Considerations for 

Implementing Voting 

Systems with COTS 

Products

 www.eac.gov @EACgov

United States Election Assistance Commission 

1335 East-West Highway Ste. 4300 Silver Spring , M D 20910 

 Managing Election Technology Series: #3
U.S. ELECTION ASSISTANCE COMMISSION www.eac.gov

The EAC’s Managing Election Technology Series

"The first rule of any technology used in a business is that automation applied to an efficient 

operation will magnify the efficiency. The second is that automation applied to an inefficient 

operation will magnify the inefficiency." 

--Bill Gates

Overview

The Election Official of today is an Information Technology (IT) Manager – whether they think they are, 

whether they want to be, or whether they were trained to be. IT Management requires a unique set of 

attitudes, knowledge and skills in order to plan, direct, and control contemporary election 

administration. This series of guides to managing election technology identify the primary areas in 

which the effective Election Official must recognize their role as an IT manager and provides ideas and 

best practices to assist in accommodating the demands of the modern election’s office.
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Implementing Voting Systems with COTS 

Products

Over the course of the past several years, 

election jurisdictions seeking to purchase new 

election systems have begun a significant shift 

in focus away from the traditional approach of 

procuring predominantly proprietary election 

systems and toward procuring systems largely 

composed of commercial products. This shift 

follows what has become the practice over the 

past decade in state and U.S. Federal

Government procurements, particularly those 

of the Department of Defense (DoD) and other 

large agencies. Many current Requests for 

Proposals (RFPs) being issued by government 

agencies now include a mandate concerning the 

amount of “COTS” (commercial off-the-shelf) 

products that must be included.

The considerations noted in this paper related 

to COTS products are cautionary: it is obvious to 

observers of election administration in this 

country that the growth in proprietary 

hardware/software costs are likely to continue, 

and that appropriate use of commerciallyavailable products is one of the remedies that 

might enable election jurisdictions to acquire 

new and improved systems in a cost-effective 

manner. Additionally, COTS-solutions may 

provide needed flexibility in managing the 

service life of election systems as well as 

increasing their adaptability to changing 

requirements.

Like any solution to a problem, there are 

drawbacks as well as benefits to using COTS in 

election systems: while it may not be readily 

apparent to the election community as yet, 

many trade-offs exist when integrating a 

predominantly commercial product into an 

election system. Using COTS components in any 

given circumstance might prove cheaper and 

easier to implement, but this is certainly not

guaranteed. Election officials, in their capacity 

as IT managers, must understand that the use 

of a COTS component may be a reasonable 

solution, but its use should be the product of 

careful analysis, reasoning, well-formed policy 

and practicable engineering decisions. COTS 

solutions present both opportunity and risks to 

jurisdictions who specify their inclusion in their 

election systems.

This paper discusses major considerations 

election officials should ponder before 

determining the extent to which their future 

election or voting system implements a 

predominantly COTS inclusive approach.

1. Use the term “COTS” precisely. 

It is important to get a clear definition of 

the term “COTS.” The following definition is 

included in the EAC Voluntary Voting 

System Guidelines, Version 1.1 and is the 

definition agreed to by the panel convened 

at the 2011 EAC Roundtable on COTS:

COTS: “Software, firmware, device or 

component that is used in the United 

States by many different people or 

organizations for many different 

applications other than certified voting 

systems and that is incorporated into 

the voting system with no 

manufacturer- or application-specific 

modification.”

Note that some items that appear to be 

COTS are really more correctly modified 

COTS1

. Any change made by an integrator 

or third party to a COTS product disqualifies 

it from being truly COTS. True COTS should 

be able to be purchased at a retail store like 

Best Buy or directly from the manufacturer 

(Dell or Apple, for example) and be able to 

be plugged into the election system with no 

 1 Modified COTS (or MOTS – Modified Off-the-Shelf) refers 

to an off-the-shelf product that is customized by a 

commercial vendor to respond to specific requirements of 

the election community.
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modification of the COTS product and only 

trivial accommodation required from 

existing components (ex: installing a COTS 

printer may require the installation and 

customization of a printer driver)

Likewise, it is equally important to define 

the term “proprietary”:

Proprietary: “A technology or product 

that is owned and distributed 

exclusively by a single company and 

that is protected by patent, copyright or 

trademark.” 

A common example of a proprietary 

product is Adobe Acrobat, whose Portable 

Document Format (PDF) files can only be 

read with the Acrobat Reader. 

To further complicate best efforts to use 

these terms in a very precise manner, many 

products (and many, if not most, current 

voting system components) use numerous 

COTS or slightly modified COTS products) in 

what we generally term “proprietary” 

voting systems. This fact is best illustrated 

by the fact that several current voting 

system manufacturers use the same COTS 

scanning device as the basis for their 

proprietary precinct count optical scanning 

products. 

2. Understand the impact of COTS 

products on the RFP and selection 

process

The use of COTS products has significant 

impact on both the RFP requirements and 

the evaluation of proposals, an impact that 

must be understood early in the election 

system acquisition process. When 

purchasing COTS based systems, an election 

official must have a full accounting of the 

various implementations of the systems as 

well as who is responsible for each portion 

of the process supported by the systems. 

The purchasing jurisdiction must view itself 

as an election system integrator instead of 

the more traditional view of the election 

official as an election system implementer. 

The election official may want to include an 

IT integration requirement to the RFP so 

there is a clear line of responsibility and 

accountability for bringing together the 

various COTS based systems with already 

existing election technology in the office. In 

the end, the election official will be held 

accountable for all the components and 

systems working together as intended. 

Election officials will do well to work closely 

with their IT procurement officers to ensure 

that there is no misunderstanding about the 

intended role of the COTS products, their 

maintenance, and the potential impact of 

unplanned and unauthorized substitutions.

3. Understand COTS impact on system 

integration.

Integrating COTS components into your 

system is not necessarily simpler than 

integrating proprietary components, and 

may in fact be more difficult. The current 

thrust toward incorporating COTS products 

takes place in the context of “COTS-based 

voting/election systems.” That is, complex 

groupings of components, interacting in 

diverse ways, and in which introducing 

commercial components will 

simultaneously result in lower cost as well 

as providing the system “plug-and-play”

characteristics

The phrase “plug-and-play” is significant, 

and is frequently the unspoken motivator 
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for much of the current interest in COTS 

products. It conjures up a “software

centric” environment wherein 

heterogeneous hardware components can 

be easily inserted or replaced, and in which 

components interconnect and interoperate

without modification or effort on the part 

of the integrator2

. It is based on the realities 

of the larger hardware world, where some 

degree of “plug and play” really does exist; 

boards, cables, printers, monitors, and

keyboards can all be purchased, replaced, 

and upgraded independently and easily.

Even with this degree of interoperability 

however, changes in hardware can have 

significant impact on a system. (As an 

example, substituting a short, shielded 

cable with a standard 3m USB cable might 

very well have a negative effect on the EMI 

characteristics of the system.)

The “plug and play” notion also rests on 

assumptions about data that different tools 

will share. For the past several years, the 

IEEE P1622 committee3 has been working 

to specify a standard or set of standards for 

a common data format for election systems

partially in order to assist in the integration 

and testing of components from different 

manufacturers and vendors. This work 

shows much promise, but still has an 

incredibly long way to go before allowing 

for true “plug and play” capability in 

election systems.

 2 An integrator (sometimes known as systems integrator) is 

a person or company that specializes in bringing together 

component subsystems into a whole and ensuring that those 

subsystems function together. As noted above, the election 

administrator may well become the integrator of the future.

3 This work is now integrating with the EAC/NIST/TGDC VVSG 

standards development process.

4. Understand COTS impact on the testing 

process.

Testing and validation of COTS-based voting 

and election systems is a substantially

different process than testing and validating 

proprietary systems. All three pre- election 

system test efforts and post-election audits 

will be impacted by the introduction of 

primarily COTS based systems: 

Federal Certification Testing

COTS products are, by nature, tested 

very differently than traditional voting 

system products. On the COTS 

manufacturer side, testing is market 

driven, not statutory or rule drive like 

Federal and State voting system testing. 

Significant research will need to be 

done to determine exactly what levels 

of testing are appropriate for COTS 

based voting and election systems. 

Much will depend upon the availability 

of testing and quality assurance 

information available from the COTS 

vendor. Certainly and at minimum, 

COTS products will need to be 

functionally tested with the full 

voting/election system to be certain 

that at least the versions of COTS 

submitted for testing work as intended 

in the system. New requirements

(VVSG) must be written to focus more 

on the product/system interface level 

and focus on performance or functional 

characteristics (i.e., what should the 

product/system be capable of doing as

opposed to how the product/system 

should do it). These functional 

characteristics should also be

quantifiable and testable by the VSTLs 

or others.
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Risk will also need to be factored into 

determinations on the level of test 

effort. What is the risk that the COTS 

product has defects? What percentage 

of allowable defects is acceptable to the 

COTS manufacturer(s)? We know that 

commercial products are never defectfree. Large commercial product vendors 

conduct a continuous balancing act 

between the quality of the system and 

time-to-market delivery, and often 

time-to market considerations win out 

over quality. In addition, while 

counterfeiting is an infrequent 

occurrence in COTS products, it does 

happen and when it occurs, it presents 

an additional obstacle to testing and 

assurance.

Federal certification testing also places 

significant importance on finding the 

root cause of failures encountered 

during the testing process. For some 

COTS-based system failures, finding the 

actual source of the failure, the root 

cause, or even re-creating the failure, 

will be more complex and timeconsuming. This will be especially true 

when the COTS election system involves 

products from multiple COTS vendors.

State certification testing will have to 

address many of the same issues faced 

by the Federal certification program, 

but perhaps with fewer resources and 

less time to complete the testing. 

States who engage in certification 

testing of voting systems will need to 

modify and validate their testing 

protocols to accommodate COTS 

components.

State/Local Acceptance Testing

The purpose of acceptance testing is to 

verify that the certified version of the 

election system is delivered to the 

jurisdiction and that the system can 

perform the functions required by the 

State and/or local election jurisdiction. 

Acceptance testing becomes a more 

complex process when integrating COTS 

components. Commercial COTS

products typically have an accelerated 

development lifecycle and may change 

every 1-2 years or less. This will 

guarantee that units delivered to the 

jurisdiction will likely not be identical to 

either the certified version, or to 

versions delivered at other times.

Another factor to consider when 

acceptance testing COTS based systems 

is determining how to test to ensure 

that the COTS products work correctly 

with all other products in your 

dependent voting or broader election 

system. Do they negatively impact your 

election night reporting system? Your epollbook system? 

Jurisdictions will need to implement 

strict version control protocols to 

ensure that all individual units are using 

the same software releases, or when 

not possible, to document the 

difference.

Logic & Accuracy (L&A) Testing

Pre and post-election logic and accuracy 

testing will be impacted as the system 

may actually introduce new COTS 

components at any time, thus making 

your system “new” again every single 
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time it is used. To that end, election 

officials will likely want to revise L&A 

test scripts each time the system 

changes. These script changes may be 

major or minor, depending on the 

nature of the system change.

L&A Testing will continue to evolve so 

that not only is the ballot being tested, 

but that the system itself is being 

tested. L&A tests that utilize sampling 

methods will have to be expanded to 

include a comprehensive review of all 

equipment to be used in the upcoming 

election. This use model will need to 

include end-to-end testing methods, 

pushing past just vote capture and 

tabulation, to include election night 

reporting and post election activities 

that are dependent upon the 

correctness of the system.

Audits and Other Post-Election 

Testing

Any jurisdiction post-election audit 

procedures will need to be reviewed to 

identify controls that may be impacted 

by the revision of COTS components in 

the system. In fact, the COTS 

components themselves may become 

the subject of such audits.

5. Understand that a COTS approach 

makes a voting or election system 

dependent on the COTS vendors.

Vendor support for the commercial 

components in a COTS-based system is 

critical to the success of that system; many 

unforeseen problems can accompany a 

commercial system after deployment. The 

role of the COTS components’ vendors can 

be a decisive factor in successfully 

implementing and maintaining a COTSbased system. Several aspects are especially 

significant.

Does the COTS vendor supply adequate 

documentation for the component or 

components in question? Some COTS 

products offer extensive and useful 

documentation, but this is by no means 

universal. Is the documentation wellwritten and accurate? Can it be relied upon 

to be the integrator in order support 

election system testing, maintenance and 

future development? What kind of user 

support is available? Is the vendor

responsive to user inquiries? In the current 

predominantly proprietary voting system 

world, problem calls will generally go to a 

help desk or to a field representative of 

your system manufacturer at their 

headquarters or in your own State or 

jurisdiction. COTS products often use 

outsourced help desk/call centers that are 

located in various locations around the 

world with varying levels of service. 

Finally, if the COTS component is to be part

of a election system that is expected to

operate for several years, what are the

probabilities that the company will exist for 

that time? Finally, even assuming that the 

company exists, how long will it support the 

COTS product in question? Vendors often 

phase out their support for any given 

product: would such an occurrence have an 

impact on the maintenance of your election

system? By way of example, on September 

30, 2015, Apple stopped signing4 iOS 8.4.1 

 

4 signing is the process of 

digitally signing executables and scripts to confirm the 
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and the first version of iOS 9 for the iPhone, 

iPad, and iPod touch, meaning users could

no longer upgrade or downgrade to those 

versions of iOS . Apple is now signing iOS 

9.0.1 and iOS 9.0.2 only.

6. Realize the cost of maintaining a COTS 

system.

The presence of COTS components does not 

necessarily mean low maintenance cost. 

COTS components can, in fact, cause 

complex problems during system upgrade 

and system maintenance. These problems 

could potentially exceed the maintenance 

cost of a proprietary system.

First, upgrading COTS-based system 

software means that as new releases of the 

commercial components are made by the 

various vendors, the system will incorporate 

them. In some instances, users can refuse 

upgrades and new releases, but it is safer to 

assume that the upgrades are inevitable.

Commercial vendors tend to support only a 

limited number of versions at any one time, 

and ignoring a vendor’s new releases is not 

an appropriate long term solution. 

A further complicating factor is that 

different COTS components of the system 

will likely be upgraded at widely varying 

intervals; licenses will be invalidated and 

need to be revalidated for different parts of 

the system at random intervals. It should 

be kept in mind that COTS component 

upgrades can result in unforeseen problems 

including incompatible files and databases, 

different naming conventions, and 

 

software author and guarantee that the code has not been 

altered or corrupted since it was signed by use of 

a cryptographic hash.

introduction of new conflicts between COTS 

components. Depending on the number of 

COTS components and different COTS 

vendors, the effect of these multiple 

dependencies can vary from short-term 

user inconvenience to total system 

instability.

Finally, election officials will need to begin 

looking at voting and election system 

components more as disposable 

commodities rather than assets.

“Maintenance” of these systems will most 

often entail replacing, upgrading and 

substituting components rather than the 

traditional model of sending a system back 

to the manufacturer, or having them come 

into your office or warehouse to conduct 

service or maintenance. 

7. Implementing COTS is not an 

automatic cost-saver

Although it might initially appear that the 

availability of COTS components brings

down election system costs, there are also 

offsetting costs to consider and manage

over the course of the COTS system 

lifecycle. 

One of the most overlooked, yet potentially 

significant costs associated with the use of 

COTS products is effective COTS-specific 

planning and budgeting. Without adequate 

planning, the jurisdiction may become 

reactive to the inevitable COTS-driven 

obsolescence situations. These situations 

limit management options (when expanding 

jurisdictional options is likely one of the 

primary reasons for moving to COTS in the 

first place...) and could force jurisdictions to 

adopt more costly solutions when COTS 

components go end-of-life. 
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Another cost related consequence of using 

rapidly changing COTS products within an

election system is the likelihood, as 

mentioned elsewhere in this paper, that the

system will include more than one 

configuration of the COTS component or 

components used in the system. This 

situation requires a rigorous application of 

configuration management (CM) processes 

to document and manage system baselines. 

Documenting product and system changes 

and instituting strong CM processes ensures 

the ability to determine the impact of

product changes to all affected 

configurations of the election system. 

Without the traditional voting system 

vendor model, the election administrator 

will likely become the system integrator and 

therefore will need to assume these roles 

and responsibilities within the election 

office. Without adequate in-house expertise 

in CM management, the election official will 

need to hire additional staff or contract out 

to a third party for such expertise. 

8. Implementing COTS election systems 

must be part of a large-scale paradigm 

shift

A change in mindset for election officials is 

as important as any change in technology 

when using election systems depending 

solely or predominantly on COTS products. 

The move to the next generation of COTSbased voting and election systems

constitutes a significant paradigm shift not 

only for programmers, system developers

and integrators, but also constitutes a 

significant paradigm shift for the election 

officials charged with the operation, testing, 

and day-to-day maintenance of these 

systems as well. Election officials need to 

assess their ability and their staff’s ability to 

work in the often technologically volatile 

world of COTS. Finding staff with the right 

attitude and right skills set may be difficult 

and expensive to maintain.

The move towards COTS-based voting and 

election systems is not simply a 

technological change. It affects everyone 

interacting with the system in profound 

ways. Election jurisdictions will experience

changes in the activities they undertake, 

their structure, required training, IT policies, 

and the relationships between the election 

jurisdiction and their vendors. Election 

officials will need to leverage “lessons 

learned” by other government agencies and 

industry and imbed them in a practical 

manner into an overall management plan to 

effectively acquire and support COTS based 

election systems. 

Conclusion: COTS Benefits and Mitigating 

Risks

Election officials must continue to find ways 

to drive down the operational costs of 

elections, while maintaining inventories of 

technologies that meet the growing 

expectations of their constituencies. COTSbased solutions represent an opportunity to 

do this – but only if properly planned and 

managed. Election officials, voting system 

vendors, and testing authorities must 

recognize the risks and opportunities 

present in COTS and find ways to mitigate 

the risks while reaping the benefits.