CDT Comments to the U.S. Election Assistance Commission on Voluntary Voting System Guidelines

The U.S. Election Assistance Commission (EAC) is responsible for managing the Voluntary Voting System Guidelines (VVSG) program. States can choose to require that their voting machines (i.e. those used for casting and tabulating ballots) be certified under the VVSG requirements. As part of the VVSG Lifecycle Policy, the EAC regularly solicits public comments regarding proposed changes to the VVSG.

Today, CDT filed comments in response to the EAC’s 2023 request for comments related to VVSG improvements. Our comments focus primarily on parts of the VVSG that relate to ballot-marking devices (BMDs), a topic that we have studied in recent years, including in a 2022 CDT report. BMDs are used by millions of Americans in every election; about a quarter of all registered voters live in jurisdictions using BMDs for all voters. BMDs are a crucial technology for ensuring that voters with disabilities are able to vote privately and independently. 

The EAC must update the VVSG to ensure that votes cast via BMD are not second-class votes. Our requested changes to the VVSG should better ensure that VVSG-certified BMDs are usable and accessible, ensure the privacy of voters who use them, and increase the likelihood that voters can and will verify their BMD-printed ballots before casting them.

Read the full comments here.