U.S. ELECTION ASSISTANCE COMMISSION

633 3rd St. NW, Suite 200

Washington, DC 20001

EAC Decision on Request for Interpretation 2023-04 Unique Identifier

EAC Decision on Request for Interpretation

2023-04 9.1.5-F Unique Identifier

Sections of Standards or Guidelines:

9.1.5-F – Unique identifier

A paper-based voting system must be capable of adding a unique identifier after a voter casts

their ballot. 

Discussion

Although not all jurisdictions may use this feature, voting systems are required to have the 

capability to add a unique identifier to ballots. 

Date:

September 29, 2023

Question(s):

1. Would a central-count scanner capable of adding a unique identifier meet the 9.1.5-F 

requirement?

2. Are precinct-count scanners required to physically mark the paper ballot to meet this 

requirement?

3. Can this requirement be accomplished procedurally?

Discussion:

The concept of unique identifiers is not new to the latest iteration of the Voluntary Voting 

Standards Guidelines. In VVSG 1.0, volume 1, requirement 7.9.3.c states: “The electronic ballot 

image and paper records shall be linked by including a unique identifier within each record that 

can be used to identify each record uniquely and each record’s corresponding record.” This 

requirement was focused on the auditability of being able to connect and verify a cast voter 

record (CVR) with a ballot image. However, this unique identifier did not link to the physical 

paper ballot. VVSG 2.0 bridges this gap by affixing a unique identifier to the voter’s cast ballot

as well as the digital CVR record. Therefore, in a situation where physical paper ballots must be 

used as a reference, election officials will be able to use the unique identifier to conduct an 

audit, by linking a physical ballot with the image and CVR as necessary.

Additionally, in VVSG 1.0, volume 1, requirement 7.9.5.f states: “Unique identifiers shall not be 

displayed in a way that is easily memorable by the voter.” This requirement attempts to take 

into consideration voter privacy by creating complex identifiers or obscuring them in other 

characters. VVSG 2.0 does away with the need to obscure unique identifiers on ballots by 
 

U.S. ELECTION ASSISTANCE COMMISSION

633 3rd St. NW, Suite 200

Washington, DC 20001

EAC Decision on Request for Interpretation 2023-04 Unique Identifier

simply affixing them after they have already left the voter’s custody. By affixing unique 

identifiers after a ballot has been cast, no individual can use the identifier to link a voter with 

their ballot. 

This requirement must be met at the time when the cast vote record and a ballot image are 

created, which is at the time of tabulation. When a ballot is tabulated, whether it be on a 

precinct scanner or a central scanner, the unique identifier must be added and linked to the 

ballot, image, and CVR. Therefore, all unique tabulation devices must be capable of adding a

unique identifier.

This requirement cannot be met procedurally, as all paper based voting devices, that tabulate 

ballots, are required to have the capability to add a unique identifier. Addressing this 

requirement procedurally introduces multiple paths of risk. These risks include: a ballot not 

being included in the process, ballots being tabulated twice, introducing a procedure that may 

not be followed, or not being able to tie a CVR with the physical ballot. Instead, to best avoid 

these risks, human intervention of procedures should be removed from consideration when 

meeting this requirement.

Conclusion:

To meet requirement 9.1.5-F, all paper-based tabulation devices must have the capability to 

add unique identifiers. This includes both precinct and central scanners and cannot be 

accomplished procedurally. Additionally, these unique identifiers must maintain ballot secrecy.

No individual should be able to identify a voter’s ballot based on the added unique identifier. 

Effective Date:

As of the date this document is published.