC%20ESTEP%20Presentation_508.pdf; Testimony of EAC
Commissioners, in U.S. Congress, Senate Committee on Rules and Administration, Hearing on Oversight of the U.S.
Election Assistance Commission, 118th Cong., 1st sess., June 7, 2023, p. 8; and EAC, “U.S. Election Assistance
Commission and the Center for Internet Security Partner on Non-Voting Election Technology Verification Pilot
Program,” press release, June 17, 2020, at https://www.eac.gov/news/2020/06/17/us-election-assistance-commission-
and-center-internet-security-partner-non-voting. For discussion of differences between voting and nonvoting systems
and how they might inform choices about testing nonvoting systems, see EAC, U.S. Election Assistance Commission
Technical Guidelines Development Committee, August 12, 2020, pp. 51-57, at https://www.eac.gov/sites/default/files/
2020-08/tgdc_meeting_on_081220_transcript.pdf.
92 See, for example, the 117th Congress’s Election Security Act of 2022 (S. 5332) and Freedom to Vote: John R. Lewis
Act (H.R. 5746).
93 As it has been defined to date, the scope of the VVSG has not covered all of the potential NIST research topics listed
by HAVA. For example, HAVA lists remote access voting and the security of statewide voter registration databases as
possible subjects of NIST research, but neither is included in the scope of VVSG 2.0. EAC, Requirements for the
Voluntary Voting System Guidelines 2.0, pp. 10-11, 13.
94 A lead sponsor of HAVA confirmed during floor proceedings on the bill that the VVSG were intended to address
“the usability, accuracy, security, accessibility, and integrity of voting systems, including those areas described [as
possible subjects of research by NIST],” but those specifics were not included in the text of the act. Rep. Vernon Ehlers
and Rep. Robert Ney, “Conference Report on H.R. 3295, Help America Vote Act of 2002,” Congressional Record, vol.
148, part 133 (October 10, 2002), p. H7842.
95 See, for example, the 110th Congress’s Know Your Vote Counts Act of 2007 (H.R. 3500) and the 116th Congress’s
Election Security Act of 2019 (H.R. 2660/S. 1540).
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standing elections objectives, such as accurately capturing and counting voters’ selections, and in
response to developments in specific cycles, such as foreign efforts to interfere in the 2016
elections.
Some of those proposals would establish or codify standards for the vendors who manufacture
and maintain voting systems used in federal elections. For example, some Members have
proposed limiting foreign ownership or control of voting system vendors and requiring vendors to
build their systems in the United States, use only domestically sourced parts, or disclose any
foreign sourcing.96 They have proposed requiring vendors to report certain security incidents;
ensure that their information technology infrastructure meets certain cybersecurity standards; and
share information about their voting system software, such as by depositing a copy of the
software in an approved repository, disclosing its source code, or reporting certain information
about the staff involved in developing it.97
Other bills would set standards for the voting systems themselves. One such proposal, which has
been introduced in similar form in each Congress since HAVA’s enactment in the 107th Congress,
would require voting systems used in federal elections to produce individual paper records that
can be verified by voters and manually audited by election officials.98 Other examples include
proposals to set mandatory standards for voting system cybersecurity and accessibility, require
voting systems to support instant runoff voting, prohibit wireless components or internet
connectivity, and mandate compliance with interoperability and auditability provisions of the
VVSG.99
Potential Considerations for Congress
Policymaking about voting systems comes with some complexities. First, voting systems are
expected to achieve many different objectives. They are expected to capture and count votes
accurately and reliably, for example, and to offer the public confidence that they do so. They have
to be accessible to individuals with disabilities and usable by voters and election workers, protect
voter privacy and ballot secrecy, and facilitate timely reporting of election results.

96 See, for example, the 115th Congress’s Protect Election Systems from Foreign Control Act (H.R. 6449); the 116th
Congress’s Secure American-Made Voting Machines Act (H.R. 2652) and Securing America’s Federal Elections
(SAFE) Act (H.R. 2722/S. 2053/S. 2238); and the 117th Congress’s American Election Security Act (H.R. 589), For the
People Act of 2021 (H.R. 1/S. 1/S. 2093), and Protect Our Elections Act (H.R. 6574).
97 See, for example, the 109th Congress’s Improving Electronic Voting Standards and Disclosure Act of 2005 (H.R.
470) and Secure America’s Vote Act of 2005 (H.R. 3094), the 110th Congress’s Election Software Disclosure Act of
2008 (H.R. 7245) and Vote Integrity and Verification Act of 2007 (S. 559), the 112th Congress’s Verifying Official
Totals for Elections (VOTE) Act (H.R. 6246), the 115th Congress’s Protect Election Systems from Foreign Control Act
(H.R. 6449), the 116th Congress’s Securing America’s Federal Elections (SAFE) Act (H.R. 2722/S. 2053/S. 2238), and
the 117th Congress’s Protect Our Elections Act (H.R. 6574). As noted in the “Testing and Certification” section of this
report, the EAC currently requires vendors to meet some of these or similar requirements in order to obtain and
maintain federal certification for their voting systems.
98 See, for example, the 108th Congress’s Voter Confidence and Increased Accessibility Act of 2003 (H.R. 2239/S.
1980), the 117th Congress’s Freedom to Vote Act (S. 2747), and the 118th Congress’s Securing America’s Elections Act
of 2023 (H.R. 466).
99 See, for example, the 109th Congress’s Voter Choice Act of 2005 (H.R. 2690); the 114th Congress’s Election
Integrity Act of 2016 (H.R. 6072); the 116th Congress’s Protecting American Votes and Elections Act of 2019 (H.R.
2754) and Securing America’s Federal Elections (SAFE) Act (H.R. 2722/S. 2053/S. 2238); the 117th Congress’s
Election Audit Transparency Act (H.R. 1070), Election Technology Integrity and Fraud Prevention Act (H.R. 1071),
No Wireless Installations in Federal Instruments for Voting (No WIFI) Act (H.R. 1634), and Safe and Certain Elections
Act (H.R. 5037); and the 118th Congress’s Election Integrity Act of 2023 (H.R. 3257).
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Standards or guidelines that are intended to advance one of those objectives could introduce
challenges for achieving others. For example, requirements aimed at increasing the security of
voting systems could affect their usability or accessibility.100 Efforts to expedite results reporting
could make it more difficult to ensure—or assure the public—that voting systems are secure.101
Second, implementation of voting systems is subject to some practical constraints. With a few
exceptions, voting systems are financed by states and localities and compete for limited state and
local funds with other priorities like potholes and policing.102 Implementing voting systems
involves various, often cost- and time-intensive processes—from the checks described in the
“Background” section of this report to state and local procurement processes to voter education
and poll worker training—and is bound by state limits on preelection changes and the firm
deadline of Election Day.103
Those practical constraints help shape the dynamics of the voting system market. States and
localities tend not to replace their voting systems often and to be price sensitive when they do.104
The limited demand for new systems, combined with barriers to entry like the high upfront costs
of testing and certification and potential reputational risks of misinformation or missteps, means
that the market is relatively small with limited capacity to influence its suppliers.105 The
irregularity of the demand means that much of vendors’ revenue comes from license and support
fees rather than new equipment sales or leases, limiting the incentive to invest in innovation.106
New voting system standards or guidelines have the potential to interact with those practical
constraints and market dynamics in ways Members might not intend. Some requirements might

100 See, for example, EAC, United States Election Assistance Commission Technical Guidelines Development
Committee, September 11, 2017, pp. 71-72, at https://www.eac.gov/sites/default/files/event_document/files/
EAC_TGDC_091117verbatim1.pdf; and EAC, United States Election Assistance Commission Public Meeting, August
23, 2005, pp. 116-122.
101 See, for example, Kim Zetter, “The Myth of the Hacker-Proof Voting Machine,” The New York Times Magazine,
February 21, 2018, at https://www.nytimes.com/2018/02/21/magazine/the-myth-of-the-hacker-proof-voting-
machine.html.
102 See, for example, CISA, Election Infrastructure Subsector-Specific Plan: An Annex to the NIPP 2013, 2020, p. 10,
at https://www.cisa.gov/sites/default/files/publications/election_infrastructure_subsector_specific_plan.pdf; and
Kathleen Hale, Robert Montjoy, and Mitchell Brown, Administering Elections: How American Elections Work (New
York, NY: Palgrave Macmillan, 2015), p. 44, at https://link.springer.com/chapter/10.1057/9781137388452_2. Congress
provided funding for replacing lever and punch card voting systems after the 2000 elections and has sometimes
appropriated more general elections funding that states can choose to put toward replacing or upgrading their voting
systems. For more on those funds, see CRS Report R46646, Election Administration: Federal Grant Funding for States
and Localities, by Karen L. Shanton.
103 See, for example, Edward Perez, Moving the Needle on Voting System Updates: Improving the Process as a Matter
of National Security, OSET Institute, August 2019, p. 9, at https://trustthevote.org/wp-content/uploads/2019/08/
02Aug_Briefing-VSUpdateChallenges-v3.1_Final.pdf.
104 See, for example, Ben Wofford, “One Man’s Quest to Break Open the Secretive World of American Voting
Machines,” Politico Magazine, June 25, 2021, at https://www.politico.com/news/magazine/2021/06/25/voting-
machines-costs-election-technology-democracy-matthew-caulfield-483080; and The Wharton School of the University
of Pennsylvania, The Business of Voting: Market Structure and Innovation in the Election Technology Industry, March
15, 2017, at https://verifiedvoting.org/wp-content/uploads/2021/05/the-business-of-voting-single-page.pdf.
105 See, for example, Matthew Caulfield et al., The Price of Voting: Today’s Voting Machine Marketplace, Verified
Voting, March 2021, at https://verifiedvoting.org/wp-content/uploads/2021/03/Price-of-Voting-FINAL2.pdf; Election
Reform Information Project, Election Reform Briefing: The Business of Elections, August 2004, p. 9, at
https://electionline.org/wp-content/uploads/2018/09/The_Business_of_Elections.pdf; and U.S. Congress, Committee on
House Administration, 2020 Election Security—Perspectives from Voting System Vendors and Experts, 116th Cong., 2nd
sess., January 9, 2020, pp. 58-59.
106 See, for example, Matthew Caulfield et al., The Price of Voting: Today’s Voting Machine Marketplace, Verified
Voting, March 2021, pp. 46-51; and Edward Perez, Moving the Needle on Voting System Updates: Improving the
Process as a Matter of National Security, OSET Institute, August 2019, pp. 2-4.
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be at odds with the practical realities of producing and implementing voting systems, making it
difficult or impossible for vendors or states and localities to meet them.107 For example, voting
system vendors testified at a 2020 hearing that they would not be able to comply with a
requirement to source all of their components domestically because some of the parts they need
are not manufactured in the United States and they do not have the market power to change their
suppliers’ practices.108 Some state and local officials reported in discussions of a bill introduced in
the 110th Congress that they would not be able to implement the proposed changes to their voting
systems on the timeline laid out in the bill.109
Increased costs or practical challenges of meeting new standards or guidelines could also prompt
voting system vendors to exit or opt against entering the space, further consolidating the market
and potentially limiting state and local access to technical support for existing systems.110
Financial or practical hurdles could lead some states to opt out of federal testing and
certification,111 limiting the influence of the VVSG not only in those states but also in general.112
The complexities of voting system policymaking might prompt Congress to keep the federal
status quo on voting systems in place. Congress might choose to leave changes to voting system
policy, if any, to states and localities.
Alternatively, Members might choose to consider whether or how to account for the complexities
when designing standards and guidelines, balancing their overarching priorities for voting
systems against other objectives and practical constraints. For example, they might set deadlines
in consultation with election officials or offer flexibility about how standards and guidelines are
implemented, specifying what voting systems should do rather than exactly how they should do
it.113

107 See, for example, Jessica Huseman, “State Lawmakers Need to Consider Practical Realities When It Comes to
Elections,” Votebeat, February 13, 2023, at https://www.votebeat.org/2023/2/13/23594541/voting-machines-costs-
state-lawmakers-procurement.
108 U.S. Congress, Committee on House Administration, 2020 Election Security—Perspectives from Voting System
Vendors and Experts, 116th Cong., 2nd sess., January 9, 2020, pp. 53, 58-59.
109 See, for example, U.S. Congress, Committee on House Administration, Subcommittee on Elections, Election
Reform: H.R. 811, 110th Cong., 1st sess., March 23, 2007, p. 114; and U.S. Congress, House Committee on House
Administration, Markup of H.R. 811; Consideration of Four Election Contests; and Consideration of a Committee
Franking Allocation Resolution, 110th Cong., 1st sess., May 8, 2007, pp. 113, 129, 251.
110 See, for example, EAC, United States Election Assistance Commission Public Meeting: Interdisciplinary
Roundtable Discussion, May 5, 2008, pp. 114-116, 175-176, at https://www.eac.gov/sites/default/files/
event_document/files/transcript%20roundtable%20may%205%202008.pdf; and EAC, United States Election
Assistance Commission Public Meeting: Voting Systems Manufacturer Roundtable Discussion, February 29, 2008, pp.
10-11, 16-20.
111 Some states have withdrawn or considered withdrawing from the federal voting system testing and certification
program in the past, when they felt it was not sufficiently meeting their needs. See, for example, EAC, Reforming the
Testing and Certification Process, June 12, 2014, pp. 74-75; EAC, United States Election Assistance Commission
Public Meeting, April 23, 2019, pp. 129-130; EAC, United States Election Assistance Commission Public Hearing,
April 10, 2019, pp. 92-93, at https://www.eac.gov/sites/default/files/event_document/files/EAC041019Verbatim.pdf;
and EAC, United States Election Assistance Commission Standards Board, February 26, 2009, pp. 119-121, at
https://www.eac.gov/sites/default/files/event_document/files/
transcript%20standards%20board%20february%2026%202009.pdf.
112 As noted in the “Introduction” to this report, the VVSG currently have significant influence in practice due to
widespread adoption of the federal testing and certification program by the states. Decisions by states to opt out of the
program could undermine that effect, reducing the incentive for vendors to build their voting systems to the VVSG or
pursue federal certification. See, for example, EAC, United States Election Assistance Commission Public Meeting:
Interdisciplinary Roundtable Discussion, May 5, 2008, p. 28.
113 For discussions of this distinction in the context of the VVSG, see EAC, Reforming the Testing and Certification
(continued...)
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Another possible option for Members interested in engaging with voting system policy might be
to explore avenues other than standards and guidelines. Some have proposed using other
legislative tools to advance voting system priorities, such as
• Funding. Congress can use federal funding to facilitate or incentivize choices
about voting systems, including by limiting use of funding to systems with
certain features or to systems or services from vendors who meet certain criteria.
For example, multiple bills in the 117th Congress, including the Election Security
Act of 2022 (S. 5332) and the For the People Act of 2021 (H.R. 1/S. 1/S. 2093),
would have authorized funding for voting systems that met certain conditions or
goods and services from “qualified election infrastructure vendors” who
complied with certain requirements.

Funding might also be used to shape the voting system market itself. Some bills,
such as the Freedom to Vote Act (S. 2747) and the Freedom to Vote: John R.
Lewis Act (H.R. 5746) in the 117th Congress and the Sustaining Our Democracy
Act (S. 630) in the 118th Congress, would provide for ongoing funding states
could use to upgrade their voting systems. Such a consistent stream of federal
funding might shift dynamics of the current voting system market that are shaped
by the limited and irregular demand for new equipment.114
• Research. Federal agency research, or agency-funded research, can help identify
both general improvements to voting systems and solutions to specific voting
system-related problems. For example, HAVA authorized a pair of election
technology research grant programs at the EAC that have been used for
Accessible Voting Technology, Military Heroes, and Pre-Election Logic and
Accuracy Testing and Post-Election Audit initiatives, and NIST led development
of common formats for elections data.115 The Defense Advanced Research
Projects Agency (DARPA) has also contributed to advancing development of a
secure, open-source voting system, and the National Science Foundation (NSF)
has awarded grants for voting technology research.116

Some Members have introduced bills that would provide for other voting system
research or research grant programs. Those bills include the NIST research
proposals described in the “VVSG Development, Testing, and Certification

Process, June 12, 2014; Sharon J. Laskowski et al., Improving the Usability and Accessibility of Voting Systems and
Products, NIST, May 2004, at https://tsapps.nist.gov/publication/get_pdf.cfm?pub_id=906168; and AEI-Brookings
Election Reform Project VVSG Task Force, A Review of Proposed Voluntary Voting System Guidelines: A Report of
the AEI-Brookings Election Reform Project VVSG Task Force, May 8, 2008, https://www.brookings.edu/wp-content/
uploads/2016/06/0520_voting.pdf.
114 See, for example, The Wharton School of the University of Pennsylvania, The Business of Voting: Market Structure
and Innovation in the Election Technology Industry, March 15, 2017, p. 33; and U.S. Congress, Committee on House
Administration, 2020 Election Security—Perspectives from Voting System Vendors and Experts, 116th Cong., 2nd sess.,
January 9, 2020, p. 272. For more on federal funding for elections in general, see CRS Report R46646, Election
Administration: Federal Grant Funding for States and Localities, by Karen L. Shanton; and CRS Report WPD00035,
Federal Role in Elections Funding, by Karen L. Shanton.
115 52 U.S.C. §§21041-21043; 52 U.S.C. §§21051-21053; EAC, “Discretionary Grants,” at https://web.archive.org/
web/20200622235023/https://www.eac.gov/payments-and-grants/discretionary-grants/; and NIST, “Interoperability,” at
https://www.nist.gov/itl/voting/interoperability.
116 See, for example, U.S. Congress, House Committee on Science, Space, and Technology, Subcommittee on
Investigations and Oversight and Subcommittee on Research and Technology, Election Security: Voting Technology
Vulnerabilities, 116th Cong., 1st sess., June 25, 2019, pp. 168-169.
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Processes” section of this report, as well as the proposals to assign voting system
research or research grant programs to other agencies in legislation like the 115th
Congress’s Protecting the American Process for Election Results (PAPER) Act
(H.R. 3751) and Election Infrastructure and Security Promotion Act of 2017
(H.R. 1907); the 116th Congress’s Election Security Assistance Act (H.R. 3412)
and Election Technology Research Act of 2020 (H.R. 4990); and the 117th
Congress’s Accessible Voting Act of 2021 (H.R. 2941/S. 1470), Securing
America’s Elections Act of 2021 (H.R. 4384), and Election Security Act of 2022
(S. 5332).117
• Technical assistance. Technical assistance from federal agencies can help states,
localities, and vendors carry out work on their voting systems that they might not
choose to do—or lack the technical or financial capacity to do—on their own.
For example, the EAC has initiated a Field Services Program to help states and
localities monitor the quality of their voting systems and provided assistance with
implementing risk-limiting audits.118 CISA has offered states, localities, and
vendors a range of election security services, such as risk and vulnerability
assessments, cyber hygiene scans, and the open-ended vulnerability assessments
available under its Critical Product Evaluation Program.119

Some Members have proposed codifying some of the assistance federal agencies
currently offer or establishing new kinds of agency support. The 116th Congress’s
Election Security Act of 2019 (H.R. 2660/S. 1540) and the 117th Congress’s For
the People Act of 2021 (H.R. 1/S. 1/S. 2093) would have codified CISA’s risk
and vulnerability assessments, for example, and the 117th Congress’s American
Confidence in Elections (ACE) Act (H.R. 8528) would have provided for
voluntary cybersecurity vulnerability testing by CISA and the EAC. The 116th
Congress’s Election Security Assistance Act (H.R. 3412) would have established
an Election Cyber Assistance Unit at the EAC, and the 117th Congress’s
Accessible Voting Act of 2021 (H.R. 2941/S. 1470) would have created an EAC
Office of Accessibility and National Resource Center on Accessible Voting.
Members might also choose to consider acting on other congressional authorities, such as
oversight or appointment authorities, instead of or in addition to pursuing legislation. For
example, as noted in the “Voluntary Guidelines” section of this report, updates to the VVSG and
accreditation of labs to test systems to the guidelines require approval by a three-vote majority of
the EAC’s commissioners, and lack of a quorum has sometimes delayed that work. HAVA assigns
Congress roles in recommending and confirming candidates for the commission, and some
Members might choose to focus on ensuring the continued availability of a quorum.

117 See also, for example, National Academies of Sciences, Engineering, and Medicine, Securing the Vote: Protecting
American Democracy, 2018, p. 123.
118 See, for example, Testimony of EAC Commissioner Donald Palmer, in U.S. Congress, Committee on House
Administration, 2022 Midterms Look Back Series: Government Voter Suppression in Luzerne County, Pennsylvania,
118th Cong., 1st sess., March 28, 2023, pp. 1-2; and EAC, 2020 Annual Report, p. 47, at https://www.eac.gov/sites/
default/files/document_library/files/EAC_2020_Annual_Report-508c.pdf.
119 See, for example, Testimony of Matthew Masterson, in U.S. Congress, House Committee on Homeland Security,
Subcommittee on Cybersecurity, Infrastructure Protection, and Innovation, Securing Democracy: Protecting Against
Threats to Election Infrastructure and Voter Confidence, 117th Cong., 2nd sess., January 20, 2022, pp. 11-12; and CISA,
“Election Security Services.”
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Appendix. Principles and Guidelines of Voluntary
Voting System Guidelines 2.0 (VVSG 2.0)
Table A-1. Principles and Guidelines of Voluntary Voting System Guidelines 2.0
(VVSG 2.0)
Principles
Guidelines
Principle 1: High quality design
1.1—The voting system is designed using commonly accepted election process
The voting system is designed
specifications.
to accurately, completely, and
1.2—The voting system is designed to function correctly under real-world
robustly carry out election
operating conditions.
processes.
1.3—Voting system design supports evaluation methods enabling testers to
clearly distinguish systems that correctly implement specified properties from
those that do not.
Principle 2: High quality
2.1—The voting system and its software are implemented using trustworthy
implementation
materials and best practices in software development.
The voting system is
2.2—The voting system is implemented using best practice user-centered design
implemented using high quality
methods that consider a wide range of representative voters, including those
best practices.
with and without disabilities, and election workers.
2.3—Voting system logic is clear, meaningful, and well-structured.
2.4—Voting system structure is modular, scalable, and robust.
2.5—The voting system supports system processes and data with integrity.
2.6—The voting system handles errors robustly and graceful y recovers from
failure.
2.7—The voting system performs reliably in anticipated physical environments.
Principle 3: Transparent
3.1—The documentation describing the voting system design, operation,
The voting system and voting
accessibility features, security measures, and other aspects of the voting system
processes are designed to
can be read and understood.
provide transparency.
3.2—The processes and transactions, both physical and digital, associated with
the voting system are readily available for inspection.
3.3—The public can understand and verify the operations of the voting system
throughout the entirety of the election.
Principle 4: Interoperable
4.1—Voting system data that is imported, exported, or otherwise reported, is
The voting system is designed
in an interoperable format.
to support interoperability in
4.2—Standard, publicly available formats for other types of data are used, where
its interfaces to external
available.
systems, its interfaces to
internal components, its data,
4.3—Widely-used hardware interfaces and communications protocols are used.
and its peripherals.
4.4—Commercial-off-the-shelf (COTS) devices can be used if they meet
applicable VVSG requirements.
Principle 5: Equivalent and
5.1—Voters have a consistent experience throughout the voting process within
consistent voter access
any method of voting.
All voters can access and use
5.2—Voters receive equivalent information and options in all modes of voting.
the voting system regardless of
their abilities.
Principle 6: Voter privacy
6.1—The voting process preserves the privacy of the voter’s interaction with
the ballot, modes of voting, and vote selections.
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Principles
Guidelines
Voters can mark, verify, and
6.2—Voters can mark, verify, and cast their ballot or other associated cast vote
cast their ballot privately and
record, without assistance from others.
independently.
Principle 7: Marked, verified,
7.1—The default voting system settings present a ballot usable for the widest
and cast as intended
range of voters, and voters can adjust settings and preferences to meet their
Ballots and vote selections are
needs.
presented in a perceivable,
7.2—Voters and election workers can use all controls accurately, and voters
operable, and understandable
have direct control of all ballot changes and selections.
way and can be marked,
verified, and cast by all voters.
7.3—Voters can understand all information as it is presented, including
instructions, messages from the system, and error messages.
Principle 8: Robust, safe,
8.1—The voting system’s hardware, software, and accessories are robust and
usable, and accessible
do not expose users to harmful conditions.
The voting system and voting
8.2—The voting system meets currently accepted federal standards for
processes provide a robust,
accessibility.
safe, usable, and accessible
experience.
8.3—The voting system is evaluated for usability with a wide range of
representative voters, including those with and without disabilities.
8.4—The voting system is evaluated for usability with election workers.
Principle 9: Auditable
9.1—An error or fault in the voting system software or hardware cannot cause
The voting system is auditable
an undetectable change in election results.
and enables evidence-based
9.2—The voting system produces readily available records that provide the
elections.
ability to check whether the election outcome is correct and, to the extent
possible, identify the root cause of any irregularities.
9.3—Voting system records are resilient in the presence of intentional forms of
tampering and accidental errors.
9.4—The voting system supports efficient audits.
Principle 10: Ballot secrecy
10.1—Ballot secrecy is maintained throughout the voting process.
The voting system protects the 10.2—The voting system does not contain nor produce records, notifications,
secrecy of voters’ ballot
information about the voter or other election artifacts that can be used to
selections.
associate the voter’s identity with the voter’s intent, choices, or selections.
Principle 11: Access control
11.1—The voting system enables logging, monitoring, reviewing, and modifying
The voting system
of access privileges, accounts, activities, and authorizations.
authenticates administrators,
11.2—The voting system limits the access of users, roles, and processes to the
users, devices, and services
specific functions and data to which each entity holds authorized access.
before granting access to
sensitive functions.
11.3—The voting system supports strong, configurable authentication
mechanisms to verify the identities of authorized users and includes multi-factor
authentication mechanisms for critical operations.
11.4—The voting system’s default access control policies enforce the principles
of least privilege and separation of duties.
11.5—Logical access to voting system assets are revoked when no longer
required.
Principle 12: Physical security
12.1—The voting system supports mechanisms to detect unauthorized physical
The voting system prevents or
access.
detects attempts to tamper
12.2—The voting system only exposes physical ports and access points that are
with voting system hardware.
essential to voting operations.
Principle 13: Data protection
13.1—The voting system prevents unauthorized access to or manipulation of
configuration data, cast vote records, transmitted data, or audit records.
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Principles
Guidelines
The voting system protects
13.2—The source and integrity of electronic tabulation reports are verifiable.
data from unauthorized access,
modification, or deletion.
13.3—All cryptographic algorithms are public, well-vetted, and standardized.
13.4—The voting system protects the integrity, authenticity, and confidentiality
of sensitive data transmitted over all networks.
Principle 14: System integrity
14.1—The voting system uses multiple layers of controls to provide resiliency
The voting system performs its against security failures or vulnerabilities.
intended function in an
14.2—The voting system is designed to limit its attack surface by avoiding
unimpaired manner, free from
unnecessary code, data paths, connectivity, and physical ports, and by using
unauthorized manipulation of
other technical controls.
the system, whether
intentional or accidental.
14.3—The voting system maintains and verifies the integrity of software,
firmware, and other critical components.
14.4—Voting system software updates are authorized by an administrator prior
to installation.
Principle 15: Detection and
15.1—Voting system equipment records important activities through event
monitoring
logging mechanisms, which are stored in a format suitable for automated
The voting system provides
processing.
mechanisms to detect
15.2—The voting system generates, stores, and reports all error messages as
anomalous or malicious
they occur.
behavior.
15.3—The voting system is designed to protect against malware.
15.4—A voting system with networking capabilities employs appropriate, well-
vetted modern defenses against network-based attacks, commensurate with
current best practice.
Source: U.S. Election Assistance Commission, Requirements for the Voluntary Voting System Guidelines 2.0,
February 10, 2021, pp. 21-25, at https://www.eac.gov/sites/default/files/TestingCertification/
Voluntary_Voting_System_Guidelines_Version_2_0.pdf.
Notes: In addition to the high-level principles and guidelines listed in this table, VVSG 2.0 includes more detailed
technical requirements voting systems must meet to receive federal certification. Additional guidance from the
EAC on testing and certifying voting systems to VVSG 2.0 is also available in test assertions and program manuals
for voting system vendors and test laboratories.

Author Information

Karen L. Shanton

Analyst in American National Government

Acknowledgments
Brion Long, Visual Information Specialist, provided assistance with the figures in this report.
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