VOLUNTARY VOTING SYSTEM

GUIDELINES

Voluntary Voting System Guidelines

Table of Contents

Volume I Voting System Performance Guidelines

Overview Voluntary Voting System Guidelines Overview

Section 1 Introduction

Section 2 Functional Requirements

Section 3 Usability and Accessibility Requirements

Section 4 Hardware Requirements

Section 5 Software Requirements

Section 6 Telecommunications Requirements

Section 7 Security Requirements

Section 8 Quality Assurance Requirements

Section 9 Configuration Management Requirements

Appendix A Glossary

Appendix B References

Appendix C Independent Verification Systems

Appendix D Technical Guidance for Color, Contrast, and Text Size

Volume II National Certification Testing Guidelines

Overview Voluntary Voting System Guidelines Overview

Section 1 Introduction

Section 2 Description of the Technical Data Package

Section 3 Functionality Testing

Section 4 Hardware Testing

Section 5 Software Testing

Section 6 System Integration Testing

Section 7 Quality Assurance Testing

Appendix A National Certification Test Plan

Appendix B National Certification Test Report

Appendix C National Certification Test Design Criteria
VOLUNTARY VOTING SYSTEM

GUIDELINES

Volume I

Voting System Performance Guidelines

Voluntary Voting System Guidelines Overview

Table of Contents

Voluntary Voting System Guidelines Overview 

Purpose and Scope of the Guidelines

Effective Date 

Summary of Changes

Volume I: Voting System Performance Guidelines Summary

Volume II: National Certification Testing Guidelines Summary

Guide to Section Locations

Voluntary Voting System Guidelines Overview

The United States Congress passed the Help America Vote Act of 2002 (HAVA) to

modernize the administration of federal elections, marking the first time in our nation’s

history that the federal government has funded an election reform effort. HAVA provides

federal funding to help the states meet the law’s uniform and non-discretionary

administrative requirements, which include the following new programs and procedures: 1)

provisional voting, 2) voting information, 3) statewide voter registration lists and

identification requirements for first-time registrants, 4) administrative complaint procedures,

and 5) updated and upgraded voting equipment.

HAVA also established the U.S. Election Assistance Commission (EAC) to administer the

federal funding and to provide guidance to the states in their efforts to comply with the

HAVA administrative requirements. Section 202 directs the EAC to adopt voluntary voting

system guidelines, and to provide for the testing, certification, decertification, and

recertification of voting system hardware and software. The purpose of the guidelines is to

provide a set of specifications and requirements against which voting systems can be tested

to determine if they provide all the basic functionality, accessibility, and security capabilities

required of voting systems.

This document, the Voluntary Voting System Guidelines (referred to herein as the Guidelines
and/or VVSG), is the third iteration of national level voting system standards that has been

developed. The Federal Election Commission published the Performance and Test Standards

for Punchcard, Marksense and Direct Recording Electronic Voting Systems in 1990. This

was followed by the Voting Systems Standards in 2002.

As required by HAVA, the EAC formed the Technical Guidelines Development Committee

(TGDC) to develop an initial set of recommendations for the Guidelines. This committee of

15 experts began their work in July 2004 and submitted their recommendations to the EAC in

the 9-month timeline prescribed by HAVA. The TGDC was provided with technical support

by the National Institute for Standards and Technology (NIST), which was given nearly $3

million dollars by the EAC to complete this work.

The EAC reviewed and revised the TGDC recommendations and, as required by HAVA,

published the proposed Guidelines for a 90 day public comment period. The document was

also provided to both the Board of Advisors and the Standards Board for their review and

comment. During the comment period the EAC conducted 3 public hearings on the

Guidelines in New York City, Pasadena and Denver. Over 6000 comments were received

from the public and the Boards. Each of these comments was reviewed and considered by the

EAC in consultation with NIST in the development of this final version.

Purpose and Scope of the Guidelines

The purpose of the Voluntary Voting System Guidelines is to provide a set of specifications

and requirements against which voting systems can be tested to determine if they provide all

the basic functionality, accessibility and security capabilities required to ensure the integrity

of voting systems. The VVSG specifies the functional requirements, performance

characteristics, documentation requirements, and test evaluation criteria for the national

certification of voting systems. The VVSG is composed of two volumes: Volume I, Voting

System Performance Guidelines and Volume II, National Certification Testing Guidelines.

Effective Date

The 2005 Voluntary Voting System Guidelines will take effect 24 months after their final

adoption in December 2005 by the EAC. At that time, all new systems submitted for national

certification will be tested for conformance with these guidelines. In addition, if a

modification to a system qualified or certified to a previous standard is submitted for national

certification after this date, every component of the modified system will be tested against

the 2005 VVSG. All previous versions of national standards will become obsolete at this time.

This effective date provision does not have any impact on the mandatory January 1, 2006,

deadline for states to comply with the HAVA Section 301 requirements.

Summary of Changes

Volume I of the Guidelines, entitled Voting System Performance Guidelines, includes new

requirements for usability, accessibility, voting system software distribution, generation of

software reference information, validation of software during voting system setup, and the

use of wireless communications. System functional requirements have been revised to

comply with HAVA Section 301 requirements. Environmental criteria have been updated.

This volume also includes requirements for a voter verifiable paper audit trail component for
direct-recording electronic voting systems for use by states that require this feature. In

addition, this volume includes an updated glossary and a conformance clause.

Volume II of the Guidelines, entitled National Certification Testing Guidelines, has been

revised to reflect the new EAC process for national certification of voting systems. This

process was initiated in 2005 and replaces the voting system qualification process conducted

by the National Association of State Election Directors (NASED) since 1994. In addition,

revisions have been made to the testing procedures to reflect new requirements for the

conduct of usability and accessibility testing. Volume II also includes an updated appendix

on procedures for testing system error rates. Terminology in both volumes has been revised

to reflect new terminology introduced by HAVA.

Volume I: Voting System Performance Guidelines Summary

Volume I, the Voting System Performance Guidelines, describes the requirements for the

electronic components of voting systems. It is intended for use by the broadest audience,

including voting system developers, manufacturers and suppliers; voting system testing labs;

state organizations that certify systems prior to procurement; state and local election officials

who procure and deploy voting systems; and public interest organizations that have an

interest in voting systems and voting system standards. It contains the following sections:

Section I describes the purpose and scope of the Voting System Performance

Guidelines.

Section 2 describes the functional capabilities required of voting systems. This section

has been revised to reflect HAVA Section 301 requirements.

Section 3 describes new standards that make voting systems more usable and accessible

for as many eligible citizens as possible, whatever their physical abilities, language

skills, or experience with technology. This section reflects the HAVA 301 (a)(3)

accessibility requirements.

Sections 4 through 6 describe specific performance standards for election system

hardware, software, telecommunications, and security. Environmental criteria have been

updated in Section 4.

Section 7 describes voting system security requirements and includes new requirements

for voting system software distribution, generation of software reference information,

validation of software during system setup, and the use of wireless. It also includes

requirements for voter verifiable paper audit trail components for direct-recording

electronic voting systems.

Sections 8 and 9 describe requirements for vendor quality assurance and configuration

management practices and the documentation about these practices required for the

EAC certification process.

Appendix A contains a glossary of terms.

Appendix B provides a list of related standards documents incorporated into the

Guidelines by reference, documents used in the preparation of the Guidelines, and

referenced legislation.

Appendix C presents an introductory discussion of independent verification systems as

a potential concept for future voting system security design.

Appendix D contains technical guidance on color, contrast and text size adjustment for

individuals with low vision or color blindness.
Volume II: National Certification Testing Guidelines Summary

Volume II, the National Certification Testing Guidelines, is a complementary document to

Volume I. Volume II provides an overview and specific detail of the national certification

testing process, which is performed by independent voting system test labs accredited by the

EAC. It is intended principally for use by vendors: test labs: and election officials who

certify, procure, and accept voting systems. This volume contains the following sections:

Section 1 describes the purpose of the National Certification Testing Guidelines.

Section 2 provides a description of the Technical Data Package that vendors are

required to submit with their system for certification testing.

Section 3 describes the basic functionality testing requirements.

Sections 4 through 6 define the requirements for hardware, software and system

integration testing. Section 6 has been revised to reflect new requirements for usability

and accessibility testing.

Section 7 describes the required examination of vendor quality assurance and

configuration management practices.

Appendix A provides the requirements for the National Certification Test Plan that is

prepared by the voting system test lab and provided to the EAC for review.

Appendix B describes the scope and content of the National Certification Test Report

which is prepared by the test lab and delivered to the EAC along with a

recommendation for certification.

Appendix C describes the guiding principles used to design the voting system

certification testing process. It also contains a revised section on testing system error

rates.

Volume I: Voting System Performance Guidelines

Guide to Section Locations

Section 1: Introduction

Section 2: Functional Requirements 

Section 3: Usability and Accessibility Requirements

Section 4: Hardware Requirements 

Section 5: Software Requirements

Section 6: Telecommunications Requirements

Section 7: Security Requirements

Section 8: Quality Assurance Requirements

Section 9: Configuration Management Requirements

Appendix A: Glossary

Appendix B: References 

Appendix C: Independent Verification Systems

Appendix D: Technical Guidance for Color, Contrast, and Text Size 
1 Introduction

Table of Contents

1 Introduction

1.1 Purpose and Scope of the Voluntary Voting System Guidelines

1.2 Use of the Voluntary Voting System Guidelines 

1.3 Evolution of Voting System Standards

1.3.1 Federal Election Commission

1.3.2 Election Assistance Commisson

1.4 Overview of Voting System Testing

1.4.1 The National Certification Program for Voting Systems 

1.4.2 State Certification Testing

1.4.3 Acceptance Testing 

1.5 Definitions, References, and Types of Voting Systems 

1.5.1 Definitions and References

1.5.2 Types of Voting Systems

1.5.2.1 Paper-Based Voting System 

1.5.2.2 Direct-Recording Electronic Voting System 

1.5.2.3 Public Network Direct-Recording Electronic Voting System

1.5.2.4 Precinct Count Voting System

1.5.2.5 Central Count Voting System

1.6 Conformance Clause

1.6.1 Scope and Applicability 

1.6.2 Conformance Framework

1.6.2.1 Applicable Entities

1.6.2.2 Relationships Among Entities 

1.6.3 Structure of Requirements

1.6.3.1 Conformance Language

1.6.3.2 Categorizing Requirements 

1.6.3.3 Extensions

1.6.4 Implementation Statement

1.7 Effective Date

1 Introduction

1.1 Purpose and Scope of the Voluntary Voting System Guidelines

The purpose of the Voluntary Voting System Guidelines (VVSG or the Guidelines) is to

provide a set of specifications and requirements against which voting systems can be tested

to determine if they provide all the basic functionality, accessibility, and security capabilities

required of voting systems. The VVSG specifies the functional requirements, performance

characteristics, documentation requirements, and test evaluation criteria for the national

certification of voting systems. To the extent possible, these requirements and specifications

are described so they can be assessed by a series of defined, objective tests. The VVSG is
composed of two volumes: Volume 1, Voting System Performance Guidelines; and Volume

2, National Certification Testing Guidelines.

The VVSG is one of several inter-related EAC promulgated guidelines and programs

concerned with maintaining the reliability and security of voting systems and the integrity of

the overall election process. The performance of national certification testing of voting

systems is restricted to testing labs that have been formally accredited to be technically

competent to evaluate systems for conformance to the Voting System Performance

Guidelines. The National Association of State Election Directors (NASED) initiated the

independent testing authority accreditation program for test labs in 1994, applying the

standards and procedures in NASED Program Handbook 9201 (Revision A). With the

passage of the Help America Vote Act (HAVA), this responsibility transitioned to the

Election Assistance Commission (EAC) with support from the National Voluntary

Laboratory Accreditation Program (NVLAP). This program is operated by the National

Institute of Standards and Technology (NIST), applying the standards and procedures in

NIST Handbook 150-22, NVLAP Voting System Testing.

The VVSG and the test lab accreditation process are essential components of the EAC

National Certification Program for voting systems. This program applies the standards and

procedures documented in the EAC voting system certification manual. HAVA Section 231

charges EAC with providing for the certification, decertification and recertification of voting

systems. Under this program national certification is just the first step of the life cycle

process of maintaining the reliability and security of the voting systems used in the nation’s

elections. To carry out this mandate, the EAC program will include monitoring of voting

system performance through incident reporting by election officials and others. The

certification program will maintain information on the quality assurance practices associated

with the development and manufacturing of voting systems. When a system has successfully

completed the certification process, the EAC program requires a copy of the certified voting

system software to be provided to the National Software Reference Library operated by

NIST. This will enable election officials to validate that the software received by their

jurisdictions is the same as the certified version.

The VVSG notes the need for appropriate procedures to complement and supplement the

technical requirements for voting system performance. It is well known that deficiencies in

election management and administration procedures can have just as much impact on the

enfranchisement of voters and the outcome of elections as the functioning of the voting

machines. The overall integrity of the election process depends on both of these elements

working together. EAC and NASED have instituted a multi-year effort to develop a

comprehensive set of election management guidelines that will complement the technical

system guidelines, as well as cover other elements of the election process.

Except as noted below, Volume I of the Guidelines applies to all system hardware, software,

telecommunications, and documentation intended for use to:

• Prepare the voting system for use in an election

• Produce the appropriate ballot formats

• Test that the voting system and ballot materials have been properly prepared and are

ready for use

• Record and count votes

• Consolidate and report election results

• Display results on-site or remotely
• Produce and maintain comprehensive audit trail data

Some voting systems use one or more commercial off-the-shelf (COTS) devices (such as

card readers, printers, and personal computers) or software products (such as operating

systems, programming language compilers, and database management systems). These

devices and products are exempt from certain portions of system certification testing, as long

as they are not modified for use in the voting system.

Volume 2 describes the testing process to provide a documented independent verification by

an accredited testing laboratory that a voting system has been demonstrated to conform to the

Volume 1 requirements and therefore should receive national certification. It provides the

specific detail about the testing process and documentation requirements required to support

the national certification program.

1.2 Use of the Voluntary Voting System Guidelines

The Guidelines are intended for use by multiple audiences to support their respective roles in

the development, testing, and acquisition of voting systems:

• The accredited testing laboratories who use this information to develop test plans and

procedures for the analysis and testing of systems in support of the national

certification testing process

• State and local election officials who are evaluating voting systems for potential use

in their jurisdictions

• Voting system designers and manufacturers who need to ensure that their products

fulfill all these requirements so they can be certified

1.3 Evolution of Voting System Standards

1.3.1 Federal Election Commission

The first voting system standards were issued in January 1990, by the Federal Election

Commission (FEC). This document included performance standards and testing procedures

for Punchcard, Marksense, and Direct-Recording Electronic (DRE) voting systems. These

standards did not cover paper ballot and mechanical lever systems because paper ballots are

sufficiently self-explanatory not to require technical standards and mechanical lever systems

are no longer manufactured or sold in the United States. The FEC also did not incorporate

requirements for mainframe computer hardware because it was reasonable to assume that

sufficient engineering and performance criteria already governed the operation of mainframe

computers. However, vote tally software installed on mainframes was covered.

A national testing effort was initiated by NASED in 1994. As the system qualification

process matured and qualified systems were used in the field, the NASED Voting Systems

Board, in consultation with the testing labs, identified certain testing issues that needed to be

resolved. Moreover, rapid advancements in information and personal computer technologies

introduced new voting system development and implementation scenarios not contemplated

by the 1990 Standards.

In 1997, NASED briefed the FEC on the importance of keeping the Standards up to date.
Following a requirements analysis completed in 1999, the FEC initiated an effort to revise

the 1990 Standards to reflect the evolving needs of the elections community. This resulted in

the 2002 Voting Systems Standards.

Voters and election officials who use voting systems represent a broad spectrum of the

population, and include individuals with disabilities who may have difficulty using

traditional voting systems. In developing accessibility provisions for the 2002 Voting

System Standards, the FEC requested assistance from the Access Board, the federal agency

in the forefront of promulgating accessibility provisions. The Access Board submitted

technical standards to meet the diverse needs of voters with a broad range of disabilities. The

FEC adopted the entirety of the Access Board’s recommendations and incorporated them into

the 2002 Voting Systems Standards.

1.3.2 Election Assistance Commission

In 2002, Congress passed the Help America Vote Act, which established the U.S. Election

Assistance Commission (EAC). EAC was mandated to develop and adopt new voluntary

voting system guidelines and to provide for the testing, certification, and decertification of

voting systems. HAVA also established the Technical Guidelines Development Committee

(TGDC) with the duty of assisting the EAC in the development of the new guidelines. The

Director of NIST chairs the TGDC, and NIST was tasked to provide technical support to

their work. The TGDC delivered their initial set of recommendations to the EAC in May,

2005.

The TGDC built on the foundation of the 2002 Voting Systems Standards and the

accessibility provisions of HAVA to expand requirements for voting system usability and

accessibility. HAVA mandates that voting systems shall be accessible for individuals with

disabilities in a manner that provides the same opportunity for access and participation

(including privacy and independence) as for other voters. To facilitate the ability of

jurisdictions to meet these requirements, HAVA allows for the use of at least one directrecording

electronic or other voting system equipped for individuals with disabilities at each

polling place. Implementing this provision, however, will not entirely eliminate the necessity

of accommodating the needs of some disabled voters by human assistance, given the

limitations of current technology.

The 2005 VVSG is the culmination of sixteen months of effort by the TGDC, NIST and the

EAC. There is still much to be done to further develop the technical guidelines for voting

system performance, accessibility and usability features, and security. Further work is also

needed for the specification of comprehensive standard test suites for certification testing, to

include testing for usability and accessibility features and expanded security testing.

1.4 Overview of Voting System Testing

1.4.1 The National Certification Program for Voting Systems

The purpose of the national certification program is to validate and document, through an

independent testing process, that voting systems meet the requirements set forth in VVSG
Volume 1 - Voting System Performance Guidelines, and perform according to the vendor’s

specifications for the system. Volume 1 specifies the minimum functional requirements,

performance characteristics, documentation requirements, and test evaluation criteria that

voting systems must meet in order to receive national certification. At the time of VVSG

2005 publication, 39 states either require national certification or utilize the national

standards when certifying voting systems.

National certification testing can only be performed by testing labs that have been accredited

for demonstrated technical competence to test voting systems using these Guidelines.

Volume 2 of the VVSG - National Certification Testing Guidelines - provides guidance on

the testing process and describes the associated documentation requirements. These tests

encompass the examination of software; the inspection and evaluation of system

documentation; tests of hardware under conditions simulating the intended storage,

operation, transportation, and maintenance environments; operational tests to validate system

performance and function under normal and abnormal conditions; and examination of the

vendor’s system development, testing, quality assurance, and configuration management

practices. Certification tests address individual system components or elements, as well as

the integrated system as a whole.

Since 1994, testing of voting systems has been performed by Independent Test Authorities

(ITAs) certified by NASED. Upon the successful completion of testing, the ITA issued a

Qualification Test Report to the vendor and NASED. The Technical Committee of the

NASED Voting Systems Board would review the test report and, if satisfactory, issue a

Qualification Number. The Qualification Number remains valid for as long as the voting

system remains unchanged.

HAVA mandated that the certification testing process be transferred from NASED to EAC.

National certification testing complements and evaluates the vendor's developmental testing

and beta testing. The test lab is expected to evaluate the completeness of the vendor's

developmental test program, including the sufficiency of vendor tests conducted to

demonstrate compliance with the Guidelines as well as the system’s performance

specifications. The test lab undertakes sample testing of the vendor's test modules and also

designs independent system-level tests to supplement and check those designed by the

vendor. Although some of the certification tests are based on those prescribed in the Military

Standards, in most cases the test conditions are less stringent, reflecting commercial, rather

than military, practice.

Upon review of test reports and a determination that satisfactory results were achieved that

address the full scope of testing, EAC will issue a certification number that indicates the

system has successfully completed testing by an accredited test lab for compliance with the

Guidelines. The certification number applies to the system as a whole and does not apply to

individual system components or untested configurations.

After a system has completed initial certification testing, further examination of the system is

required if modifications are made to hardware, software, or telecommunications, including

the installation of software on different hardware. Vendors request review of modifications
by the test lab based on the nature and scope of changes made. The test lab will assess

whether the modified system should be resubmitted for certification testing and the extent of

testing to be conducted, and then it will provide an appropriate recommendation to the EAC

and the vendor.

Generally, a voting system remains certified under the standards against which it was tested

as long as no modifications requiring recertification have been made to the system. However,

if a new threat to a particular voting system is discovered, it is the prerogative of EAC to

determine which certified voting systems are vulnerable, whether those systems need to be

retested, and the specific tests to be conducted. In addition, when new requirements

supersede the requirements under which the system was certified, it is the prerogative of

EAC to determine when systems that were certified under the earlier requirements will need

to be re-tested to meet current guidelines.

1.4.2 State Certification Testing

State certification tests are performed by individual states, with or without the assistance of

outside consultants, to:

• Confirm that the voting system presented is the same as the one certified under the

Guidelines

• Test for the proper implementation of state-specific requirements

• Establish a baseline for future evaluations or tests of the system, such as acceptance

testing or state review after modifications have been made

• Define acceptance tests

State certification test scripts are not included in the Guidelines, as they must be defined by

the state, with its laws, election practices, and needs in mind. However, it is recommended

that they not duplicate the national certification tests, but instead focus on functional tests

and qualitative assessment to ensure that the system operates in a manner that is acceptable

under state law. If a voting system is modified after state certification is completed, it is

recommended that states reevaluate the system to determine if further certification testing is

warranted.

Certification tests performed by individual states typically rely on information contained in

documentation provided by the vendor for system design, installation, operations, required

facilities and supplies, personnel support and other aspects of the voting system. States and

jurisdictions may define information and documentation requirements additional to those

defined in the Guidelines. By design, the Guidelines do not address these additional

requirements. However, national certification testing will address all the capabilities of a

voting system stated by the vendor in the system documentation submitted with the testing

application to the EAC, including additional capabilities that are not required by the states.

1.4.3 Acceptance Testing

Acceptance tests are performed at the state or local jurisdiction level upon system delivery by

the vendor to:
• Confirm that the system delivered is the specific system certified by EAC and, when

applicable, certified by the state

• Evaluate the degree to which delivered units conform to both the system

characteristics specified in the procurement documentation, and those demonstrated

in the national and state certification tests

• Establish a baseline for any future required audits of the system

Some of the operational tests conducted during certification may be repeated during

acceptance testing.

1.5 Definitions, References, and Types of Voting Systems

1.5.1 Definitions and References

The Guidelines contain terms describing function, design, documentation, and testing

attributes of voting system hardware, software and telecommunications. Unless otherwise

specified, the intended sense of technical terms is that which is commonly used by the

information technology industry. In some cases terminology is specific to elections or voting

systems. A glossary of terms is contained in Appendix A. Non-technical terms not listed in

Appendix A shall be interpreted according to their standard dictionary definitions.

There are a number of technical standards that are incorporated in the Guidelines by

reference. These are referred to by title in the body of the document. The full citations for

these publications are provided in Appendix B. In addition, this appendix includes other

references that may be useful for understanding and interpretation.

1.5.2 Types of Voting Systems

HAVA Section 301 defines a voting system as the total combination of mechanical,

electromechanical, or electronic equipment (including the software, firmware, and

documentation required to program, control, and support the equipment), that is used to

define ballots; to cast and count votes; to report or display election results; and to maintain

and produce any audit trail information. In addition, a voting system includes the practices

and associated documentation used to identify system components and versions of such

components; to test the system during its development and maintenance; to maintain records

of system errors and defects; to determine specific system changes made after initial

certification; and to make available any materials to the voter (such as notices, instructions,

forms, or paper ballots).

Traditionally, a voting system has been defined by the mechanism the system uses to cast

votes and further categorized by the location where the system tabulates ballots. In addition

to defining a common set of requirements that apply to all voting systems, the VVSG states

requirements specific to a particular type of voting system, where appropriate. However, the

Guidelines recognize that as the industry develops new solutions and the technology

continues to evolve, the distinctions between voting system types may become blurred. The

fact that the VVSG refers to specific system types is not intended to stifle innovations that
may be based on a more fluid understanding of system types. However, appropriate

procedures must be in place to ensure new developments provide the necessary integrity and

can be properly evaluated in the certification process.

Consequently, vendors that submit a system that integrates components from more than one

traditional system type or a system that includes components or technology not addressed in

the Guidelines shall submit the results of all beta tests of the new system when applying for

national certification. Vendors shall also submit a proposed test plan to the EAC for use in

national certification testing. The Guidelines permit vendors to produce or utilize

interoperable components of a voting system that are tested within the full voting system

configuration.

The listing below summarizes the functional requirements that HAVA Section 301 mandates

to assist voters. While these requirements may be implemented in a different manner for

different types of voting systems, all types of voting systems must provide these capabilities:

• permit the voter to verify (in a private and independent manner) the vote selected by

the voter on the ballot before the ballot is cast and counted

• provide the voter with the opportunity (in a private and independent manner) to

change the ballot or correct any error before the ballot is cast and counted

• notify the voter if he or she has selected more than one candidate for a single office,

inform the voter of the effect of casting multiple votes for a single office, and provide

the voter an opportunity to correct the ballot before it is cast and counted

• be accessible for individuals with disabilities in a manner that provides the same

opportunity for access and participation (including privacy and independence) as for

other voters

• provide alternative language accessibility pursuant to Section 203 of the Voting

Rights Act

1.5.2.1 Paper-Based Voting System

A paper-based voting system records votes, counts votes, and produces a tabulation of the

vote count from votes cast on paper cards or sheets. A marksense (also known as optical

scan) voting system allows a voter to record votes by making marks directly on the ballot,

usually in voting response locations. Additionally, a paper-based system may allow for the

voter’s selections to be indicated by marks made on a paper ballot by an electronic input

device, as long as such an input device does not independently record, store, or tabulate the

voter selections.

1.5.2.2 Direct-Recording Electronic Voting System

A direct-recording electronic (DRE) voting system records votes by means of a ballot display

provided with mechanical or electro-optical components that can be activated by the voter;

that processes data by means of a computer program; and that records voting data and ballot

images in memory components. It produces a tabulation of the voting data stored in a

removable memory component and as printed copy. The system may also provide a means

for transmitting individual ballots or vote totals to a central location for consolidating and

reporting results from precincts at the central location.
1.5.2.3 Public Network Direct-Recording Electronic Voting

System

A public network DRE voting system is an election system that uses electronic ballots and

transmits vote data from the polling place to another location over a public network. Vote

data may be transmitted as individual ballots as they are cast, periodically as batches of

ballots throughout the election day, or as one batch at the close of voting. For purposes of the

Guidelines, public network DRE voting systems are considered a form of DRE voting system

and are subject to the standards applicable to DRE voting systems. However, because

transmitting vote data over public networks relies on equipment beyond the control of the 

election authority, the system is subject to additional threats to system integrity and

availability. Therefore, additional requirements are applied to provide appropriate security

for data transmission.

The use of public networks for transmitting vote data must provide the same level of integrity

as other forms of voting systems, and must be accomplished in a manner that precludes three

risks to the election process: automated casting of fraudulent votes, automated manipulation

of vote counts, and disruption of the voting process such that the system is unavailable to

voters during the time period authorized for system use.

1.5.2.4 Precinct Count Voting System

A precinct count voting system is a voting system that tabulates ballots at the polling place.

These systems typically tabulate ballots as they are cast and print the results after the close of

polling. For DREs and some paper-based systems these systems provide electronic storage of

the vote count and may transmit results to a central location over public telecommunication

networks.

1.5.2.5 Central Count Voting System

A central count voting system is a voting system that tabulates ballots from multiple

precincts at a central location. Voted ballots are typically placed into secure storage at the

polling place. Stored ballots are transported or transmitted to a central counting location. The

system produces a printed report of the vote count, and may produce a report stored on

electronic media.

1.6 Conformance Clause

1.6.1 Scope and Applicability

The Voluntary Voting System Guidelines define requirements for conformance of voting

systems that voting system vendors shall meet. The Guidelines also provide the framework,

procedures, and requirements that testing labs responsible for the certification testing of

voting systems shall follow. The requirements and procedures in the Guidelines may also be

used by states to certify voting systems. To ensure that correct voting system software has

been distributed without modification, the Guidelines include requirements for certified

voting system software to be deposited in a national software repository. This provides an
independent means for election officials to verify the software they purchase.

The Guidelines define the minimum requirements for voting systems and the process of

testing voting systems. The guidelines are intended for use by:

• Designers and manufacturers of voting systems

• Test labs performing the analysis and testing of voting systems in support of the EAC

national certification process

• Software repositories designated by EAC or by a state

• Election officials, including ballot designers and officials responsible for the

installation, operation, and maintenance of voting machines

• Test labs and consultants performing the state certification of voting systems

Minimum requirements specified in these guidelines include:

• Functional capabilities

• Performance characteristics, including security

• Documentation

• Test evaluation criteria

1.6.2 Conformance Framework

This section provides the framework in which conformance is defined. It identifies the

entities to which these guidelines apply, the relationships among the various entities, the

structure of the requirements, and the terminology used to indicate conformance.

1.6.2.1 Applicable Entities

The requirements, prohibitions, options, and guidance specified in these guidelines apply to

voting systems, voting system vendors, test labs, and software repositories. In general,

requirements for voting systems in these guidelines apply to all types of voting systems,

unless prefaced with explanatory narrative that applicability is limited to a specific type of

system. Other terms in these guidelines shall be construed as synonymous with “voting

systems.” They are: “systems”, “the system”, “the voting system”, and “each voting

system.”

The term “voting system vendor” imposes documentation or testing requirements for the

manufacturer or vendor. Other terms in these guidelines shall be construed as synonymous

with “voting system vendor.” They are: “vendors”, “the vendor”, “manufacturer or vendor”,

“voting system designers”, and "implementer".

The terms used to designate requirements and procedural guidelines for national certification

testing laboratories are indicated by referring to “testing authorities”, “test labs”, and

“accredited test labs”. The term “repository” will be used to designate requirements levied on

the National Software Reference Library repository maintained at NIST or any other

designated repository.

1.6.2.2 Relationships Among Entities

It is the voting system vendor that needs to implement these requirements and provide the

necessary documentation for the system. In order to claim conformance to the Guidelines,

the voting system vendor shall satisfy the specified requirements, including implementation

of functionality, prescribed software coding and assurance practices, and preparation of the

Technical Data Package. The voting system vendor shall successfully complete the
prescribed test campaign with an EAC accredited test lab.

The accredited test lab shall satisfy the requirements for conducting certification testing. The

test lab may use an operational environment emulating that used by election officials as part

of their testing to ensure that the voting system can be configured and operated in a secure

and reliable manner according to the vendor’s documentation and as specified by the

Guidelines. The test lab shall coordinate and deliver the requisite documentation and test

report to the EAC for review. Upon issuance of a certification number by the EAC, the test

lab shall deposit a copy of the certified voting system software with the National Software

Reference Library.

The EAC shall review the test results and associated documentation and make a

determination that all requirements have been appropriately tested and the test results are

acceptable. The EAC will issue a national certification number that indicates conformance of

the specified system with these Guidelines.

The National Software Reference Library (NSRL) shall create a digital signature of the

voting system software provided by the test lab. This information will be posted to a website

so election officials can compare the digital signature of the software provided to them by the

voting system vendor with this certified reference. The NSRL shall maintain this reference

information until notified by the EAC that it can be archived.

1.6.3 Structure of Requirements

Each voting system requirement in Volume I is identified according to a hierarchical scheme

in which higher-level requirements (such as “provide accessibility for visually impaired

voters”) are supported by lower-level requirements (e.g., “provide an audio-tactile

interface”). Thus, requirements are nested. When the nesting hierarchy has reached four

levels (i.e., 1.1.1.1), further nested requirements are designated with lowercase letters, then

roman numerals. Therefore, all requirements are traceable by a distinct reference.

Some requirements are directly testable and some are not. The latter tend to be higher-level

and are included because (1) they are testable indirectly insofar as their lower-level

requirements are testable, and (2) they often provide the structure and rationale for the lowerlevel

requirements. Satisfying the lower-level requirements will result in satisfying the

higher-level requirement.

1.6.3.1 Conformance Language

The following keywords are used to convey conformance requirements:

• Shall – indicates a mandatory requirement in order to conform. Synonymous with “is

required to.”

• Is prohibited –indicates a mandatory requirement that indicates something that is not

permitted (allowed) in order to conform. Synonymous with “shall not.”

• Should, is encouraged - indicates an optional recommended action, one that is

particularly suitable, without mentioning or excluding others. Synonymous with “is

permitted and recommended.”

• May - indicates an optional, permissible action. Synonymous with “is permitted.”

Informative parts of this document include examples, extended explanations, and other
matter that contain information necessary for proper understanding of the Guidelines and

conformance to it.

1.6.3.2 Categorizing Requirements

The Guidelines set forth a common set of requirements for national certification that apply to

all types of electronic voting systems. They also provide requirements that are applicable for

particular circumstances, such as alternative language capability or disability accessibility.

The requirements implementing the HAVA Section 301(a) mandates, except for disability

accessibility, must be met by all voting systems. The alternative language capability

mandated by Section 301(a)(4) must be met by all systems intended for use in jurisdictions

subject to Section 203 of the Voting Rights Act. The Section 301(a)(3) disability accessibility

requirements must be met by all systems intended to fulfill the one per polling place

disability equipped voting system provision of Section 301(a)(3)(B).

In addition, the Guidelines categorize some requirements into related groups of functionality

to address equipment type, ballot tabulation location, and voting system component (e.g.,

election management system, voting machine). Hence, all of the requirements contained in

the Guidelines do not apply to all elements of all voting systems. For example, requirements

categorized as applying to DRE systems are not applicable to paper-based voting. The

requirements implementing disability accessibility are not required of all voting systems,

only by those systems the vendor designates as accessible voting systems.

Among the categories defined in the VVSG are two types of voting systems with respect to

mechanisms to cast votes – paper-based voting systems and DRE voting systems.

Additionally, voting systems are further categorized by the locations where ballots are

tabulated – precinct count voting systems, which tabulate ballots at the polling place, and

central count voting systems, which tabulate ballots from multiple precincts at a central

location. The Guidelines define specific requirements for systems that fall within these four

categories as well as various combinations of these categories.

1.6.3.3 Extensions

Extensions are additional functions, features, and/or capabilities included in a voting system

that are not required by the Guidelines. To accommodate the needs of states that may impose

additional requirements and to accommodate changes in technology, these guidelines allow

extensions. For example, the requirements for a voter verifiable paper audit trail feature will

only be applied to those systems designated by the vendor as providing this feature. The use

of extensions shall not contradict nor cause the nonconformance of functionality required by

the Guidelines.

1.6.4 Implementation Statement

The voting system implementation statement describes the voting system and documents the

VVSG Volume 1 requirements that have been implemented by the voting system. It can also

identify optional features and capabilities supported by the voting system, as well as any

extensions (i.e., additional functionality beyond what is required in the guidelines). The

implementation statement must include a checklist identifying all the requirements for which

a claim of conformance is made.
The implementation statement must be submitted with the vendor’s application to the EAC

for national certification testing. It must provide a concise summary and narrative description

of the voting system’s capabilities. It shall include identifying information about the voting

system, including the hardware and software components, version number and date.

1.7 Effective Date

The Voluntary Voting System Guidelines (VVSG) shall become effective for national

certification testing 24 months after their final adoption in December, 2005 by EAC. At that

time, all new systems submitted for national certification shall be tested for conformance

with these Guidelines. In addition, if a modification to a system certified or qualified to a

previous standard is submitted for national certification after this date, every component of

the modified system shall be tested using these Guidelines. All previous versions of national

voting system standards will become obsolete upon this effective date.

These Guidelines are voluntary in that each of the states can decide whether to require the

voting systems used in their state to have a national certification. States may decide to adopt

these Guidelines in whole or in part at any time, irrespective of the effective date. In addition,

states may specify additional requirements that voting systems in their jurisdiction must

meet. The national certification program does not in any way pre-empt the ability of the

states to have their own system certification process.

This VVSG effective date provision has no effect on the mandatory voting system

requirements prescribed in HAVA Section 301(a), which states must comply with on or

before January 1, 2006. The EAC issued Advisory 2005-004 to assist states in determining if

a voting system is compliant with Section 301(a). This advisory is available on the EAC

website at www.eac.gov.

2 Functional Requirements

Table of Contents

2 Functional Requirements 

2.1 Overall System Capabilities 

2.1.1 Security

2.1.2 Accuracy

2.1.3 Error Recovery 

2.1.4 Integrity 

2.1.5 System Audit 

2.1.5.1 Operational Requirements 

2.1.5.2 Use of Shared Computing Platforms 

2.1.6 Election Management System 

2.1.7 Vote Tabulating Program 

2.1.7.1 Functions

2.1.7.2 Voting Variations

2.1.8 Ballot Counter

2.1.9 Telecommunications
2.1.10 Data Retention 

2.2 Pre-voting Capabilities 

2.2.1 Ballot Preparation

2.2.1.1 General Capabilities

2.2.1.2 Ballot Formatting

2.2.1.3 Ballot Production 

2.2.2 Election Programming

2.2.3 Ballot and Program Installation and Control

2.2.4 Readiness Testing

2.2.5 Verification at the Polling Place

2.2.6 Verification at the Central Location 

2.3 Voting Capabilities

2.3.1 Opening the Polls 

2.3.1.1 Precinct Count Systems 

2.3.1.2 Paper-based System Requirements

2.3.1.3 DRE System Requirements 

2.3.2 Activating the Ballot (DRE Systems)

2.3.3 Casting a Ballot 

2.3.3.1 Common Requirements 

2.3.3.2 Paper-based System Requirements

2.3.3.3 DRE System Requirements 

2.4 Post-Voting Capabilities 

2.4.1 Closing the Polls

2.4.2 Consolidating Vote Data 

2.4.3 Producing Reports 

2.4.4 Broadcasting Results 

2.5 Maintenance, Transportation, and Storage

2 Functional Requirements

This section contains requirements detailing the functional capabilities required of a voting

system. This section sets out precisely what a voting system is required to do. In addition, it

sets forth the minimum actions a voting system must be able to perform to be eligible for

certification.

For organizational purposes, functional capabilities are categorized as follows by the phase

of election activity in which they are required:

2.1 Overall System Capabilities: These functional capabilities apply throughout the

election process. They include security, accuracy, integrity, system auditability,

election management system, vote tabulation, ballot counters, telecommunications,

and data retention.

2.2 Pre-voting Capabilities: These functional capabilities are used to prepare the

voting system for voting. They include ballot preparation, the preparation of

election-specific software (including firmware), the production of ballots, the

installation of ballots and ballot counting software (including firmware), and
system and equipment tests.

2.3 Voting System Capabilities: These functional capabilities include all operations

conducted at the polling place by voters and officials including the generation of

status messages.

2.4 Post-voting Capabilities: These functional capabilities apply after all votes have

been cast. They include closing the polling place; obtaining reports by voting

machine, polling place, and precinct; obtaining consolidated reports; and obtaining

reports of audit trails.

2.5 Maintenance, Transportation and Storage Capabilities: These capabilities are

necessary to maintain, transport, and store voting system equipment.

In recognition of the diversity of voting systems, the Guidelines apply specific requirements

to specific technologies. Some of the guidelines apply only if the system incorporates certain

optional functions (for example, voting systems employing telecommunications to transmit

voting data). For each functional capability, common requirements are specified. Where

necessary, these are followed by requirements applicable to specific technologies (i.e., 

paperbasedor DRE) or intended use (i.e., central or precinct count).

2.1 Overall System Capabilities

This section defines required functional capabilities that are system-wide in nature and not

unique to pre-voting, voting, and post-voting operations. All voting systems shall provide

the following functional capabilities, further outlined in this section:

2.1.1 Security

2.1.2 Accuracy

2.1.3 Error Recovery

2.1.4 Integrity

2.1.5 System Audit

2.1.6 Election Management System

2.1.7 Vote Tabulating Program

2.1.8 Ballot Counter

2.1.9 Telecommunications

2.1.10 Data Retention

Voting systems may also include telecommunications components. Technical standards for

these capabilities are described in Sections 3 through 6 of the Voluntary Voting System

Guidelines.

2.1.1 Security

System security is achieved through a combination of technical capabilities and sound

administrative practices. To ensure security, all systems shall:

a. Provide security access controls that limit or detect access to critical system

components to guard against loss of system integrity, availability, confidentiality, and

accountability
b. Provide system functions that are executable only in the intended manner and order,

and only under the intended conditions

c. Use the system's control logic to prevent a system function from executing if any

preconditions to the function have not been met

d. Provide safeguards in response to system failure to protect against tampering during

system repair or interventions in system operations

e. Provide security provisions that are compatible with the procedures and administrative

tasks involved in equipment preparation, testing, and operation

f. Incorporate a means of implementing a capability if access to a system function is to be

restricted or controlled

g. Provide documentation of mandatory administrative procedures for effective system

security

2.1.2 Accuracy

Memory hardware, such as semiconductor devices and magnetic storage media, must be

accurate. The design of equipment in all voting systems shall provide for the highest possible

levels of protection against mechanical, thermal, and electromagnetic stresses that impact

system accuracy. Section 4 provides additional information on susceptibility requirements.

To ensure vote accuracy, all systems shall:

a. Record the election contests, candidates, and issues exactly as defined by election

officials

b. Record the appropriate options for casting and recording votes

c. Record each vote precisely as indicated by the voter and produce an accurate report of

all votes cast;

d. Include control logic and data processing methods incorporating parity and checksums

(Or equivalent error detection and correction methods) to demonstrate that the

System has been designed for accuracy

e. Provide software that monitors the overall quality of data read-write and transfer

Quality status, checking the number and types of errors that occur in any of the

Relevant operations on data and how they were corrected

In addition, DRE systems shall:

f. As an additional means of ensuring accuracy in DRE systems, voting devices shall

record and retain redundant copies of the original ballot image. A ballot image is an

electronic record of all votes cast by the voter, including undervotes.

2.1.3 Error Recovery

To recover from a non-catastrophic failure of a device, or from any error or malfunction that

is within the operator's ability to correct, the system shall provide the following capabilities:

a. Restoration of the device to the operating condition existing immediately prior to the

error or failure, without loss or corruption of voting data previously stored in the

device

b. Resumption of normal operation following the correction of a failure in a memory

component, or in a data processing component, including the central processing unit

c. Recovery from any other external condition that causes equipment to become
inoperable, provided that catastrophic electrical or mechanical damage due to external

phenomena has not occurred

2.1.4 Integrity

Integrity measures ensure the physical stability and function of the vote recording and

counting processes.

To ensure system integrity, all systems shall:

a. Protect against a single point of failure that would prevent further voting at the

polling place

b. Protect against the interruption of electrical power

c. Protect against generated or induced electromagnetic radiation

d. Protect against ambient temperature and humidity fluctuations

e. Protect against the failure of any data input or storage device

f. Protect against any attempt at improper data entry or retrieval

g. Record and report the date and time of normal and abnormal events

h. Maintain a permanent record of all original audit data that cannot be modified or

overridden but may be augmented by designated authorized officials in order to adjust

for errors or omissions (e.g., during the canvassing process)

i. Detect and record every event, including the occurrence of an error condition that the

system cannot overcome, and time-dependent or programmed events that occur

without the intervention of the voter or a polling place operator

j. Include built-in measurement, self-test, and diagnostic software and hardware for

detecting and reporting the system's status and degree of operability

In addition to the common requirements, DRE systems shall:

k. Maintain a record of each ballot cast using a process and storage location that differs

from the main vote detection, interpretation, processing, and reporting path

l. Provide a capability to retrieve ballot images in a form readable by humans

2.1.5 System Audit

This subsection describes the context and purpose of voting system audits and sets forth

specific functional requirements. Election audit trails provide the supporting documentation

for verifying the accuracy of reported election results. They present a concrete, indestructible

archival record of all system activity related to the vote tally, and are essential for public

confidence in the accuracy of the tally, for recounts, and for evidence in the event of criminal

or civil litigation.

These requirements are based on the premise that system-generated creation and maintenance

of audit records reduces the chance of error associated with manually generated audit

records. Because most audit capability is automatic, the system operator has less information

to track and record, and is less likely to make mistakes or omissions. The subsections that

follow present operational requirements critical to acceptable performance and reconstruction

of an election. Requirements for the content of audit records are described in Section 5.

The requirements for all system types, both precinct and central count, are described in

generic language. Because the actual implementation of specific characteristics may vary

from system to system, it is the responsibility of the vendor to describe each system's
characteristics in sufficient detail so that test labs and system users can evaluate the adequacy

of the system's audit trail. This description shall be incorporated in the System Operating

Manual, which is part of the Technical Data Package.

Documentation of items such as paper ballots delivered, paper ballots collected,

administrative procedures for system security, and maintenance performed on voting

equipment are also part of the election audit trail, but are not covered in these technical

standards. Useful guidance is provided by the Innovations in Election Administration #10;

Ballot Security and Accountability, available on the EAC’s website.

2.1.5.1 Operational Requirements

Audit records shall be prepared for all phases of election operations performed using devices

controlled by the jurisdiction or its contractors. These records rely upon automated audit data

acquisition and machine-generated reports, with manual input of some information. These

records shall address the ballot preparation and election definition phase, system readiness

tests, and voting and ballot-counting operations. The software shall activate the logging and

reporting of audit data as described below.

a. The timing and sequence of audit record entries is as important as the data contained

in the record. All voting systems shall meet the requirements for time, sequence and

preservation of audit records outlined below.

i. Except where noted, systems shall provide the capability to create and maintain

a real-time audit record. This capability records and provides the operator or

precinct official with continuous updates on machine status. This information

allows effective operator identification of an error condition requiring

intervention, and contributes to the reconstruction of election-related events

necessary for recounts or litigation.

ii. All systems shall include a real-time clock as part of the system’s hardware.

The system shall maintain an absolute record of the time and date or a record

relative to some event whose time and data are known and recorded.

iii.All audit record entries shall include the time-and-date stamp.

iv. The audit record shall be active whenever the system is in an operating mode.

This record shall be available at all times, though it need not be continually

visible.

v. The generation of audit record entries shall not be terminated or altered by

program control, or by the intervention of any person. The physical security and

integrity of the record shall be maintained at all times.

vi. Once the system has been activated for any function, the system shall preserve

the contents of the audit record during any interruption of power to the system

until processing and data reporting have been completed.

vii. The system shall be capable of printing a copy of the audit record. A separate

printer is not required for the audit record, and the record may be produced on

the standard system printer if all the following conditions are met:

• The generation of audit trail records does not interfere with the production

of output reports

• The entries can be identified so as to facilitate their recognition,

segregation, and retention
• The audit record entries are kept physically secure

b. All voting systems shall meet the requirements for error messages below.

i. The voting system shall generate, store, and report to the user all error messages

as they occur.

ii. All error messages requiring intervention by an operator or precinct official

shall be displayed or printed clearly in easily understood language text, or by

means of other suitable visual indicators.

iii.When the voting system uses numerical error codes for trained technician

maintenance or repair, the text corresponding to the code shall be self-contained

or affixed inside the voting machine. This is intended to reduce inappropriate

reactions to error conditions, and to allow for ready and effective problem

correction.

iv. All error messages for which correction impacts vote recording or vote

processing shall be written in a manner that is understandable to an election

official who possesses training on system use and operation, but does not

possess technical training on system servicing and repair.

v. The message cue for all voting systems shall clearly state the action to be

performed in the event that voter or operator response is required.

vi. Voting system design shall ensure that erroneous responses will not lead to

irreversible error.

vii. Nested error conditions shall be corrected in a controlled sequence such that

voting system status shall be restored to the initial state existing before the first

error occurred.

c. The Guidelines provide latitude in software design so that vendors can consider

various user processing and reporting needs. The jurisdiction may require some status

and information messages to be displayed and reported in real-time. Messages that do

not require operator intervention may be stored in memory to be recovered after

ballot processing has been completed.

The voting system shall display and report critical status messages using clear

indicators or English language text. The voting system need not display non-critical

status messages at the time of occurrence. Voting systems may display non-critical

status messages (i.e., those that do not require operator intervention) by means of

numerical codes for subsequent interpretation and reporting as unambiguous text.

Voting systems shall provide a capability for the status messages to become part of

the real-time audit record. The voting system shall provide a capability for a

jurisdiction to designate critical status messages.

2.1.5.2 Use of Shared Computing Platforms

Further requirements must be applied to Commercial-off-the-Shelf operating systems to

ensure completeness and integrity of audit data for election software. These operating

systems are capable of executing multiple application programs simultaneously. These

systems include both servers and workstations, including the many varieties of UNIX and

Linux, and those offered by Microsoft and Apple. Election software running on these

systems is vulnerable to unintended effects from other user sessions, applications, and

utilities executing on the same platform at the same time as the election software.
“Simultaneous processes” of concern include: unauthorized network connections, unplanned

user logins, and unintended execution or termination of operating system processes. An

unauthorized network connection or unplanned user login can host unintended processes and

user actions, such as the termination of operating system audit, the termination of election

software processes, or the deletion of election software audit and logging data. The execution

of an operating system process could be a full system scan at a time when that process would

adversely affect the election software processes. Operating system processes improperly

terminated could be system audit or malicious code detection.

To counter these vulnerabilities, three operating system protections are required on all such

systems on which election software is hosted. First, authentication shall be configured on the

local terminal (display screen and keyboard) and on all external connection devices

(“network cards” and “ports”). This ensures that only authorized and identified users affect

the system while election software is running.

Second, operating system audit shall be enabled for all session openings and closings, for all

connection openings and closings, for all process executions and terminations, and for the

alteration or deletion of any memory or file object. This ensures the accuracy and

completeness of election data stored on the system. It also ensures the existence of an audit

record of any person or process altering or deleting system data or election data.

Third, the system shall be configured to execute only intended and necessary processes

during the execution of election software. The system shall also be configured to halt election

software processes upon the termination of any critical system process (such as system audit)

during the execution of election software.

2.1.6 Election Management System

The Election Management System (EMS) is used to prepare ballots and programs for use in

casting and counting votes, and to consolidate, report, and display election results. An EMS

shall generate and maintain a database, or one or more interactive databases, that enables

election officials or their designees to perform the following functions:

• Define political subdivision boundaries and multiple election districts as indicated in

the system documentation

• Identify contests, candidates, and issues

• Define ballot formats and appropriate voting options

• Generate ballots and election-specific programs for voting equipment

• Install ballots and election-specific programs

• Test that ballots and programs have been properly prepared and installed

• Accumulate vote totals at multiple reporting levels as indicated in the system

documentation

• Generate the post-voting reports required by Subsection 2.4

• Process and produce audit reports of the data as indicated in Subsection 5.5

2.1.7 Vote Tabulating Program

Each voting system shall have a vote tabulation program that will meet specific functional

requirements.
2.1.7.1 Functions

The vote tabulating program software resident in each voting machine, vote count server, or

other devices shall include all software modules required to:

a. Monitor system status and generate machine-level audit reports

b.Accommodate device control functions performed by polling place officials and

maintenance personnel

c. Register and accumulate votes

d.Accommodate variations in ballot counting logic

2.1.7.2 Voting Variations

There are significant variations among state election laws with respect to permissible ballot

contents, voting options, and the associated ballot counting logic. The Technical Data

Package accompanying the system shall specifically identify which of the following items

can and cannot be supported by the voting system, as well as how the voting system can

implement the items supported:

• Closed primaries

• Open primaries

• Partisan offices

• Non-partisan offices

• Write-in voting

• Primary presidential delegation nominations

• Ballot rotation

• Straight party voting

• Cross-party endorsement

• Split precincts

• Vote for N of M

• Recall issues, with options

• Cumulative voting

• Ranked order voting

• Provisional or challenged ballots

2.1.8 Ballot Counter

For all voting systems, each piece of voting equipment that tabulates ballots shall provide a

counter that:

a. Can be set to zero before any ballots are submitted for tally

b. Records the number of ballots cast during a particular test cycle or election

c. Increases the count only by the input of a ballot

d. Prevents or disables the resetting of the counter by any person other than authorized

persons at authorized points

e. Is visible to designated election officials

2.1.9 Telecommunications
For all voting systems that use telecommunications for the transmission of data during prevoting,

voting or post-voting activities, capabilities shall be provided that ensure data are

transmitted with no alteration or unauthorized disclosure during transmission. Such

transmissions shall not violate the privacy, secrecy, and integrity demands of the Guidelines.

Section 6 describes telecommunications standards that apply to, at a minimum, the following

types of data transmissions:

Voter Authentication: Coded information that confirms the identity of a voter for

security purposes for a system that transmit votes individually over a public network

Ballot Definition: Information that describes to voting equipment the content and

appearance of the ballots to be used in an election

Vote Transmission to Central Site: For voting systems that transmit votes

individually over a public network, the transmission of a single vote to the county (or

contractor) for consolidation with other county vote data

Vote Count: Information representing the tabulation of votes at any one of several

levels: polling place, precinct, or central count

List of Voters: A listing of the individual voters who have cast ballots in a specific

Election

2.1.10 Data Retention

United States Code Title 42, Sections 1974 through 1974e state that election administrators

shall preserve for 22 months “all records and paper that came into (their) possession relating

to an application, registration, payment of poll tax, or other act requisite to voting.” This

retention requirement applies to systems that will be used at anytime for voting of candidates

for federal offices (e.g., Member of Congress, United States Senator, and/or Presidential

Elector). Therefore, all voting systems shall provide for maintaining the integrity of voting

and audit data during an election and for a period of at least 22 months thereafter.

Because the purpose of this law is to assist the federal government in discharging its law

enforcement responsibilities in connection with civil rights and elections crimes, its scope

must be interpreted in keeping with that objective. The appropriate state or local authority

must preserve all records that may be relevant to the detection and prosecution of federal

civil rights or election crimes for the 22-month federal retention period, if the records were

generated in connection with an election that was held in whole or in part to select federal

candidates. It is important to note that Section 1974 does not require that election officials

generate any specific type or classification of election record. However, if a record is

generated, Section 1974 comes into force and the appropriate authority must retain the

records for 22 months.

For 22-month document retention, the general rule is that all printed copy records produced

by the election database and ballot processing systems shall be so labeled and archived.

Regardless of system type, all audit trail information spelled out in Subsection 5.5 shall be

retained in its original format, whether that be real-time logs generated by the system, or

manual logs maintained by election personnel. The election audit trail includes not only 

inprocess logs of election-night and subsequent processing of absentee or provisional ballots,

but also time logs of baseline ballot definition formats, and system readiness and testing

results.
In many voting systems, the source of election-specific data (and ballot formats) is a database

or file. In precinct count voting systems, this data is used to program each machine, establish

ballot layout, and generate tallying files. It is not necessary to retain this information on

electronic media if there is an official, authenticated printed copy of all final database

information. However, it is recommended that the state or local jurisdiction also retain

electronic records of the aggregate data for each voting machine so that reconstruction of an

election is possible without data re-entry. The same requirement and recommendation applies

to vote results generated by each precinct count voting machine.

2.2 Pre-voting Capabilities

This subsection defines capabilities required to support functions performed prior to the opening 

of polls. All voting systems shall provide capabilities to support:

• Ballot preparation

• Election programming

• Ballot and program installation and control

• Readiness testing

• Verification at the polling place

• Verification at the central counting place

The standards also include requirements to ensure compatible interfaces with the ballot definition 

process and the reporting of election results.

2.2.1 Ballot Preparation

Ballot preparation is the process of using election databases to define the specific contests,

questions, and related instructions to be contained in ballots and to produce all permissible

ballot layouts. Ballot preparation requirements include:

• General capabilities

• Ballot formatting

• Ballot production

2.2.1.1 General Capabilities

All systems shall provide the general capabilities for ballot preparation. All systems shall be

capable of:

a. Enabling the automatic formatting of ballots in accordance with the requirements for

offices, candidates, and measures qualified to be placed on the ballot for each

political subdivision and election district

b. Collecting and maintaining the following data

i. Offices and their associated labels and instructions

ii. Candidate names and their associated labels

iii.Issues or measures and their associated text

c. Supporting the maximum number of potentially active voting positions as indicated in

the system documentation

d. For a primary election, generating ballots that segregate the choices in partisan

contests by party affiliation

e. Generating ballots that contain identifying codes or marks uniquely associated with
each format

f. Ensuring that vote response fields, selection buttons, or switches properly align with

the specific candidate names and/or issues printed on the ballot display, ballot card or

sheet, or separate ballot pages

Paper-based voting systems shall also meet the following requirements applicable to the

technology used:

g. Enable voters to make selections by making a mark in areas designated for this

purpose upon each ballot sheet

h. For marksense systems, ensure that the timing marks align properly with the vote

response fields

2.2.1.2 Ballot Formatting

Ballot formatting is the process by which election officials or their designees use election

databases and voting system software to define the specific contests and related instructions

contained on the ballot and present them in a layout permitted by state law. All voting

systems shall provide a capability for:

a. Creation of newly defined elections

b. Rapid and error-free definition of elections and their associated ballot layouts

c. Uniform allocation of space and fonts used for each office, candidate, and contest

such that the voter perceives no active voting position to be preferred to any other

d. Simultaneous display of the maximum number of choices for a single contest as

indicated by the vendor in the system documentation

e. Retention of previously defined formats for an election

f. Prevention of unauthorized modification of any ballot formats

g. Modification by authorized persons of a previously defined ballot format for use in a

subsequent election

2.2.1.3 Ballot Production

Ballot production is the process of converting ballot formats to a media ready for use in the

physical ballot production or electronic presentation.

The voting system shall provide a means of printing or otherwise generating a ballot display

that can be installed in all voting equipment for which it is intended. All voting systems shall

provide the capabilities below.

a. The electronic display or printed document on which the user views the ballot is

capable of rendering an image of the ballot in any of the languages required by the

Voting Rights Act of 1965, as amended.

b. The electronic display or printed document on which the user views the ballot does

not show any advertising or commercial logos of any kind, whether public service,

commercial, or political, unless specifically provided for in state law. Electronic

displays shall not provide connection to such material through hyperlink.

c. The ballot conforms to vendor specifications for type of paper stock, weight, size,

shape, size and location of mark field used to record votes, folding, bleed-through,

and ink for printing if paper ballot documents or paper displays are part of the system.

Vendor documentation for marksense systems shall include specifications for ballot materials

to ensure that vote selections are read from only a single ballot at a time, without detection of
marks from multiple ballots concurrently (e.g., reading of bleed-through from other ballots).

2.2.2 Election Programming

Election programming is the process by which election officials or their designees use

election databases and vendor system software to logically define the voter choices

associated with the contents of the ballots. All systems shall provide for the:

a. Logical definition of the ballot, including the definition of the number of allowable

choices for each office and contest

b. Logical definition of political and administrative subdivisions, where the list of

candidates or contests varies between polling places

c. Exclusion of any contest on the ballot in which the voter is prohibited from casting a

ballot because of place of residence, or other such administrative or geographical

criteria

d. Ability to select from a range of voting options to conform to the laws of the

jurisdiction in which the system will be used

e. Generation of all required master and distributed copies of the voting program, in

conformance with the definition of the ballots for each voting device and polling

place, and for each tabulating device

2.2.3 Ballot and Program Installation and Control

All systems shall provide a means of installing ballots and programs on each piece of polling

place or central count equipment in accordance with the ballot requirements of the election

and the requirements of the jurisdiction in which the equipment will be used. All systems

shall include the following at the time of ballot and program installation:

a. A detailed work plan or other documentation providing a schedule and steps for the

software and ballot installation, which includes a table outlining the key dates, events

and deliverables

b. A capability for automatically verifying that the software has been properly selected

and installed in the equipment or in programmable memory devices, and for

indicating errors

c. A capability for automatically validating that software correctly matches the ballot

formats that it is intended to process, for detecting errors, and for immediately

notifying an election official of detected errors

2.2.4 Readiness Testing

Election personnel conduct voting equipment and voting system readiness tests prior to the

start of an election to ensure that the voting system functions properly, to confirm that voting

equipment has been properly integrated, and to obtain equipment status reports. All voting

systems shall provide the capabilities to:

a. Verify that voting equipment and precinct count equipment is properly prepared for

an election, and collect data that verifies equipment readiness

b. Obtain status and data reports from each set of equipment

c. Verify the correct installation and interface of all voting equipment

d. Verify that hardware and software function correctly

e. Generate consolidated data reports at the polling place and higher jurisdictional levels
f. Segregate test data from actual voting data, either procedurally or by

hardware/software features

Resident test software, external devices, and special purpose test software connected to or

installed in voting equipment to simulate operator and voter functions may be used for these

tests provided that the following standards are met:

g. These elements shall be capable of being tested separately, and shall be proven to be

reliable verification tools prior to their use

h. These elements shall be incapable of altering or introducing any residual effect on the

intended operation of the voting device during any succeeding test and operational

phase

Paper-based systems shall:

i. Support conversion testing that uses all potential ballot positions as active positions

j. Support conversion testing of ballots with active position density for systems without

pre-designated ballot positions

2.2.5 Verification at the Polling Place

Election officials perform verification at the polling place to ensure that all voting systems

and voting equipment function properly before and during an election. All voting systems

shall provide a formal record of the following, in any media, upon verification of the

authenticity of the command source:

a. The election's identification data

b. The identification of all equipment units

c. The identification of the polling place

d. The identification of all ballot formats

e. The contents of each active candidate register by office and of each active measure

register at all storage locations (showing that they contain only zeros)

f. A list of all ballot fields that can be used to invoke special voting options

g. Other information needed to confirm the readiness of the equipment, and to

accommodate administrative reporting requirements

To prepare voting devices to accept voted ballots, all voting systems shall provide the

capability to test each device prior to opening to verify that each is operating correctly. At a

minimum, the tests shall include:

h. Confirmation that there are no hardware or software failures

i. Confirmation that the device is ready to be activated for accepting votes

If a precinct count system includes equipment for the consolidation of polling place data at

one or more central counting locations, it shall have means to verify the correct extraction of

voting data from transportable memory devices, or to verify the transmission of secure data

over secure communication links.

2.2.6 Verification at the Central Location

Election officials perform verification at the central location to ensure that vote counting and

vote consolidation equipment and software function properly before and after an election.

Upon verification of the authenticity of the command source, any system used in a central

count environment shall provide a printed record of the following:

a. The election's identification data

b. The contents of each active candidate register by office and of each active measure
register at all storage locations (showing that they contain all zeros)

c. Other information needed to ensure the readiness of the equipment and to

accommodate administrative reporting requirements

2.3 Voting Capabilities

All voting systems shall support:

• Opening the polls

• Casting a ballot

Additionally, all DRE systems shall support:

• Activating the ballot

• Augmenting the election counter

• Augmenting the life-cycle counter

2.3.1 Opening the Polls

The capabilities required for opening the polls are specific to individual voting system

technologies. At a minimum, the systems shall provide the functional capabilities indicated

below.

2.3.1.1 Precinct Count Systems

To allow voting devices to be activated for voting, all precinct count systems shall provide:

a. An internal test or diagnostic capability to verify that all of the polling place tests

specified in Subsection 2.2.5 have been successfully completed

b. Automatic disabling of any device that has not been tested until it has been tested

2.3.1.2 Paper-based System Requirements

To facilitate opening the polls, all paper-based systems shall include:

a. A means of verifying that ballot marking devices are properly prepared and ready to

use

b. A voting booth or similar facility, in which the voter may mark the ballot in privacy

c. Secure receptacles for holding voted ballots

In addition to the above requirements, all paper-based precinct count equipment shall include

a means of:

d. Activating the ballot counting device

e. Verifying that the device has been correctly activated and is functioning properly

f. Identifying device failure and corrective action needed

2.3.1.3 DRE System Requirements

To facilitate opening the polls, all DRE systems shall include:

a. A security seal, a password, or a data code recognition capability to prevent the

inadvertent or unauthorized actuation of the poll-opening function

b. A means of enforcing the execution of steps in the proper sequence if more than one

step is required

c. A means of verifying the system has been activated correctly

d. A means of identifying system failure and any corrective action needed
2.3.2 Activating the Ballot (DRE Systems)

To activate the ballot, all DRE systems shall:

a. Enable election officials to control the content of the ballot presented to the voter,

whether presented in printed form or electronic display, such that each voter is

permitted to record votes only in contests in which that voter is authorized to vote

b. Allow each eligible voter to cast a ballot

c. Prevent a voter from voting on a ballot to which he or she is not entitled

d. Prevent a voter from casting more than one ballot in the same election

e. Activate the casting of a ballot in a general election

f. Enable the selection of the ballot that is appropriate to the party affiliation declared by

the voter in a primary election

g. Activate all portions of the ballot upon which the voter is entitled to vote

h. Disable all portions of the ballot upon which the voter is not entitled to vote

2.3.3 Casting a Ballot

Some required capabilities for casting a ballot are common to all systems. Others are specific

to individual voting technologies or intended use. Systems must provide additional functional

capabilities that enable accessibility to disabled voters as defined in Subsection 3.2.

2.3.3.1 Common Requirements

To facilitate casting a ballot, all systems shall:

a. Provide text that is at least 3 millimeters high and provide the capability to adjust or

magnify the text to an apparent size of 6.3 millimeters

b. Protect the secrecy of the vote such that the system cannot reveal any information

about how a particular voter voted, except as otherwise required by individual state

law

c. Record the selection and non-selection of individual vote choices for each contest and

ballot measure

d. Record the voter’s selection of candidates whose names do not appear on the ballot, if

permitted under state law, and record as many write-in votes as the number of

candidates the voter is allowed to select

e. In the event of a failure of the main power supply external to the voting system,

provide the capability for any voter who is voting at the time to complete casting a

ballot, allow for the successful shutdown of the voting system without loss or

degradation of the voting and audit data, and allow voters to resume voting once the

voting system has reverted to back-up power

f. Provide the capability for voters to continue casting ballots in the event of a failure of

a telecommunications connection within the polling place or between the polling

place and any other location

2.3.3.2 Paper-based System Requirements

All paper-based systems shall:

a. Allow the voter to easily identify the voting field that is associated with each

candidate or ballot measure response
b. Allow the voter to mark the ballot to register a vote

c. Allow either the voter or the appropriate election official to place the voted ballot into

the ballot counting device (for precinct count systems) or into a secure receptacle (for

central count systems)

d. Protect the secrecy of the vote throughout the process

In addition to the above requirements, all paper-based precinct count systems shall:

e. Provide feedback to the voter that identifies specific contests for which he or she has

made no selection or fewer than the allowable number of selections (e.g., undervotes)

f. Notify the voter if he or she has made more than the allowable number of selections

for any contest (e.g., overvotes)

g. Notify the voter before the ballot is cast and counted of the effect of making more

than the allowable number of selections for a contest

h. Provide the voter opportunity to correct the ballot for either an undervote or overvote

before the ballot is cast and counted

2.3.3.3 DRE System Requirements

In addition to the above common requirements, DRE systems shall:

a. Prohibit the voter from accessing or viewing any information on the display screen

that has not been authorized by election officials and preprogrammed into the voting

system (i.e., no potential for display of external information or linking to other

information sources)

b. Enable the voter to easily identify the selection button or switch, or the active area of

the ballot display, that is associated with each candidate or ballot measure response

c. Allow the voter to select his or her preferences on the ballot in any legal number and

combination

d. Indicate that a selection has been made or canceled

e. Indicate to the voter when no selection, or an insufficient number of selections, has

been made for a contest (e.g., undervotes)

f. Notify the voter if he or she has made more than the allowable number of selections

for any contest (e.g., overvotes)

g. Notify the voter before the ballot is cast and counted of the effect of making more

than the allowable number of selections for a contest

h. Provide the voter opportunity to correct the ballot for either an undervote or overvote

before the ballot is cast and counted

i. Notify the voter when the selection of candidates and measures is completed

j. Allow the voter, before the ballot is cast, to review his or her choices and, if the voter

desires, to delete or change his or her choices before the ballot is cast

k. For electronic image displays, prompt the voter to confirm the voter's choices before

casting his or her ballot, signifying to the voter that casting the ballot is irrevocable

and directing the voter to confirm the voter’s intention to cast the ballot

l. Notify the voter after the vote has been stored successfully that the ballot has been

cast

m. Notify the voter that the ballot has not been cast successfully if it is not stored

successfully, including storage of the ballot image, and provide clear instruction as to

the steps the voter should take to cast his or her ballot should this event occur

n. Provide sufficient computational performance to provide responses back to each voter
entry in no more than three seconds

o. Ensure that the votes stored accurately represent the actual votes cast

p. Prevent modification of the voter’s vote after the ballot is cast

q. Provide a capability to retrieve ballot images in a form readable by humans [in

accordance with the requirements of Subsections 2.1.2 (f) and 2.1.4 (k) and (l)]

r. Increment the proper ballot position registers or counters

s. Protect the secrecy of the vote throughout the voting process

t. Prohibit access to voted ballots until after the close of polls

u. Provide the ability for election officials to submit test ballots for use in verifying the

end-to-end integrity of the voting system

v. Isolate test ballots such that they are accounted for accurately in vote counts and are

not reflected in official vote counts for specific candidates or measures

2.4 Post-Voting Capabilities

All voting systems shall provide capabilities to accumulate and report results for the

jurisdiction and to generate audit trails. In addition, precinct count voting systems must

provide a means to close the polls including generating appropriate reports. If the system

provides the capability to broadcast results, additional standards apply.

2.4.1 Closing the Polls

These requirements for closing the polls and locking voting systems against future voting are

specific to precinct count systems. The voting system shall provide the means for:

a. Preventing the further casting of ballots once the polls have closed

b. Providing an internal test that verifies that the prescribed closing procedure has been

followed, and that the device status is normal

c. Incorporating a visible indication of system status

d. Producing a diagnostic test record that verifies the sequence of events, and indicates

that the extraction of voting data has been activated

e. Precluding the unauthorized reopening of the polls once the poll closing has been

completed for that election

2.4.2 Consolidating Vote Data

All systems shall provide a means to consolidate vote data from all polling places, and

optionally from other sources such as absentee ballots, provisional ballots, and voted ballots

requiring human review (e.g., write-in votes).

2.4.3 Producing Reports

All systems shall be able to create reports summarizing the vote data on multiple levels.

All systems shall provide capabilities to:

a. Support geographic reporting, which requires the reporting of all results for each

contest at the precinct level and additional jurisdictional levels

b. Produce a printed report of the number of ballots counted by each tabulator

c. Produce a printed report for each tabulator of the results of each contest that includes

the votes cast for each selection, the count of undervotes, and the count of overvotes

d. Produce a consolidated printed report of the results for each contest of all votes cast
(including the count of ballots from other sources supported by the system as

specified by the vendor) that includes the votes cast for each selection, the count of

undervotes, and the count of overvotes. Be capable of producing a consolidated printed report of 

the combination of overvotes for any contest that is selected by an authorized official (e.g., the 

number of overvotes in a given contest combining candidate A and candidate B, combining

candidate A and candidate C, etc.)

f. Produce all system audit information required in Subsection 5.4 in the form of printed

reports, or in electronic memory for printing centrally

g. Prevent data from being altered or destroyed by report generation, or by the

transmission of results over telecommunications lines

In addition, all precinct count voting systems shall:

h. Prevent the printing of reports and the unauthorized extraction of data prior to the

official close of the polls

i. Provide a means to extract information from a transportable programmable memory

device or data storage medium for vote consolidation

j. Consolidate the data contained in each unit into a single report for the polling place

when more than one voting machine or precinct tabulator is used

k. Prevent data in transportable memory from being altered or destroyed by report

generation, or by the transmission of official results over telecommunications lines

2.4.4 Broadcasting Results

Some voting systems offer the capability to make unofficial results available to external

organizations such as the news media, political party officials, and others. Although this

capability is not required, systems that make unofficial results available shall:

a. Provide only aggregated results, and not data from individual ballots

b. Provide no access path from unofficial electronic reports or files to the storage

devices for official data

c. Clearly indicate on each report or file that the results it contains are unofficial

2.5 Maintenance, Transportation, and Storage

All systems shall be designed and manufactured to facilitate preventive and corrective

maintenance, conforming to the hardware standards described in Subsection 4.1. All vote

casting and tally equipment designated for storage between elections shall:

a. Function without degradation in capabilities after transit to and from the place of use,

as demonstrated by meeting the performance standards described in Subsection 4.1

b. Function without degradation in capabilities after storage between elections, as

demonstrated by meeting the performance standards described in Subsection 4.1

3 Usability and Accessibility Requirements

Table of Contents

3 Usability and Accessibility Requirements 

3.1 Usability Requirements

3.1.1 Usability Testing 
3.1.2 Functional Capabilities

3.1.3 Alternative Languages

3.1.4 Cognitive Issues

3.1.5 Perceptual Issues 

3.1.6 Interaction Issues 

3.1.7 Privacy

3.1.7.1 Privacy at the Polls 

3.1.7.2 No Recording of Alternate Format Usage 

3.2 Accessibility Requirements 

3.2.1 General 

3.2.2 Vision 

3.2.2.1 Partial Vision 

3.2.2.2 Blindness

3.2.3 Dexterity 

3.2.4 Mobility 

3.2.5 Hearing 

3.2.6 Speech

3.2.7 English Proficiency 

3.2.8 Cognition 

3 Usability and Accessibility Requirements

The importance of usability and accessibility in the design of voting systems has become

increasingly apparent. It is not sufficient that the internal operation of these systems be

correct; in addition, voters and poll workers must be able to use them effectively. There are

some particular considerations for the design of usable and accessible voting systems:

• The voting task itself can be fairly complex; the voter may have to navigate an

electronic ballot, choose multiple candidates in a single contest, or decide on

abstrusely worded referenda

• Voting is performed infrequently, so there is limited opportunity for voters and poll

workers to gain familiarity with the process

• Jurisdictions may change voting equipment, thus obviating whatever familiarity the

voter might have acquired

• Usability and accessibility requirements include a broad range of factors, including

physical abilities, language skills, and technology experience

The challenge, then, is to provide a voting system that voters can use comfortably,

efficiently, and with confidence that they have cast their votes correctly. The requirements

within this section are intended to serve that goal. Three broad principles motivate this

section:

1. All eligible voters shall have access to the voting process without discrimination.

The voting process shall be accessible to individuals with disabilities. The voting process

includes access to the polling place, instructions on how to vote, initiating the voting session,

making ballot selections, review of the ballot, final submission of the ballot, and getting help

when needed.

2. Each cast ballot shall accurately capture the selections made by the voter.

The ballot shall be presented to the voter in a manner that is clear and usable. Voters should
encounter no difficulty or confusion regarding the process for recording their selections.

3. The voting process shall preserve the secrecy of the ballot.

The voting process shall preclude anyone else from determining the content of a voter's

ballot, without the voter's cooperation. If such a determination is made against the wishes of

the voter, then his or her privacy has been violated.

All the requirements in this section have the purpose of improving the quality of interaction

between voters and voting systems.

• Requirements for general usability apply to all voting systems. Requirements for any

alternative languages required by state or federal law are included under this heading.

• Requirements to assist voters with physical, sensory, or cognitive disabilities apply,

as a minimum, to the accessible voting stations required by HAVA Section 301

(a)(3)(B). They may also assist those not usually described as having a disability,

e.g., voters with poor eyesight or limited dexterity.

Several uncommon terms are used in this section. For the convenience of the reader, they are

defined below, in addition to being included in the Glossary. Other terms frequently used

here and throughout this document are defined in the Glossary. Note in particular the

distinctions between these terms: voting system, voting equipment, voting machine and

voting station.

• Common Industry Format (CIF) - the format to be used for usability testing reporting,

described in ANSI/INCITS 354-2001 "Common Industry Format (CIF) for Usability

Test Reports"

• Accessible Voting Station – the voting station equipped for individuals with

disabilities referred to in HAVA 301 (a)(3)(B).

• Audio-Tactile Interface - a voter interface designed not to require visual reading of a

ballot. Audio is used to convey information to the voter and sensitive tactile controls

allow the voter to convey information to the voting system.

3.1 Usability Requirements

The voting process shall provide a high level of usability for voters. Accordingly, voters

shall be able to negotiate the process effectively, efficiently, and comfortably. The

mandatory voting system standards mandated in HAVA Section 301 relate to the interaction

between the voter and the voting system:

a. Requirements.--Each voting system used in an election for

federal office shall meet the following requirements:

1. In general.--

A. Except as provided in subparagraph (B), the voting system

(including any lever voting system, optical scanning voting system,

or direct recording electronic system) shall--

i. Permit the voter to verify (in a private and independent manner)

the votes selected by the voter on the ballot before the ballot is cast

and counted;

ii. Provide the voter with the opportunity (in a private and

independent manner) to change the ballot or correct any error

before the ballot is cast and counted (including the opportunity to

correct the error through the issuance of a replacement ballot if

the voter was otherwise unable to change the ballot or correct any
error); and

iii. If the voter selects votes for more than one candidate for a

single office—

I. Notify the voter that the voter has selected more than one

candidate for a single office on the ballot;

II. Notify the voter before the ballot is cast and counted of the effect of casting multiple 

votes for the office; and

III. Provide the voter with the opportunity to correct the ballot before the ballot is cast and 

counted.

B. A state or jurisdiction that uses a paper ballot voting system, a punch card voting 

system, or a central count voting system (including mail-in absentee ballots and mail-in 

ballots), may meet the requirements of subparagraph (A)(iii) by—

i. Establishing a voter education program specific to that voting system that notifies each 

voter of the effect of casting multiple votes for an office; and

ii. Providing the voter with instructions on how to correct the ballot before it is cast and 

counted (including instructions on how to correct the error through the issuance of a 

replacement ballot if the voter was otherwise unable to change the ballot or correct any 

error).

C. The voting system shall ensure that any notification required under this paragraph 

preserves the privacy of the voter and the confidentiality of the ballot.

Usability is defined generally as a measure of the effectiveness, efficiency, and satisfaction

achieved by a specified set of users with a given product in the performance of specified

tasks. In the context of voting, the primary user is the voter, the product is the voting system,

and the task is the correct recording of the voter ballot selections. Additional requirements

for task performance are independence and privacy: the voter should normally be able to

complete the voting task without assistance from others, and the voter selections should be

private. Lack of independence or privacy may adversely affect effectiveness (e.g., by

possibly inhibiting the voter's free choice) and efficiency (e.g., by slowing down the process).

Among the basic metrics for usability are:

• low error rate for marking the ballot (the voter selection is correctly conveyed to and

represented within the voting system)

• efficient operation (time required to vote is not excessive)

• satisfaction (voter experience is safe, comfortable, free of stress, and instills

confidence)

It is the intention of the EAC that in future revisions to the Guidelines, usability will be

addressed by high-level performance-based requirements. That is, the requirements will

directly address metrics for effectiveness (e.g., correct capture of voter selections), efficiency

(e.g., time taken to vote), and satisfaction. Until the supporting research is completed,

however, the contents of this subsection are limited to a basic set of widely accepted design

requirements and lower-level performance requirements. The reasons for this approach are:

• These are to serve as interim requirements, pending the issuance of high-level

performance requirements

• The actual benefit of numerous detailed design guidelines is difficult to prove or

measure

• The technical complexity and costs of a large set of detailed requirements may not be
justified

• Guidelines that are difficult to test because of insufficient specificity have been

omitted

While the scope of usability applies to the entire voting process, the emphasis in these

requirements is on the voter interface with the voting machine, which is assumed to be a

visual-tactile interface.

The outline for this subsection is:

3.1.1 Usability Testing

3.1.2 Functional Capabilities

3.1.3 Alternative Languages

3.1.4 Cognitive Issues

3.1.5 Perceptual Issues

3.1.6 Interaction Issues

3.1.7 Privacy

3.1.1 Usability Testing

The vendor shall conduct summative usability tests on the voting system using individuals

representative of the general population. The vendor shall document the testing performed

and report the test results using the Common Industry Format. This documentation shall be

included in the Technical Data Package submitted to the EAC for national certification.

Discussion: Voting system developers are required to conduct realistic usability tests on

the final product. For the present, vendors can define their own testing

protocols. Future revisions to the Guidelines will include requirements for

usability testing that will provide specific performance benchmarks.

3.1.2 Functional Capabilities

The voting process shall provide certain functional capabilities to support voter usability.

a. The voting system shall provide feedback to the voter that identifies specific contests

or ballot issues for which he or she has made no selection or fewer than the allowable

number of selections (e.g., undervotes)

b. The voting system shall notify the voter if he or she has made more than the

allowable number of selections for any contest (e.g., overvotes)

c. The voting system shall notify the voter before the ballot is cast and counted of the

effect of making more than the allowable number of selections for a contest

d. The voting system shall provide the voter the opportunity to correct the ballot for

either an undervote or overvote before the ballot is cast and counted

e. The voting system shall allow the voter, at his or her choice, to submit an undervoted

ballot without correction

f. DRE voting machines shall allow the voter to change a vote within a contest before

advancing to the next contest.

Discussion: The point here is that voters using a DRE should not have to wait for the

final ballot review screen in order to change a vote.

g. DRE voting machines should provide navigation controls that allow the voter to

advance to the next contest or go back to the previous contest before completing a

vote on the contest currently being presented (whether visually or aurally).

Discussion: For example, the voter should not be forced to proceed sequentially through

all the contests before going back to check his or her selection for a
previous contest.

3.1.3 Alternative Languages

The voting equipment shall be capable of presenting the ballot, ballot selections, review

screens and instructions in any language required by state or federal law.

Discussion: HAVA Section 301 (a)(4) states that the voting system shall provide

alternative language accessibility pursuant to the requirements of section

203 of the Voting Rights Act of 1965 (42 U.S.C. 1973aa-1a). Ideally every

voter would be able to vote independently and privately, regardless of

language. As a practical matter, alternative language access is mandated

under the Voting Rights Act of 1975, subject to certain thresholds, e.g., if

the language group exceeds 5% of the voting age population. The audio

interface provided for blind voters may also assist voters who speak

English, but who are unable to read it (See Subsection 3.2.2.2).

3.1.4 Cognitive Issues

The voting process shall be designed to minimize cognitive difficulties for the voter.

a. Consistent with election law, the voting system should support a process that does not

introduce any bias for or against any of the selections to be made by the voter. In

both visual and aural formats, contest choices shall be presented in an equivalent

manner.

Discussion: Certain differences in presentation are mandated by state law, such as the

order in which candidates are listed and provisions for voting for write-in

candidates. But comparable characteristics such as font size or voice

volume and speed must be the same for all choices.

b. The voting machine or related materials shall provide clear instructions and assistance

to allow voters to successfully execute and cast their ballots independently.

Discussion: Voters should not routinely need to ask for human assistance.

i. Voting machines or related materials shall provide a means for the voter to get

help at any time during the voting session.

Discussion: The voter should always be able to get help if needed. DRE voting

machines may provide this with a distinctive “help” button. Any type of

voting equipment may provide written instructions that are separate from

the ballot.

ii. The voting machine shall provide instructions for all its valid operations.

Discussion: If an operation is available to the voter, it must be documented. Examples

include how to change a vote, how to navigate among contests, how to cast

a straight party vote, and how to cast a write-in vote.

c. The voting system shall provide the capability to design a ballot for maximum clarity

and comprehension.

i. The voting equipment should not visually present a single contest spread over

two pages or two columns.

Discussion: Such a visual separation poses the risk that the voter may perceive one

contest as two. If a contest has a large number of candidates, it may be

infeasible to observe this guideline.

ii. The ballot shall clearly indicate the maximum number of candidates for which

one can vote within a single contest.

iii.There shall be a consistent relationship between the name of a candidate and the
mechanism used to vote for that candidate.

Discussion: For example, if the response field where voters indicate their selections is

located to the left of a candidate’s name, then each response field shall be

located to the left of the associated candidates’ names.

d. Warnings and alerts issued by the voting system should clearly state the nature of the

problem and the set of responses available to the voter. The warning should clearly

state whether the voter has performed or attempted an invalid operation or whether

the voting equipment itself has malfunctioned in some way.

Discussion: In case of an equipment failure, the only action available to the voter might

be to get assistance from a poll worker.

e. The use of color by the voting system should agree with common conventions: (a)

green, blue or white is used for general information or as a normal status indicator;

(b) amber or yellow is used to indicate warnings or a marginal status; (c) red is used

to indicate error conditions or a problem requiring immediate attention

.

3.1.5 Perceptual Issues

The voting process shall be designed to minimize perceptual difficulties for the voter.

a. No voting machine display screen shall flicker with a frequency between 2 Hz and 55

Hz.

Discussion: Aside from usability concerns, this requirement protects voters with

epilepsy.

b. Any aspect of the voting machine that is adjustable by the voter or poll worker,

including font size, color, contrast, and audio volume, shall automatically reset to a

standard default value upon completion of that voter's session.

Discussion: The voting machine must present the same initial appearance to every voter.

c. If any aspect of a voting machine is adjustable by the voter or poll worker, there shall

be a mechanism to reset all such aspects to their default values.

Discussion: The purpose is to allow a voter who has adjusted the machine into an

undesirable state to reset all the aspects to begin again.

d. All electronic voting machines shall provide a minimum font size of 3.0 mm

(measured as the height of a capital letter) for all text.

e. All voting machines using paper ballots should make provisions for voters with poor

reading vision.

Discussion: Possible solutions include: (a) providing paper ballots in at least two font

sizes, 3.0-4.0mm and 6.3-9.0mm and (b) providing a magnifying device.

f. The default color coding shall maximize correct perception by voters with color

blindness.

Discussion: There are many types of color blindness and no color coding can, by itself,

guarantee correct perception for everyone. However, designers should take

into account such factors as: red-green color blindness is the most common

form; high luminosity contrast will help colorblind voters to recognize

visual features; and color-coded graphics can also use shape to improve the

ability to distinguish certain features.

g. Color coding shall not be used as the sole means of conveying information, indicating

an action, prompting a response, or distinguishing a visual element.

Discussion: While color can be used for emphasis, some other non-color mode must

also be used to convey the information, such as a shape or text style. For

example, red can be enclosed in an octagon shape.
h. All text intended for the voter should be presented in a sans serif font.

Discussion: Experimentation has shown that users prefer such a font and the legibility of

serif and sans serif fonts is equivalent.

i. The minimum figure-to-ground ambient contrast ratio for all text and informational

graphics (including icons) intended for the voter shall be 3:1.

3.1.6 Interaction Issues

The voting process shall be designed to minimize interaction difficulties for the voter.

a. Voting machines with electronic image displays shall not require page scrolling by

the voter.

Discussion: This is not an intuitive operation for those unfamiliar with the use of

computers. Even those experienced with computers often do not notice a

scroll bar and miss information at the bottom of the “page.” Voting

systems may require voters to move to the next or previous "page."

b. The voting machine shall provide unambiguous feedback regarding the voter’s

selection, such as displaying a checkmark beside the selected option or conspicuously

changing its appearance.

c. If the voting machine requires a response by a voter within a specific period of time,

it shall issue an alert at least 20 seconds before this time period has expired and

provide a means by which the voter may receive additional time.

d. Input mechanisms shall be designed to minimize accidental activation.

i. On touch screens, the sensitive touch areas shall have a minimum height of 0.5

inches and minimum width of 0.7 inches. The vertical distance between the

centers of adjacent areas shall be at least 0.6 inches, and the horizontal distance

at least 0.8 inches.

ii. No key or control on a voting machine shall have a repetitive effect as a result

of being held in its active position.

Discussion: This is to preclude accidental activation. For instance, if a voter is typing in

the name of a write-in candidate, depressing and holding the “e” key results

in only a single “e” added to the name.

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3.1.7 Privacy

The voting process shall preclude anyone else from determining the content of a voter's

ballot, without the voter's cooperation.

Discussion: Privacy ensures that the voter can make selections based solely on his or

her own preferences without intimidation or inhibition. Among other

practices, this forbids the issuance of a receipt to the voter that would

provide proof of how he or she voted.

3.1.7.1 Privacy at the Polls

When deployed according to the installation instructions provided by the vendor, the voting

station shall prevent others from observing the contents of a voter’s ballot.

a. The ballot and any input controls shall be visible only to the voter during the voting
session and ballot submission.

b. The audio interface shall be audible only to the voter.

Discussion: Voters who are hard of hearing but need to use an audio interface may also

need to increase the volume of the audio. Such situations require

headphones with low sound leakage.

c. As mandated by HAVA 301 (a)(1)(C), the voting system shall notify the voter of an

attempted overvote in a way that preserves the privacy of the voter and the

confidentiality of the ballot.

3.1.7.2 No Recording of Alternate Format Usage

Voter anonymity shall be maintained for alternative format ballot presentation.

a. No information shall be kept within an electronic cast vote record that identifies any

alternative language feature(s) used by a voter.

b. No information shall be kept within an electronic cast vote record that identifies any

accessibility feature(s) used by a voter.

3.2 Accessibility Requirements

The voting process shall be accessible to voters with disabilities. As a minimum, every

polling place shall have at least one voting station equipped for individuals with disabilities,

as provided in HAVA 301 (a)(3)(B). A machine so equipped is referred to herein as an

accessible voting station.

HAVA Section 301 (a) (3) reads, in part:

ACCESSIBILITY FOR INDIVIDUALS WITH DISABILITIES.--The

voting system shall—

(A) be accessible for individuals with disabilities, including nonvisual

accessibility for the blind and visually impaired, in a manner that

provides the same opportunity for access and participation (including

privacy and independence) as for other voters;

(B) satisfy the requirement of subparagraph (A) through the use of at

least one direct recording electronic voting system or other voting system

equipped for individuals with disabilities at each polling place

The requirements in Subsection 3.2 are intended to address this mandate. Ideally, every

voter would be able to vote independently and privately. As a practical matter, there may be

some number of voters whose disabilities are so severe that they will need personal

assistance. Nonetheless, these requirements are meant to make the voting system

independently accessible to as many voters as possible. These requirements are in addition

to those described in Subsection 3.1 Usability Requirements.

The outline for this subsection is:

3.2.1 General

3.2.2 Vision

3.2.3 Dexterity

3.2.4 Mobility

3.2.5 Hearing

3.2.6 Speech

3.2.7 English Proficiency
3.2.8 Cognition

3.2.1 General

The voting process shall incorporate the following features that are applicable to all types of

disabilities:

a. When the provision of accessibility involves an alternative format for ballot

presentation, then all information presented to voters including instructions, warnings,

error and other messages, and ballot choices shall be presented in that alternative

format.

b. The support provided to voters with disabilities shall be intrinsic to the accessible

voting station. It shall not be necessary for the accessible voting station to be

connected to any personal assistive device of the voter in order for the voter to

operate it correctly.

Discussion: This requirement does not preclude the accessible voting station from

providing interfaces to assistive technology. [See definition of “personal

assistive devices” in the Glossary.] Its purpose is to assure that disabled

voters are not required to bring special devices with them in order to vote

successfully. The requirement does not assert that the accessible voting

station will obviate the need for a voter’s ordinary non-interfacing devices,

such as eyeglasses or canes. Jurisdictions should ensure that an accessible

voting station provides clean and sanitary devices for voters with dexterity

disabilities.

c. When the primary means of voter identification or authentication uses biometric

measures that require a voter to possess particular biological characteristics, the

voting process shall provide a secondary means that does not depend on those

characteristics.

Discussion: For example, if fingerprints are used for voter identification, another

mechanism shall be provided for voters without usable fingerprints.

3.2.2 Vision

The voting process shall be accessible to voters with visual disabilities.

Discussion: Note that all aspects of the voting process are to be accessible, not just the

voting machine.

3.2.2.1 Partial Vision

The accessible voting station shall be accessible to voters with partial vision.

a. The vendor shall conduct summative usability tests on the voting system using

partially sighted individuals. The vendor shall document the testing performed and

report the test results using the Common Industry Format. This documentation shall

be included in the Technical Data Package submitted to the EAC for national

certification.

Discussion: Voting system developers are required to conduct realistic usability tests on

the final product. For the present, vendors can define their own testing

protocols. Future revisions to the Guidelines will include requirements for

usability testing that will provide specific performance benchmarks.

b. The accessible voting station with an electronic image display shall be capable of

showing all information in at least two font sizes, (a) 3.0-4.0 mm and (b) 6.3-9.0 mm,

under control of the voter.
Discussion: All millimeters will be calculated using Hard Metric Conversion. [See

Glossary for definition.] While larger font sizes may assist most voters

with poor vision, certain disabilities such as tunnel vision are best

addressed by smaller font sizes.

c. An accessible voting station with a monochrome-only electronic image display shall

be capable of showing all information in high contrast either by default or under the

control of the voter or poll worker. High contrast is a figure-to-ground ambient

contrast ratio for text and informational graphics of at least 6:1.

d. An accessible voting station with a color electronic image display shall allow the

voter to adjust the color or the figure-to-ground ambient contrast ratio.

Discussion: See Technical Guide for Color, Contrast and Text Size in Appendix D for

examples of how a voting station may meet this requirement by offering a

limited number of discrete choices. In particular, it is not required that the

station offer a continuous range of color or contrast values.

e. Buttons and controls on accessible voting stations shall be distinguishable by both

shape and color.

Discussion: The redundant cues are helpful to those with low vision. They are also

helpful to individuals who may have difficulty reading the text on the

screen.

f. An accessible voting station using an electronic image display shall provide

synchronized audio output to convey the same information as that which is displayed

on the screen.

3.2.2.2 Blindness

The accessible voting station shall be accessible to voters who are blind.

a. The vendor shall conduct summative usability tests on the voting system using

individuals who are blind. The vendor shall document the testing performed and

report the test results using the Common Industry Format. This documentation shall

be included in the Technical Data Package submitted to the EAC for national

certification.

Discussion: Voting system developers are required to conduct realistic usability tests on

the final product. For the present, vendors can define their own testing

protocols. Future revisions to the Guidelines will include requirements for

usability testing that will provide specific performance benchmarks.

b. The accessible voting station shall provide an audio-tactile interface (ATI) that

supports the full functionality of the visual ballot interface, as specified in Subsection

2.3.3.

Discussion: Note the necessity of both audio output and tactilely discernible controls for

voter input. Full functionality includes at least:

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• Instructions and feedback on initial activation of the ballot (such as

insertion of a smart card), if this is normally performed by the voter on

comparable voting stations

• Instructions and feedback to the voter on how to operate the accessible

voting station, including settings and options (e.g., volume control,

repetition)
• Instructions and feedback for navigation of the ballot

• Instructions and feedback for contest choices, including write-in

candidates

• Instructions and feedback on confirming and changing selections

• Instructions and feedback on final submission of ballot

i. The ATI of the accessible voting station shall provide the same capabilities to

vote and cast a ballot as are provided by other voting machines or by the visual

interface of the standard voting machine.

Discussion: For example, if a visual ballot supports voting a straight party ticket and

then changing the choice in a single contest, so must the ATI.

ii. The ATI shall allow the voter to have any information provided by the voting

system repeated.

iii.The ATI shall allow the voter to pause and resume the audio presentation.

iv.The ATI shall allow the voter to skip to the next contest or return to previous

contests.

Discussion: This is analogous to the ability of sighted voters to move on to the next

contest once they have made a selection or to abstain from voting on a

contest altogether.

v. The ATI shall allow the voter to skip over the reading of a referendum so as to

be able to vote on it immediately.

Discussion: This is analogous to the ability of sighted voters to skip over the wording of

a referendum on which they have already made a decision prior to the

voting session (e.g., “Vote yes on proposition #123”).

c. All voting stations that provide audio presentation of the ballot shall conform to the

following requirements:

Discussion: These requirements apply to all voting machine audio output, not just to the

ATI of an accessible voting station.

i. The ATI shall provide its audio signal through an industry standard connector

for private listening using a 3.5mm stereo headphone jack to allow voters to use

their own audio assistive devices.

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ii. When a voting machine utilizes a telephone style handset or headphone to

provide audio information, it shall provide a wireless T-Coil coupling for

assistive hearing devices so as to provide access to that information for voters

with partial hearing. That coupling shall achieve at least a category T4 rating as

defined by American National Standard for Methods of Measurement of

Compatibility between Wireless Communications Devices and Hearing Aids,

ANSI C63.19.

iii.No voting equipment shall cause electromagnetic interference with assistive

hearing devices that would substantially degrade the performance of those

devices. The voting equipment, considered as a wireless device, shall achieve at

least a category T4 rating as defined by American National Standard for

Methods of Measurement of Compatibility between Wireless Communications

Devices and Hearing Aids, ANSI C63.19.

Discussion: "Hearing devices" include hearing aids and cochlear implants.
iv. A sanitized headphone or handset shall be made available to each voter.

Discussion: This requirement can be achieved in various ways, including the use of

"throwaway" headphones, or of sanitary coverings.

v. The voting machine shall set the initial volume for each voter between 40 and

50 dB SPL.

Discussion: A voter does not "inherit" the volume as set by the previous user of the

voting station.

vi.The voting machine shall provide a volume control with an adjustable volume

from a minimum of 20dB SPL up to a maximum of 100 dB SPL, in increments

no greater than 10 dB.

vii. The audio system shall be able to reproduce frequencies over the audible

speech range of 315 Hz to 10 KHz.

viii. The audio presentation of verbal information should be readily

comprehensible by voters who have normal hearing and are proficient in the

language. This includes such characteristics as proper enunciation, normal

intonation, appropriate rate of speech, and low background noise. Candidate

names should be pronounced as the candidate intends.

ix.The audio system shall allow voters to control the rate of speech. The range of

speeds supported should be at least 75% to 200% of the nominal rate.

Discussion: Many blind voters are accustomed to interacting with accelerated speech.

d. If the normal procedure is to have voters initialize the activation of the ballot, the

accessible voting station shall provide features that enable voters who are blind to

perform this activation.

Discussion: For example, smart cards might provide tactile cues so as to allow correct

insertion.

e. If the normal procedure is for voters to submit their own ballots, then the accessible

voting station shall provide features that enable voters who are blind to perform this

submission.

Discussion: For example, if voters normally feed their own optical scan ballots into a

reader, blind voters should also be able to do so.

f. All mechanically operated controls or keys on an accessible voting station shall be

tactilely discernible without activating those controls or keys.

g. On an accessible voting station, the status of all locking or toggle controls or keys

(such as the "shift" key) shall be visually discernible, and discernible either through

touch or sound.

3.2.3 Dexterity

The voting process shall be accessible to voters who lack fine motor control or use of their

hands.

a. The vendor shall conduct summative usability tests on the voting system using

individuals lacking fine motor control. The vendor shall document the testing

performed and report the test results using the Common Industry Format. This

documentation shall be included in the Technical Data Package submitted to the EAC

for national certification.

Discussion: Voting system developers are required to conduct realistic usability tests on

the final product. For the present, vendors can define their own testing

protocols. Future revisions to the Guidelines will include requirements for
usability testing that will provide specific performance benchmarks.

b. All keys and controls on the accessible voting station shall be operable with one hand

and shall not require tight grasping, pinching, or twisting of the wrist. The force

required to activate controls and keys shall be no greater 5 lbs. (22.2 N).

Discussion: Controls are to be operable without excessive force.

c. The accessible voting station controls shall not require direct bodily contact or for the

body to be part of any electrical circuit.

Discussion: This requirement ensures that controls are operable by individuals using

prosthetic devices.

d. The accessible voting station shall provide a mechanism to enable non-manual input

that is functionally equivalent to tactile input.

Discussion: This requirement ensures that the accessible voting station is operable by

individuals who do not have the use of their hands. All the functionality of

the accessible voting station (e.g., straight party voting, write-in candidates)

that is available through the other forms of input, such as tactile, must also

be available through a non-manual input mechanism if it is provided by the

accessible voting station.

e. If the normal procedure is for voters to submit their own ballots, then the accessible

voting station shall provide features that enable voters who lack fine motor control or

the use of their hands to perform this submission.

3.2.4 Mobility

The voting process shall be accessible to voters who use mobility aids, including

wheelchairs.

a. The accessible voting station shall provide a clear floor space of 30 inches (760 mm)

minimum by 48 inches (1220 mm) minimum for a stationary mobility aid. The clear

floor space shall be level with no slope exceeding 1:48 and positioned for a forward

approach or a parallel approach.

b. All controls, keys, audio jacks and any other part of the accessible voting station

necessary for the voter to operate the voting machine shall be within reach as

specified under the following sub-requirements:

Discussion: Note that these requirements have meaningful application mainly to

controls in a fixed location. A hand-held tethered control panel is another

acceptable way of providing reachable controls.

i. If the accessible voting station has a forward approach with no forward reach

obstruction then the high reach shall be 48 inches maximum and the low reach

shall be 15 inches minimum. See Figure 1.

ii. If the accessible voting station has a forward approach with a forward reach

obstruction, the following requirements apply (See Figure 2):

• The forward obstruction shall be no greater than 25 inches in depth, its top

no higher than 34 inches and its bottom surface no lower than 27 inches.

• If the obstruction is no more than 20 inches in depth, then the maximum

high reach shall be 48 inches, otherwise it shall be 44 inches.

iii.Space under the obstruction between the finish floor or ground and 9 inches

(230 mm) above the finish floor or ground shall be considered toe clearance and

shall comply with the following provisions:

• Toe clearance shall extend 25 inches (635 mm) maximum under the
obstruction

• The minimum toe clearance under the obstruction shall be either 17 inches

(430 mm) or the depth required to reach over the obstruction to operate the

accessible voting station, whichever is greater

• Toe clearance shall be 30 inches (760 mm) wide minimum

iv. Space under the obstruction between 9 inches (230 mm) and 27 inches (685

mm) above the finish floor or ground shall be considered knee clearance and

shall comply with the following provisions:

• Knee clearance shall extend 25 inches (635 mm) maximum under the

obstruction at 9 inches (230 mm) above the finish floor or ground.

• The minimum knee clearance at 9 inches (230 mm) above the finish floor

or ground shall be either 11 inches (280 mm) or 6 inches less than the toe

clearance, whichever is greater.

• Between 9 inches (230 mm) and 27 inches (685 mm) above the finish floor

or ground, the knee clearance shall be permitted to reduce at a rate of 1

inch (25 mm) in depth for each 6 inches (150 mm) in height.

Discussion: It follows that the minimum knee clearance at 27 inches above the finish

floor or ground shall be 3 inches less than the minimum knee clearance at 9

inches above the floor.

• Knee clearance shall be 30 inches (760 mm) wide minimum.

v. If the accessible voting station has a parallel approach with no side reach

obstruction then the maximum high reach shall be 48 inches and the minimum

low reach shall be 15 inches. See Figure 3.

vi. If the accessible voting station has a parallel approach with a side reach

obstruction, the following sub-requirements apply. See Figure 4.

• The side obstruction shall be no greater than 24 inches in depth and its top

no higher than 34 inches.

• If the obstruction is no more than 10 inches in depth, then the maximum

high reach shall be 48 inches, otherwise it shall be 46 inches.

Discussion: Since this is a parallel approach, no clearance under the obstruction is

required.

c. All labels, displays, controls, keys, audio jacks, and any other part of the accessible

voting station necessary for the voter to operate the voting machine shall be easily

legible and visible to a voter in a wheelchair with normal eyesight (no worse than

20/40, corrected) who is in an appropriate position and orientation with respect to the

accessible voting station

Discussion: There are a number of factors that could make relevant parts of the

accessible voting station difficult to see such as; small lettering, controls

and labels tilted at an awkward angle from the voter's viewpoint, and glare

from overhead lighting.

Figures 1-4

Figure 1

Unobstructed forward reach

Figure 2

Obstructed forward reach

(a) for an obstruction depth of up to 20 inches (508 mm)
(b) for an obstruction depth of up to 25 inches (635 mm)

Figure 3

Unobstructed side reach with an

allowable obstruction less than 10

inches (254 mm) deep.

Figure 4

Obstructed side reach

(a) for an obstruction depth of up to 10 inches (254 mm)

(b) for an obstruction depth of up to 24 inches (610 mm)

3.2.5 Hearing

The voting process shall be accessible to voters with hearing disabilities.

a. The accessible voting station shall incorporate the features listed under requirement

3.2.2.2 (c) for voting equipment that provides audio presentation of the ballot to

provide accessibility to voters with hearing disabilities.

Discussion: Note especially the requirements for volume initialization and control.

b. If voting equipment provides sound cues as a method to alert the voter, the tone shall

be accompanied by a visual cue, unless the station is in audio-only mode.

Discussion: For instance, the voting equipment might beep if the voter attempts to

overvote. If so, there would have to be an equivalent visual cue, such as the

appearance of an icon, or a blinking element. Some voting equipment may

have an audio-only mode, in which case, there would be no visual cue.

3.2.6 Speech

The voting process shall be accessible to voters with speech disabilities.

a. No voting equipment shall require voter speech for its operation.

Discussion: This does not preclude voting equipment from offering speech input as an

option, but speech must not be the only means of input.

3.2.7 English Proficiency

For voters who lack proficiency in reading English, or whose primary language is unwritten,

the voting equipment shall provide spoken instructions and ballots in the preferred language

of the voter, consistent with state and federal law. The requirements of 3.2.2.2 (c) shall apply

to this mode of interaction.

3.2.8 Cognition

The voting process should be accessible to voters with cognitive disabilities.

Discussion: At present there are no design features specifically aimed at helping those

with cognitive disabilities. Requirements 3.2.2.1 (f), the synchronization of

audio with the screen in a DRE, is helpful for some cognitive disabilities

such as dyslexia. Requirements in Subsection 3.1.4 also address cognitive

issues relative to voting system usability.

4 Hardware Requirements

Table of Contents
4 Hardware Requirements

4.1 Performance Requirements

4.1.1 Accuracy Requirements

4.1.2 Environmental Requirements 

4.1.2.1 Shelter Requirements

4.1.2.2 Space Requirements

4.1.2.3 Furnishings and Fixtures

4.1.2.4 Electrical Supply

4.1.2.5 Electrical Power Disturbance 

4.1.2.6 Electrical Fast Transient 

4.1.2.7 Lightning Surge 

4.1.2.8 Electrostatic Disruption 

4.1.2.9 Electromagnetic Emissions

4.1.2.10 Electromagnetic Susceptibility 

4.1.2.11 Conducted RF Immunity 

4.1.2.12 Magnetic Fields Immunity

4.1.2.13 Environmental Control - Operating Environment 

4.1.2.14 Environmental Control - Transit and Storage

4.1.2.15 Data Network Requirements

4.1.3 Election Management System Requirements

4.1.3.1 Recording Requirements 

4.1.3.2 Memory Stability 

4.1.4 Vote Recording Requirements 

4.1.4.1 Common Requirements 

4.1.4.2 Paper-based Recording Requirements

4.1.4.3 DRE System Recording Requirements

4.1.5 Paper-based Conversion Requirements

4.1.5.1 Ballot Handling

4.1.5.2 Ballot Reading Accuracy

4.1.6 Tabulation Processing Requirements 

4.1.6.1 Paper-based System Processing Requirements 

4.1.6.2 DRE System Processing Requirements 

4.1.7 Reporting Requirements

4.1.7.1 Removable Storage Media

4.1.7.2 Printers

4.1.8 Vote Data Management Requirements

4.1.8.1 Data File Management

4.1.8.2 Data Report Generation 

4.2 Physical Characteristics

4.2.1 Size 

4.2.2 Weight 

4.2.3 Transport and Storage of Precinct Systems

4.3 Design, Construction, and Maintenance Characteristics 

4.3.1 Materials, Processes, and Parts

4.3.2 Durability

4.3.3 Reliability 
4.3.4 Maintainability 

4.3.4.1 Physical Attributes

4.3.4.2 Additional Attributes 

4.3.5 Availability 

4.3.6 Product Marking

4.3.7 Workmanship 

4.3.8 Safety

4 Hardware Requirement

This section contains the requirements for the machines and manufactured devices that are

part of a voting system. It specifies minimum values for certain performance characteristics;

physical characteristics; and design, construction, and maintenance characteristics for the

hardware and selected related components of all voting systems, such as:

• Ballot printers

• Ballot cards and sheets

• Ballot displays

• Voting devices, including ballot marking devices and DRE recording devices

• Voting booths and enclosures

• Ballot boxes and ballot transfer boxes

• Ballot readers

• Computers used to prepare ballots, program elections, consolidate and report votes,

and perform other elections management activities

• Electronic ballot recorders

• Electronic precinct vote control units

• Removable electronic data storage media

• Servers

• Printers

This section applies to the combination of software and hardware to accomplish specific

performance and system control requirements. Standards that are specific to software alone

are provided in Section 5.

The requirements of this section apply generally to all hardware used in voting systems,

including:

• Hardware provided by the voting system vendor and its suppliers

• Hardware furnished by an external provider (for example, providers of commercialoffthe-shelf equipment) where the hardware may be used in any way during voting

system operation

• Hardware provided by the voting jurisdiction

The requirements presented in this section are organized as follows:

Performance Requirements: These requirements address the combined operational

capabilities of the voting system hardware and software across a broad range of

parameters

Physical Requirements: These requirements address the size, weight and

transportability of the voting system

Design, Construction, and Maintenance Requirements: These requirements address

the reliability and durability of materials, product marking, quality of system

workmanship, safety, and other attributes to ensure smooth system operation in the
voting environment

4.1 Performance Requirements

The performance requirements address a broad range of parameters, encompassing:

• Accuracy requirements, where requirements are specified for distinct processing

functions of paper-based and DRE systems

• Environmental requirements, where no distinction is made between requirements for

paper-based and DRE systems, but requirements for precinct and central count are

described

• Vote data management requirements, where no differentiation is made between

requirements for paper-based and DRE systems

• Vote recording requirements, where separate and distinct requirements are delineated

for paper-based and DRE systems

• Conversion requirements, which apply only to paper-based systems

• Processing requirements, where separate and distinct requirements are delineated for

paper-based and DRE systems

• Reporting requirements, where no distinction is made between requirements for

paper-based and DRE systems, but where differences between precinct and central

count systems are readily apparent based on differences of their reporting

The performance requirements include such attributes as ballot reading and handling

requirements; system accuracy; memory stability; and the ability to withstand specified

environmental conditions. These characteristics also encompass system-wide requirements

for shelter, electrical supply, and compatibility with data networks.

Performance requirements for voting systems represent the combined operational capability

of both system hardware and software. Accuracy, as measured by data error rate, and

operational failure are treated as distinct attributes in performance testing. All systems shall

meet the performance requirements under operating conditions and after storage under 

nonoperating

conditions.

4.1.1 Accuracy Requirements

Voting system accuracy addresses the accuracy of data for each of the individual ballot

positions that could be selected by a voter, including the positions that are not selected. For a

voting system, accuracy is defined as the ability of the system to capture, record, store,

consolidate and report the specific selections and absence of selections, made by the voter for

each ballot position without error. Required accuracy is defined in terms of an error rate that

for testing purposes represents the maximum number of errors allowed while processing a

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specified volume of data. This rate is set at a sufficiently stringent level that the likelihood of

voting system errors affecting the outcome of an election is exceptionally remote even in the

closest of elections.

The error rate is defined using a convention that recognizes differences in how vote data is

processed by different types of voting systems. Paper-based and DRE systems have different
processing steps. Some differences also exist between precinct count and central count

systems. Therefore, the acceptable error rate applies separately and distinctly to each of the

following functions:

a. For all paper-based voting systems:

i. Scanning ballot positions on paper ballots to detect selections for individual

candidates and contests

ii. Conversion of selections detected on paper ballots into digital data

b. For all DRE voting systems:

i. Recording the voter selections of candidates and contests into voting data storage

ii. Recording voter selections of candidates and contests into ballot image storage

independently from voting data storage

c. For precinct-count voting systems (paper-based and DRE):

i. Consolidation of vote selection data from multiple precinct-based voting

machines to generate jurisdiction-wide vote counts, including storage and

reporting of the consolidated vote data

d. For central-count voting systems (paper-based and DRE):

i. Consolidation of vote selection data from multiple counting devices to generate

jurisdiction-wide vote counts, including storage and reporting of the

consolidated vote data

For testing purposes, the acceptable error rate is defined using two parameters: the desired

error rate to be achieved, and the maximum error rate that should be accepted by the test

process.

For each processing function indicated above, the voting system shall achieve a target error

rate of no more than one in 10,000,000 ballot positions, with a maximum acceptable error

rate in the test process of one in 500,000 ballot positions.

4.1.2 Environmental Requirements

The environmental requirements for voting systems include shelter, space, furnishings and

fixtures, supplied energy, environmental control, and external telecommunications services.

Environmental conditions applicable to the design and operation of voting systems consist of

the following categories:

• Natural environment, including temperature, humidity, and atmospheric pressure

• Induced environment, including proper and improper operation and handling of the

system and its components during the election processes

• Transportation and storage

• Electromagnetic signal environment, including exposure to and generation of radio

frequency energy

All voting systems shall be designed to withstand the environmental conditions contained in

the appropriate test procedures of the Guidelines. These procedures will be applied to all

devices for casting, scanning and counting ballots, except those that constitute COTS devices

that have not been modified in any manner to support their use as part of a voting system and

that have a documented record of performance under conditions defined in the Guidelines.

The Technical Data Package supplied by the vendor shall include a statement of all

requirements and restrictions regarding environmental protection, electrical service,

recommended auxiliary power, telecommunications service, and any other facility or

resource required for the proper installation and operation of the system.
4.1.2.1 Shelter Requirements

All precinct count systems shall be designed for storage and operation in any enclosed

facility ordinarily used as a warehouse or polling place, with prominent instructions as to any

special storage requirements.

4.1.2.2 Space Requirements

There is no restriction on space allowed for the installation of voting systems, except that the

arrangement of these systems shall not impede performance of their duties by polling place

officials, the orderly flow of voters through the polling place or the ability for the voter to

vote in private.

4.1.2.3 Furnishings and Fixtures

Any furnishings or fixtures provided as a part of voting systems, and any components

provided by the vendor that are not a part of the voting system but that are used to support its

storage, transportation or operation, shall comply with the safety design of Subsection 4.3.8.

4.1.2.4 Electrical Supply

Components of voting systems that require an electrical supply shall meet the following

standards:

a. Precinct count voting systems shall operate with the electrical supply ordinarily found

in polling places (Nominal 120 Vac/60Hz/1 phase)

b. Central count voting systems shall operate with the electrical supply ordinarily found

in central tabulation facilities or computer room facilities (Nominal 120 Vac/60Hz/1,

nominal 208 Vac/60Hz/3 or nominal 240 Vac/60Hz/2)

c. All voting machines shall also be capable of operating for a period of at least 2 hours

on backup power, such that no voting data is lost or corrupted nor normal operations

interrupted. When backup power is exhausted the voting machine shall retain the

contents of all memories intact

The backup power capability is not required to provide lighting of the voting area.

4.1.2.5 Electrical Power Disturbance

Vote scanning and counting equipment for paper-based voting systems, and all DRE voting

equipment, shall be able to withstand, without disruption of normal operation or loss of data:

a. Voltage dip of 30% of nominal @10 ms;

b. Voltage dip of 60% of nominal @100 ms & 1 sec

c. Voltage dip of >95% interrupt @5 sec

d. Surges of +15% line variations of nominal line voltage

e. Electric power increases of 7.5% and reductions of 12.5% of nominal specified power

supply for a period of up to four hours at each power level

4.1.2.6 Electrical Fast Transient

Vote scanning and counting equipment for paper-based systems, and all DRE equipment,

shall be able to withstand, without disruption of normal operation or loss of data, electrical

fast transients of:
a. + 2 kV and - 2 kV on External Power lines (both AC and DC)

b. + 1 kV and - 1 kV on Input/Output lines(signal, data, and control lines) longer than 3

meters

c. Repetition Rate for all transient pulses will be 100 kHz

4.1.2.7 Lightning Surge

Vote scanning and counting equipment for paper-based systems, and all DRE equipment,

shall be able to withstand, without disruption of normal operation or loss of data, surges of:

a. +2 kV AC line to line

b. +2 kV AC line to earth

c. + or – 0.5 kV DC line to line >10m

d. + or – 0.5 kV DC line to earth >10m

e. +1 kV I/O sig/control >30m

4.1.2.8 Electrostatic Disruption

Vote scanning and counting equipment for paper-based systems, and all DRE equipment,

shall be able to withstand ±15 kV air discharge and ±8 kV contact discharge without damage

or loss of data. The equipment may reset or have momentary interruption so long as normal

operation is resumed without human intervention or loss of data. Loss of data means votes

that have been completed and confirmed to the voter.

4.1.2.9 Electromagnetic Emissions

Vote scanning and counting equipment for paper-based systems, and all DRE equipment,

shall comply with the Rules and Regulations of the Federal Communications Commission,

Part 15; Class B requirements for both radiated and conducted emissions.

4.1.2.10 Electromagnetic Susceptibility

Vote scanning and counting equipment for paper-based systems, and all DRE equipment,

shall be able to withstand an electromagnetic field of 10 V/m modulated by a 1 kHz 80% AM

modulation over the frequency range of 80 MHz to 1000 MHz, without disruption of normal

operation or loss of data.

4.1.2.11 Conducted RF Immunity

Vote scanning and counting equipment for paper-based systems, and all DRE equipment,

shall be able to withstand, without disruption of normal operation or loss of data, conducted

RF energy of:

a. 10V rms over the frequency range 150 KHz to 80 MHz with an 80% amplitude

modulation with a 1 KHz sine wave AC & DC power

b. 10V sig/control >3 m over the frequency range 150 KHz to 80 MHz with an 80%

amplitude modulation with a 1 KHz sine wave

4.1.2.12 Magnetic Fields Immunity

Vote scanning and counting equipment for paper-based systems, and all DRE equipment,

shall be able to withstand, without disruption of normal operation or loss of data, AC

magnetic fields of 30 A/m at 60 Hz.
4.1.2.13 Environmental Control - Operating Environment

Equipment used for election management activities or vote counting (including both precinct

and central count systems) shall be capable of operation in temperatures ranging from 50 to

95 degrees Fahrenheit.

4.1.2.14 Environmental Control - Transit and Storage

Equipment used for vote casting or for counting votes in a precinct count system, shall meet

these specific minimum performance standards that simulate exposure to physical shock and

vibration associated with handling and transportation by surface and air common carriers,

and to temperature conditions associated with delivery and storage in an uncontrolled

warehouse environment:

a. High and low storage temperatures ranging from -4 to +140 degrees Fahrenheit,

equivalent to MIL-STD-810D, Methods 501.2 and 502.2, Procedure I-Storage

b. Bench handling equivalent to the procedure of MIL-STD-810D, Method 516.3,

Procedure VI

c. Vibration equivalent to the procedure of MIL-STD-810D, Method 514.3, Category 1-

Basic Transportation, Common Carrier

d. Uncontrolled humidity equivalent to the procedure of MIL-STD-810D, Method

507.2, Procedure I-Natural Hot-Humid

4.1.2.15 Data Network Requirements

Voting systems may use a local or remote data network. If such a network is used, then all

components of the network shall comply with the telecommunications requirements

described in Section 6 and the Security requirements described in Section 7.

4.1.3 Election Management System Requirements

The Election Management System (EMS) requirements address electronic hardware and

software used to conduct the pre-voting functions defined in Section 2 with regard to ballot

preparation, election programming, ballot and program installation, readiness testing,

verification at the polling place, and verification at the central location.

4.1.3.1 Recording Requirements

Voting systems shall accurately record all election management data entered by the user,

including election officials or their designees.

For recording accuracy, all systems shall:

a. Record every entry made by the user

b. Add permissible voter selections correctly to the memory components of the device

c. Verify the correctness of detection of the user selections and the addition of the

selections correctly to memory

d. Add various forms of data entered directly by the election official or designee, such

as text, line art, logos, and images

e. Verify the correctness of detection of data entered directly by the user and the

addition of the selections correctly to memory

f. Preserve the integrity of election management data stored in memory against
corruption by stray electromagnetic emissions, and internally generated spurious

electrical signals

g. Log corrected data errors by the voting system

4.1.3.2 Memory Stability

Memory devices used to retain election management data shall have demonstrated error-free

data retention for a period of 22 months.

4.1.4 Vote Recording Requirements

The vote recording requirements address the enclosure, equipment, and supplies used by

voters to vote.

4.1.4.1 Common Requirements

All voting systems shall provide voting booths or enclosures for poll site use. Such booths or

enclosures may be integral to the voting system or supplied as components of the voting

system, and shall:

a. Be integral to, or make provision for, the installation of the voting machine

b. Ensure by its structure stability against movement or overturning during entry,

occupancy, and exit by the voter

c. Provide privacy for the voter, and be designed in such a way as to prevent observation

of the ballot by any person other than the voter

d. Be capable of meeting the accessibility requirements of Subsection 3.2

4.1.4.2 Paper-based Recording Requirements

The paper-based recording requirements govern:

• Ballot cards or sheets, and pages or assemblies of pages containing ballot field

identification data

• Ballot marking devices

• Frames or fixtures to hold the ballot while it is being marked

• Compartments or booths where voters record selections

• Secure containers for the collection of voted ballots

a. Paper ballots used by paper-based voting systems shall meet the following standards:

i. Marks that identify the unique ballot format shall be outside the area in which

votes are recorded, so as to minimize the likelihood that these marks will be

mistaken for vote responses and the likelihood that recorded votes will

obliterate these marks

ii. If printed alignment marks are used to locate the vote response fields on the

ballot, these marks shall be outside the area in which votes are recorded, so as

to minimize the likelihood that these marks will be mistaken for vote responses

and the likelihood that recorded votes will obliterate these marks

iii.The Technical Data Package shall specify the required paper stock, size, shape,

opacity, color, watermarks, field layout, orientation, size and style of printing,

size and location of mark fields used for vote response fields and to identify

unique ballot formats, placement of alignment marks, ink for printing, and

folding and bleed-through limitations for preparation of ballots that are
compatible with the system

b. The Technical Data Package shall specify marking devices, which, if used to make

the prescribed form of mark, produce readable marked ballots such that the system

meets the performance requirements for accuracy in Subsection 4.1.1. Marking

devices can be either manual (such as pens or pencils) or electronic. These

specifications shall identify:

i. Specific characteristics of marking devices that affect readability of marked

ballots

ii. Performance capabilities with regard to each characteristic

iii.For marking devices manufactured by multiple external sources, a listing of

sources and model numbers that are compatible with the system

c. A frame or fixture for printed ballot cards is optional. However, if such a device is

provided, it shall:

i. Be of any size and shape consistent with its intended use

ii. Position the card properly

iii.Hold the ballot card securely in its proper location and orientation for voting

iv. Comply with the requirements for design and construction contained in

Subsection 4.3

d. Ballot boxes and ballot transfer boxes, which serve as secure containers for the

storage and transportation of voted ballots, shall:

i. Be of any size, shape, and weight commensurate with their intended use

ii. Incorporate locks or seals, the specifications of which are described in the

system documentation

iii.Provide specific points where ballots are inserted, with all other points on the

box constructed in a manner that prevents ballot insertion

iv. For precinct count systems, contain separate compartments for the segregation

of unread ballots, ballots containing write-in votes or any irregularities that may

require special handling or processing. In lieu of compartments, the conversion

processing may mark such ballots with an identifying spot or stripe to facilitate

manual segregation

4.1.4.3 DRE System Recording Requirements

The DRE system recording requirements address the detection and recording of votes,

including the logic and data processing functions required to determine the validity of voter

selections, to accept and record valid selections, and to reject invalid selections. The

requirements also address the physical environment in which ballots are cast.

a. DRE systems shall include an audible or visible activity indicator providing the status

of each voting device. This indicator shall:

i. Indicate whether the device has been activated for voting

ii. Indicate whether the device is in use

b. To ensure vote recording accuracy and integrity while protecting the anonymity of the

voter, all DRE systems shall:

i. Contain all mechanical, electromechanical, and electronic components;

software; and controls required to detect and record the activation of selections

made by the voter in the process of voting and casting a ballot

ii. Incorporate redundant memories to detect and allow correction of errors caused
by the failure of any of the individual memories

iii.Provide at least two processes that record the voter’s selections that:

• To the extent possible, are isolated from each other

• Designate one process and associated storage location as the main vote

detection, interpretation, processing and reporting path

iv. Use a different process to store ballot images, for which the method of

recording may include any appropriate encoding or data compression procedure

consistent with the regeneration of an unequivocal record of the ballot as cast

by the voter

v. Provide a capability to retrieve ballot images in a form readable by humans

vi. Ensure that all processing and storage protects the anonymity of the voter

c. DRE systems shall meet the following requirements for recording accurately each

vote and ballot cast:

i. Detect every selection made by the voter

ii. Correctly add permissible selections to the memory components of the device

iii.Verify the correctness of the detection of the voter selections and the addition

of the selections to memory

iv. Achieve an error rate not to exceed the requirement indicated in Subsection

4.1.1

v. Preserve the integrity of voting data and ballot images (for DRE machines)

stored in memory for the official vote count and audit trail purposes against

corruption by stray electromagnetic emissions, and internally generated

spurious electrical signals

vi. Maintain a log of corrected data

Recording reliability refers to the ability of the DRE system to record votes accurately at its

maximum rated processing volume for a specified period of time. The DRE system shall

record votes reliably in accordance with the requirements of Subsection 4.3.3.

4.1.5 Paper-based Conversion Requirements

The paper-based conversion requirements address the ability of the system to read the ballot

card and to translate its pattern of marks into electronic signals for later processing. These

capabilities may be built into the voting system in an integrated fashion, or may be provided

by one or more components that are not unique to the system, such as a general purpose data

processing card reader or read head suitably interfaced to the system. These requirements

address two major functions: ballot handling and ballot reading.

4.1.5.1 Ballot Handling

Ballot handling consists of a ballot card’s acceptance, movement through the read station,

and transfer into a collection station or receptacle.

a. The capacity to convert the marks on individual ballots into signals is uniquely

important to central count systems. The capacity for a central count system shall be

documented by the vendor. This documentation shall include the capacity for

individual components that impact the overall capacity

b. When ballots are unreadable or some condition is detected requiring that the cards be

segregated from normally processed ballots for human review (e.g. write-ins), all

central count paper-based systems shall do one of the following:
i. Outstack the ballot

ii. Stop the ballot reader and display a message prompting the election official or

designee to remove the ballot

iii. Mark the ballot with an identifying mark to facilitate its later identification

c. Additionally, the system shall provide a capability that can be activated by an

authorized election official to identify ballots containing overvotes, blank ballots, and

ballots containing undervotes in a designated contest. If enabled, these capabilities

shall perform one of the above actions in response to the indicated condition.

d. When ballots are unreadable or when some condition is detected requiring that the

cards be segregated from normally processed ballots for human review (e.g. write-in

votes) all precinct count systems shall:

i. In response to an unreadable or blank ballot, return the ballot and provide a

message prompting the voter to examine the ballot

ii. In response to a ballot with a write-in vote, segregate the ballot or mark the

ballot with an identifying mark to facilitate its later identification

iii. In response to a ballot with an overvote the system shall:

• Provide a capability to identify an overvoted ballot

• Return the ballot

• Provide an indication prompting the voter to examine the ballot

• Allow the voter to correct the ballot

• Provide a means for an authorized election official to deactivate this

capability entirely and by contest

iv. In response to a ballot with an undervote, the system shall:

• Provide a capability to identify an undervoted ballot

• Return the ballot

• Provide an indication prompting the voter to examine the ballot

• Allow the voter to correct the ballot

• Allow the voter to submit the ballot with the undervote

• Provide a means for an authorized election official to deactivate this

capability

e. Ballot readers shall prevent multiple feed or detect and provide an alarm indicating

multiple feed. Multiple feed occurs when a ballot reader attempts to read more than

one ballot at a time.

i. If multiple feed is detected, the card reader shall halt in a manner that permits

the operator to remove the unread cards causing the error, and reinsert them in

the card input hopper

ii. The frequency of multiple feeds with ballots intended for use with the system

shall not exceed l in 10,000

4.1.5.2 Ballot Reading Accuracy

This paper-based system requirement governs the conversion of the physical ballot into

electronic data. Reading accuracy for ballot conversion refers to the ability to:

a. Recognize vote punches or marks, or the absence thereof, for each possible selection

on the ballot

b. Discriminate between valid punches or marks and extraneous perforations, smudges,

and folds
c. Convert the vote punches or marks, or the absence thereof, for each possible selection

on the ballot into digital signals

To ensure accuracy, paper-based systems shall:

d. Detect punches or marks that conform to vendor specifications with an error rate not

exceeding the requirement indicated in Subsection 4.1.1

e. Ignore, and not record, extraneous perforations, smudges, and folds

f. Reject ballots that meet all vendor specifications at a rate not to exceed 2 percent

4.1.6 Tabulation Processing Requirements

Tabulation processing requirements apply to the hardware and software required to

accumulate voting data for all candidates and measures within voting machines and polling

places, and to consolidate the voting data at a central level or multiple levels. These

requirements also address the generation and maintenance of audit records, the detection and

disabling of improper use or operation of the system, and the monitoring of overall system

status. Separate and distinct requirements for paper-based and DRE voting systems are

presented below.

4.1.6.1 Paper-based System Processing Requirements

The paper-based processing requirements address all mechanical devices, electromechanical

devices, electronic devices, and software required to perform the logical and numerical

functions of interpreting the electronic image of the voted ballot, and assigning votes to the

proper memory registers.

a. Processing accuracy refers to the ability of the system to receive electronic signals

produced by punches for punchcard systems and vote marks and timing information

for marksense systems; perform logical and numerical operations upon these data;

and reproduce the contents of memory when required, without error. Specific

requirements are detailed below:

i. Processing accuracy shall be measured by vote selection error rate, the ratio of

uncorrected vote selection errors to the total number of ballot positions that

could be recorded across all ballots when the system is operated at its nominal

or design rate of processing

ii. The vote selection error rate shall include data that denotes ballot style or

precinct as well as data denoting a vote in a specific contest or ballot

proposition

iii. The vote selection error rate shall include all errors from any source

iv. The vote selection error rate shall not exceed the requirement indicated in

Subsection 4.1.1

b. Paper-based system memory devices, used to retain control programs and data, shall

have demonstrated error-free data retention for a period of 22 months, under the

environmental conditions for operation and non-operation (i.e., storage).

4.1.6.2 DRE System Processing Requirements

The DRE voting systems processing requirements address all mechanical devices,

electromechanical devices, electronic devices, and software required to process voting data

after the polls are closed.
a. DRE voting systems shall meet the following requirements for processing speed:

i. Operate at a speed sufficient to respond to any operator and voter input without

perceptible delay (no more than three seconds)

ii. If the consolidation of polling place data is done locally, perform this

consolidation in a time not to exceed five minutes for each device in the polling

place

b. Processing accuracy is defined as the ability of the system to process voting data

stored in DRE voting devices or in removable memory modules installed in such

devices. Processing includes all operations to consolidate voting data after the polls

have been closed. DRE voting systems shall:

i. Produce reports that are completely consistent, with no discrepancy among

reports of voting device data produced at any level

ii. Produce consolidated reports containing absentee, provisional or other voting

data that are similarly error-free. Any discrepancy, regardless of source, is

resolvable to a procedural error, to the failure of a non-memory device or to an

external cause

c. DRE system memory devices used to retain control programs and data shall have

demonstrated error-free data retention for a period of 22 months. Error-free retention

may be achieved by the use of redundant memory elements, provided that the

capability for conflict resolution or correction among elements is included.

4.1.7 Reporting Requirements

The reporting requirements govern all mechanical, electromechanical, and electronic devices

required for voting systems to print audit record entries and results of the tabulation. These

requirements also address data storage media for transportation of data to other sites.

4.1.7.1 Removable Storage Media

In voting systems that use storage media that can be removed from the system and

transported to another location for readout and report generation, these media shall use

devices with demonstrated error-free retention for a period of 22 months under the

environmental conditions for operation and non-operation contained in Subsection 4.1.2.

Examples of removable storage media include: programmable read-only memory (PROM),

random access memory (RAM) with battery backup, magnetic media or optical media.

4.1.7.2 Printers

All printers used to produce reports of the vote count shall be capable of producing:

a. Alphanumeric headers

b. Election, office and issue labels

c. Alphanumeric entries generated as part of the audit record

4.1.8 Vote Data Management Requirements

The vote data management requirements for all systems address capabilities that manage,

process, and report voting data after the data has been consolidated at the polling place or

other jurisdictional levels.

These capabilities allow the system to:
• Consolidate voting data from polling place data memory or transfer devices

• Report polling place summaries

• Process absentee ballots, data entered manually, and administrative ballot definition

data

The requirements address all hardware and software required to generate output reports in the

various formats required by the using jurisdiction.

4.1.8.1 Data File Management

All voting systems shall provide the capability to:

a. Integrate voting data files with ballot definition files

b. Verify file compatibility

c. Edit and update files as required

4.1.8.2 Data Report Generation

All voting systems shall include report generators for producing output reports at the device,

polling place, and summary level, with provisions for administrative and judicial

subdivisions as required by the using jurisdiction.

4.2 Physical Characteristics

This subsection covers physical characteristics of all voting systems and components that

affect their general utility and suitability for election operations.

4.2.1 Size

There is no numerical limitation on the size of any voting equipment, but the size of each

voting machine should be compatible with its intended use and the location at which the

equipment is to be used.

4.2.2 Weight

There is no numerical limitation on the weight of any voting equipment, but the weight of

each voting machine should be compatible with its intended use and the location at which the

equipment is to be used.

4.2.3 Transport and Storage of Precinct Systems

All precinct voting systems shall:

a. Provide a means to safely and easily handle, transport, and install voting equipment,

such as wheels or a handle or handles

b. Be capable of using, or be provided with, a protective enclosure rendering the

equipment capable of withstanding:

i. Impact, shock and vibration loads associated with surface and air transportation

ii. Stacking loads associated with storage

4.3 Design, Construction, and Maintenance Characteristics

This subsection covers voting system materials, construction workmanship, and specific

design characteristics important to the successful operation and efficient maintenance of the
voting system.

4.3.1 Materials, Processes, and Parts

The approach to system design is unrestricted, and may incorporate any form or variant of

technology capable of meeting the voting systems requirements and standards.

Precinct count systems shall be designed in accordance with best commercial practice for

microcomputers, process controllers, and their peripheral components. Central count voting

systems and equipment used in a central tabulating environment shall be designed in

accordance with best commercial and industrial practice.

All voting systems shall:

a. Be designed and constructed so that the frequency of equipment malfunctions and

maintenance requirements are reduced to the lowest level consistent with cost

constraints

b. Include, as part of the accompanying Technical Data Package, an approved parts list

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c. Exclude parts or components not included in the approved parts list

4.3.2 Durability

All voting systems shall be designed to withstand normal use without deterioration and

without excessive maintenance cost for a period of ten years.

4.3.3 Reliability

The reliability of voting system devices shall be measured as Mean Time Between Failure

(MTBF) for the system submitted for testing. MBTF is defined as the value of the ratio of

operating time to the number of failures which have occurred in the specified time interval. A

typical system operations scenario consists of approximately 45 hours of equipment

operation, consisting of 30 hours of equipment set-up and readiness testing and 15 hours of

elections operations. For the purpose of demonstrating compliance with this requirement, a

failure is defined as any event which results in either the:

• Loss of one or more functions

• Degradation of performance such that the device is unable to perform its intended

function for longer than 10 seconds

The MTBF demonstrated during certification testing shall be at least 163 hours.

4.3.4 Maintainability

Maintainability represents the ease with which maintenance actions can be performed based

on the design characteristics of equipment and software and the processes the vendor and

election officials have in place for preventing failures and for reacting to failures.

Maintainability includes the ability of equipment and software to self-diagnose problems and

make non-technical election workers aware of a problem. Maintainability addresses all

scheduled and unscheduled events, which are performed to:

• Determine the operational status of the system or a component

• Adjust, align, tune or service components
• Repair or replace a component having a specified operating life or replacement

interval

• Repair or replace a component that exhibits an undesirable predetermined physical

condition or performance degradation

• Repair or replace a component that has failed

• Verify the restoration of a component or the system to operational status

Maintainability shall be determined based on the presence of specific physical attributes that

aid system maintenance activities, and the ease with which system maintenance tasks can be

performed by the test lab. Although a more quantitative basis for assessing maintainability,

such as the Mean Time to Repair the system is desirable, the certification of a system is

conducted before it is approved for sale and thus before a broader base of maintenance

experience can be obtained.

4.3.4.1 Physical Attributes

The following physical attributes will be examined to assess reliability:

a. Presence of labels and the identification of test points

b. Provision of built-in test and diagnostic circuitry or physical indicators of condition

c. Presence of labels and alarms related to failures

d. Presence of features that allow non-technicians to perform routine maintenance

tasks (such as update of the system database)

4.3.4.2 Additional Attributes

The following additional attributes will be considered to assess system maintainability:

a. Ease of detecting that equipment has failed by a non-technician

b. Ease of diagnosing problems by a trained technician

c. Low false alarm rates (i.e., indications of problems that do not exist)

d. Ease of access to components for replacement

e. Ease with which adjustment and alignment can be performed

f. Ease with which database updates can be performed by a non-technician

g. Adjust, align, tune or service components

4.3.5 Availability

The availability of a voting system is defined as the probability that the equipment (and

supporting software) needed to perform designated voting functions will respond to

operational commands and accomplish the function. The voting system shall meet the

availability standard for each of the following voting functions:

a. For all paper-based systems:

i. Recording voter selections (such as by ballot marking or punch)

ii. Scanning the punches or marks on paper ballots and converting them into

digital data

b. For all DRE systems, recording and storing voter ballot selections

c. For precinct count systems (paper-based and DRE), consolidation of vote selection

data from multiple precinct based systems to generate jurisdiction-wide vote counts,

including storage and reporting of the consolidated vote data

d. For central-count systems (paper-based and DRE), consolidation of vote selection
data from multiple counting devices to generate jurisdiction-wide vote counts,

including storage and reporting of the consolidated vote data

System availability is measured as the ratio of the time during which the system is

operational (up time) to the total time period of operation (up time plus down time). Inherent

availability (Ai) is the fraction of time a system is functional, based upon Mean Time

Between Failure (MTBF) and Mean Time To Repair (MTTR), that is:

Ai = (MTBF)/(MTBF + MTTR)

MTTR is the average time required to perform a corrective maintenance task during periods

of system operation. Corrective maintenance task time is active repair time, plus the time

attributable to other factors that could lead to logistic or administrative delays, such as travel

notification of qualified maintenance personnel and travel time for such personnel to arrive at

the appropriate site.

Corrective maintenance may consist of substitution of the complete device or one of its

components, as in the case of precinct count and some central count systems, or it may

consist of on-site repair.

The voting system shall achieve at least 99 percent availability during normal operation for

the functions indicated above. This standard encompasses for each function the combination

of all devices and components that support the function, including their MTTR and MTBF

attributes.

Vendors shall specify the typical system configuration that is to be used to assess availability,

and any assumptions made with regard to any parameters that impact the MTTR. These

factors shall include at a minimum:

e. Recommended number and locations of spare devices or components to be kept on

hand for repair purposes during periods of system operation

f. Recommended number and locations of qualified maintenance personnel who need to

be available to support repair calls during system operation

g. Organizational affiliation (i.e., jurisdiction, vendor) of qualified maintenance

personnel

4.3.6 Product Marking

All voting systems shall:

a. Identify all devices by means of a permanently affixed nameplate or label containing

the name of the manufacturer or vendor, the name of the device, its part or model

number, its revision letter, its serial number, and if applicable, its power requirements

b. Display on each device a separate data plate containing a schedule for and list of

operations required to service or to perform preventive maintenance

c. Display advisory caution and warning instructions to ensure safe operation of the

equipment and to avoid exposure to hazardous electrical voltages and moving parts at

all locations where operation or exposure may occur

4.3.7 Workmanship

To help ensure proper workmanship, all manufacturers of voting systems shall:

a. Adopt and adhere to practices and procedures to ensure that their products are free

from damage or defect that could make them unsatisfactory for their intended purpose

b. Ensure that components provided by external suppliers are free from damage or

defect that could make them unsatisfactory for their intended purpose
4.3.8 Safety

All voting systems shall meet the following requirements for safety:

a. All voting systems and their components shall be designed to eliminate hazards to

personnel or to the equipment itself

b. Defects in design and construction that can result in personal injury or equipment

damage must be detected and corrected before voting systems and components are

placed into service

c. Equipment design for personnel safety shall be equal to or better than the appropriate

requirements of the Occupational Safety and Health Act, Code of Federal

Regulations, Title 29, Part 1910

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5 Software Requirements

Table of Contents

5 Software Requirements

5.1 Scope

5.1.1 Software Sources 

5.1.2 Management of Software and Hardware 

5.1.3 Exclusions

5.2 Software Design and Coding Standards

5.2.1 Selection of Programming Languages

5.2.2 Software Integrity

5.2.3 Software Modularity and Programming

5.2.4 Control Constructs

5.2.5 Naming Conventions 

5.2.6 Coding Conventions 

5.2.7 Comment Conventions 

5.3 Data and Document Retention 

5.4 Audit Record Data 

5.4.1 Pre-election Audit Records

5.4.2 System Readiness Audit Records

5.4.3 In-process Audit Records 

5.4.4 Vote Tally Data 

5.5 Vote Secrecy on DRE Systems 

5 Software Requirements

5.1 Scope

This section describes essential design and performance characteristics of the software used

in voting systems, addressing both system level software, such as operating systems, and

voting system application software, including firmware. The requirements of this section are
intended to ensure that voting system software is reliable, robust, testable, and maintainable.

The requirements in this section also support system accuracy, logical correctness, privacy,

security and integrity.

The general requirements of this section apply to software used to support the entire range of

voting system activities described in Section 2. More specific requirements are defined for

ballot counting, vote processing, creating an audit trail, and generating output reports and

files. Although this section emphasizes software, the guidelines described also influence

hardware design considerations.

This section recognizes that there is no best way to design software. Many programming

languages are available for which modern programming practices are applicable, such as the

use of rigorous program and data structures, data typing, and naming conventions. Other

programming languages exist for which such practices are not easily applied.

The Guidelines are intended to guide the design of software written in any of the

programming languages commonly used for mainframe, mini-computer, and microprocessor

systems. They are not intended to preclude the use of other languages or environments, such

as those that exhibit declarative structure, object-oriented languages, functional programming

languages, or any other combination of language and implementation that provides

appropriate levels of performance, testability, reliability, and security. The vendor makes

specific software selections. However, the use of widely recognized and proven software

design methods will facilitate the analysis and testing of voting system software in the

certification process.

5.1.1 Software Sources

The requirements of this section apply generally to all software used in voting systems,

including:

• Software provided by the voting system vendor and its component suppliers

• Software furnished by an external provider (for example, providers of COTS

operating systems and web browsers) where the software may be used in any way

during voting system operation

• Software developed by the voting jurisdiction

Compliance with the software requirements is assessed by several formal tests, including

code examination. Unmodified software is not subject to code examination; however, source

code provided by third parties and embedded in software modules for compilation or

interpretation shall be provided in human readable form to the accredited test lab. The

accredited test lab may inspect source code units to determine testing requirements or to

verify that the code is unmodified and that the default configuration options have not been

changed.

Configuration of software, both operating systems and applications, is critical to proper

system functioning. Correct test design and sufficient test execution must account for the

intended and proper configuration of all system components. Therefore, the vendors shall

submit a record of all user selections made during software installation as part of the

Technical Data Package. The vendor shall also submit a record of all configuration changes

made to the software following its installation. The accredited test lab shall confirm the

propriety and correctness of these user selections and configuration changes.
5.1.2 Management of Software and Hardware

The requirements of this section apply to all software used in any manner to support any

voting-related activities, regardless of the ownership of the software or the ownership and

location of the hardware on which the software is installed or operates. These requirements

apply to:

• Software that operates on voting devices and vote counting devices installed at

polling places under the control of the voting jurisdiction

• Software that operates on ballot printers, vote counting devices, and other hardware

typically installed at central or precinct locations (including contractor facilities)

• Election management software

However, some requirements apply only in specific situations indicated in this section. In

addition to the requirements of this section, all software used in any manner to support any

voting-related activities shall meet the requirements for security described in Section 7.

5.1.3 Exclusions

Some voting systems use computers that also may be used for other purposes. General

purpose software such as operating systems, programming language compilers, database

management systems, and Web browsers may be installed on these computers. Such software

is governed by the Guidelines unless:

a. The software provides no support of voting system capabilities

b. The software is removable, disconnectable or switchable such that it cannot function

while voting system functions are enabled

c. Procedures are provided that confirm that the software has been removed,

disconnected or switched

5.2 Software Design and Coding Standards

The software used by voting systems is selected by the vendor and not prescribed by the

Guidelines. This section provides requirements for voting system software with regard to:

• Selection of programming languages

• Software integrity

• Software modularity and programming

• Control constructs

• Naming conventions

• Coding conventions

• Comment conventions

5.2.1 Selection of Programming Languages

Software associated with the logical and numerical operations of vote data shall use a highlevel

programming language, such as: Pascal, Visual Basic, Java, C and C++. The

requirement for the use of high-level language for logical operations does not preclude the

use of assembly language for hardware-related segments, such as device controllers and

handler programs. Also, operating system software may be designed in assembly language.
5.2.2 Software Integrity

Self-modifying, dynamically loaded or interpreted code is prohibited, except under the

security provisions outlined in Subsection 7.4. This prohibition is to ensure that the software

tested and approved during the certification process remains unchanged and retains its

integrity. External modification of code during execution shall be prohibited. Where the

development environment (programming language and development tools) includes the

following features, the software shall provide controls to prevent accidental or deliberate

attempts to replace executable code:

a. Unbounded arrays or strings (includes buffers used to move data)

b. Pointer variables

c. Dynamic memory allocation and management

5.2.3 Software Modularity and Programming

Voting system application software, including commercial off-the-shelf (COTS) software,

shall be designed in a modular fashion. However, COTS software is not required to be

inspected for compliance with this requirement. For the purpose of this requirement1,

“modules” may be compiled or interpreted independently. Modules may also be nested. The

modularity rules described here apply to the component sub-modules of a library. The

principle to be followed is that the module contains all the elements to compile or interpret

successfully and has limited access to data in other modules. The design concept is simple

replacement with another module whose interfaces match the original module. A module is

designed in accordance with the rules below.

a. Each module shall have a specific function that can be tested and verified

independently of the remainder of the code. In practice, some additional modules

(such as library modules) may be needed to compile the module under test, but the

modular construction allows the supporting modules to be replaced by special test

versions that support test objectives.

b. Each module shall be uniquely and mnemonically named, using names that differ by

more than a single character. In addition to the unique name, the modules shall

include a set of header comments identifying the module’s purpose, design,

conditions, and version history, followed by the operational code. Headers are

optional for modules of fewer than ten executable lines where the subject module is

embedded in a larger module that has a header containing the header information.

Library modules shall also have a header comment describing the purpose of the

library and version information.

c. All required resources, such as data accessed by the module, should either be

contained within the module or explicitly identified as input or output to the module.

Within the constraints of the programming language, such resources shall be placed at

the lowest level where shared access is needed. If that shared access level is across

multiple modules, the definitions should be defined in a single file (called header files

in some languages, such as C) where any changes can be applied once and the change

automatically applies to all modules upon compilation or activation.

d. A module is small enough to be easy to follow and understand. Program logic

visible on a single page is easy to follow and correct. Volume II, Section 5 provides

testing guidelines for the accredited test lab to identify large modules subject to

review under this requirement.
e. Each module shall have a single entry point, and a single exit point, for normal

process flow. For library modules or languages such as the object-oriented

languages, the entry point is to the individual contained module or method invoked.

The single exit point is the point where control is returned. At that point, the data that

1 Some software languages and development environments use a different definition of module but this

principle still applies.

is expected as output must be appropriately set. The exception for the exit point is

where a problem is so severe that execution cannot be resumed. In this case, the

design must explicitly protect all recorded votes and audit log information and must

implement formal exception handlers provided by the language.

f. Process flow within the modules shall be restricted to combinations of the control

structures defined in Volume II, Section 5. These structures support the modular

concept, especially the single entry and exit rule above. They apply to any language

feature where program control passes from one activity to the next, such as control

scripts, object methods or sets of executable statements, even though the language

itself is not procedural

5.2.4 Control Constructs

Voting system software shall use the control constructs identified in Volume II, Section 5:

a. Acceptable constructs are Sequence, If-Then-Else, Do-While, Do-Until, Case, and the

General Loop (including the special case for loop).

i. If the programming language used does not provide these control constructs,

the vendor shall provide comparable control structure logic. The constructs

shall be used consistently throughout the code. No other constructs shall be

used to control program logic and execution.

ii. While some programming languages do not create programs as linear

processes, stepping from an initial condition through changes to a conclusion,

the program components nonetheless contain procedures (such as “methods” in

object-oriented languages). Even in these programming languages, the

procedures must execute through these control constructs or their equivalents,

as defined and provided by the vendor.

iii.Operator intervention or logic that evaluates received or stored data shall not redirect

program control within a program routine. Program control may be redirected

within a routine by calling subroutines, procedures, and functions, and

by interrupt service routines and exception handlers (due to abnormal error

conditions). Do-While (False) constructs and intentional exceptions (used as

GoTos) are prohibited.

5.2.5 Naming Conventions

Voting system software shall use the naming conventions below.

a. Object, function, procedure, and variable names shall be chosen to enhance the

readability and intelligibility of the program. Insofar as possible, names shall be

selected so that their parts of speech represent their use, such as nouns to represent

objects and verbs to represent functions.

b. Names used in code and in documentation shall be consistent.

c. Names shall be unique within an application. Names shall differ by more than a
single character. All single-character names are forbidden except those for variables

used as loop indexes. In large systems where subsystems tend to be developed

independently, duplicate names may be used where the scope of the name is unique

within the application. Names should always be unique where modules are shared.

d. Language keywords shall not be used as names of objects, functions, procedures,

variables or in any manner not consistent with the design of the language.

5.2.6 Coding Conventions

Voting system software shall adhere to basic coding conventions. The coding conventions

used shall meet one of the following conditions:

a. The vendors shall identify the published, reviewed, and industry-accepted coding

conventions used and the accredited test lab shall test for compliance

b. The accredited test lab shall evaluate the code using the coding convention

requirements specified in Volume II, Section 5

These guidelines reference conventions that protect the integrity and security of the code,

which may be language-specific and language-independent conventions that

significantly contribute to readability and maintainability. Specific style conventions

that support economical testing are not binding unless adopted by the vendor.

5.2.7 Comment Conventions

Voting system software shall use the following comment conventions:

a. All modules shall contain headers. For small modules of 10 lines or less, the header

may be limited to identification of unit and revision information. Other header

information should be included in the small unit headers if not clear from the actual

lines of code. Header comments shall provide the following information:

i. The purpose of the unit and how it works

ii. Other units called and the calling sequence

iii.A description of input parameters and outputs

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iv. File references by name and method of access (i.e., read, write, modify or

append)

v. Global variables used

vi. Date of creation and a revision record

b. Descriptive comments shall be provided to identify objects and data types. All

variables shall have comments at the point of declaration clearly explaining their use.

Where multiple variables that share the same meaning are required, the variables may

share the same comment

c. In-line comments shall be provided to facilitate interpretation of functional

operations, tests, and branching

d. Assembly code shall contain descriptive and informative comments such that its

executable lines can be clearly understood

e. All comments shall be formatted in a uniform manner that makes it easy to

distinguish them from executable code
5.3 Data and Document Retention

All systems shall:

a. Maintain the integrity of voting and audit data during an election, and for at least 22

months thereafter, a time sufficient to resolve most contested elections and support

other activities related to the reconstruction and investigation of a contested election

b. Protect against the failure of any data input or storage device at a location controlled

by the jurisdiction or its contractors, and against any attempt at improper data entry or

retrieval

5.4 Audit Record Data

Audit trails are essential to ensure the integrity of a voting system. Operational requirements

for audit trails are described in Subsection 2.5.1.1. Audit record data are generated by these

procedures. The audit record data in the following subsections are essential to the complete

recording of election operations and reporting of the vote tally. This list of audit records may

not reflect the design constructs of some systems. Therefore, vendors shall supplement it

with information relevant to the operation of their specific systems.

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5.4.1 Pre-election Audit Records

During election definition and ballot preparation, the system shall audit the preparation of the

baseline ballot formats and modifications to them, a description of these modifications, and

corresponding dates.

The log shall include:

a. The allowable number of selections a contest

b. The combinations of voting patterns permitted or required by the jurisdiction

c. The inclusion or exclusion of contests as the result of multiple districting within the

polling place

d. Any other characteristics that may be peculiar to the jurisdiction, the election or the

polling place location

e. Manual data maintained by election personnel

f. Samples of all final ballot formats

g. Ballot preparation edit listings

5.4.2 System Readiness Audit Records

The following minimum requirements apply to system readiness audit records:

a. Prior to the start of ballot counting, a system process shall verify hardware and

software status and generate a readiness audit record. This record shall include the

identification of the software release, the identification of the election to be

processed, and the results of software and hardware diagnostic tests

b. In the case of systems used at the polling place, the record shall include polling place

identification

c. The ballot interpretation logic shall test and record the correct installation of ballot

formats on voting devices

d. The software shall check and record the status of all data paths and memory locations

to be used in vote recording to protect against contamination of voting data

e. Upon the conclusion of the tests, the software shall provide evidence in the audit
record that the test data have been expunged

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f. If required and provided, the ballot reader and arithmetic-logic unit shall be evaluated

for accuracy, and the system shall record the results. It shall allow the processing or

simulated processing of sufficient test ballots to provide a statistical estimate of

processing accuracy

g. For systems that use a public network, provide a report of test ballots that includes:

i. Number of ballots sent

ii. When each ballot was sent

iii.Machine from which each ballot was sent

iv. Specific votes or selections contained in the ballot

5.4.3 In-process Audit Records

In-process audit records document system operations during diagnostic routines and the

casting and tallying of ballots. At a minimum, the in-process audit records shall contain:

a. Machine generated error and exception messages to demonstrate successful recovery.

Examples include, but are not necessarily limited to:

i. The source and disposition of system interrupts resulting in entry into exception

handling routines

ii. All messages generated by exception handlers

iii.The identification code and number of occurrences for each hardware and

software error or failure

iv. Notification of system login or access errors, file access errors, and physical

violations of security as they occur, and a summary record of these events after

processing

v. Other exception events such as power failures, failure of critical hardware

components, data transmission errors or other types of operating anomalies

b. Critical system status messages other than informational messages displayed by the

system during the course of normal operations. These items include, but are not

limited to:

i. Diagnostic and status messages upon startup

ii. The “zero totals” check conducted before opening the polling place or counting

a precinct centrally

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iii.For paper-based systems, the initiation or termination of card reader and

communications equipment operation

iv. For DRE machines at controlled voting locations, the event (and time, if

available) of activating and casting each ballot (i.e., each voter's transaction as

an event). This data can be compared with the public counter for reconciliation

purposes

c. Non-critical status messages that are generated by the machine's data quality monitor

or by software and hardware condition monitors
d. System generated log of all normal process activity and system events that require

operator intervention, so that each operator access can be monitored and access

sequence can be constructed

5.4.4 Vote Tally Data

In addition to the audit requirements described above, other election-related data is essential

for reporting results to interested parties, the press, and the voting public, and is vital to

verifying an accurate count.

Voting systems shall meet these reporting requirements by providing software capable of

obtaining data concerning various aspects of vote counting and producing printed reports. At

a minimum, vote tally data shall include:

a. Number of ballots cast, using each ballot configuration, by tabulator, by precinct, and

by political subdivision

b. Candidate and measure vote totals for each contest, by tabulator

c. The number of ballots read within each precinct and for additional jurisdictional

levels, by configuration, including separate totals for each party in primary elections

d. Separate accumulation of overvotes and undervotes for each contest, by tabulator,

precinct and for additional jurisdictional levels (no overvotes would be indicated for

DRE voting devices)

e. For paper-based systems only, the total number of ballots both able to be processed

and unable to be processed; and if there are multiple card ballots, the total number of

cards read

For systems that produce an electronic file containing vote tally data, the contents of the file

shall include the same minimum data cited above for printed vote tally reports.

5.5 Vote Secrecy on DRE Systems

All DRE systems shall ensure vote secrecy by:

a. Immediately after the voter chooses to cast his or her ballot, record the voter’s

selections in the memory to be used for vote counting and audit data (including ballot

images), and erase the selections from the display, memory, and all other storage,

including all forms of temporary storage

b.Immediately after the voter chooses to cancel his or her ballot, erase the selections

from the display and all other storage, including buffers and other temporary storage

6 Telecommunications Requirements

Table of Contents

6 Telecommunications Requirements

6.1 Scope

6.1.1 Types of Components

6.1.2 Telecommunications Operations and Providers

6.1.3 Data Transmission 

6.2 Design, Construction, and Maintenance Requirements 

6.2.1 Accuracy

6.2.2 Durability
6.2.3 Reliability 

6.2.4 Maintainability 

6.2.5 Availability 

6.2.6 Integrity 

6.2.7 Confirmation

6 Telecommunications Requirements

6.1 Scope

This section contains the performance, design, and maintenance characteristics of the

telecommunications components of voting systems and the acceptable levels of performance

against these characteristics. For the purpose of the Guidelines, telecommunications is

defined as the capability to transmit and receive data electronically using hardware and

software components over distances both within and external to a polling place.

The requirements in this section represent acceptable levels of combined telecommunications

hardware and software function and performance for the transmission of data that is used to

operate the system and report election results. Where applicable, this section specifies

minimum values for critical performance and functional attributes involving

telecommunications hardware and software components.

This section does not apply to other means of moving data, such as the physical transport of

data recorded on paper-based media or the transport of physical devices, such as memory

cards, that store data in electronic form.

Voting systems may include network hardware and software to transfer data among systems.

Major network components are local area networks (LANs), wide area networks (WANs),

workstations (desktop computers), servers, data, and applications. Workstations include

voting stations, precinct tabulation systems, and voting supervisory terminals. Servers

include systems that provide registration forms and ballots and accumulate and process voter

registrations and cast ballots.

Desirable network characteristics include simplicity, flexibility (especially in routing, to

maintain good response times) and maintainability (including availability, provided primarily

through redundancy of resources and connections, particularly of connections to public

infrastructure).

A wide area network (WAN) public telecommunications component consists of the hardware

and software to transport information, over shared public (i.e., commercial or governmental)

circuitry or among private systems. For voting systems, the telecommunications boundaries

are defined as the transport circuitry, on one side of which exists the public

telecommunications infrastructure, outside the control of voting system supervisors. On the

other side of the transport circuitry are the local area network (LAN) resources, workstations,

servers, data and applications controlled by voting system supervisors.

Local area network (LAN) components consist of the hardware and software infrastructure

used to transport information between users in a local environment, typically a building or
group of buildings. Typically a LAN connects workstations with a local server.

An application may be a single program or a group of programs that work together to provide

a function to an end user, who may be a voter or an election administrator. Voter programs

may include voter registration, balloting, and status checking. Administrator programs may

include ballot preparation, registration for preparation, registration approval, ballot vetting,

ballot processing, and election processing.

This section is intended to complement the network security requirements found in Section 7,

which include requirements for voter and administrator access, availability of network

service, data confidentiality, and data integrity. Most importantly, security services must

restrict access to local election system components from public resources, and these services

must also restrict access to voting system data while it is in transit through public networks.

6.1.1 Types of Components

This section addresses telecommunications hardware and software across a broad range of

technologies including, but not limited to:

• Dial-up communications technologies including standard landline, wireless,

microwave, Very Small Aperture Terminal, Integrated Services Digital Network,

Digital Subscriber Line

• Public and private high-speed telecommunications lines including FT-1, T-1, T-3;

frame relay; private line

• Cabling technologies including Universal Twisted Pair cable (CAT 5 or higher) or

Ethernet hub/switch

• Wireless including radio frequency and infrared

• Communications routers

• Modems, whether internal and external to personal computers, servers, and other

voting system components installed at the polling place or central count location

• Modem drivers, dial-up networking software

• Channel service units and Data service units installed at the polling place or central

count location

• Dial-up networking applications software

6.1.2 Telecommunications Operations and Providers

This section applies to voting-related transmissions over public networks, such as those

provided by local distribution and long distance carriers. This section also applies to private

networks regardless of whether the network is owned and operated by the election

jurisdiction.

For systems that transmit official data over public networks, this section applies to

telecommunications components installed and operated at locations supervised by election

officials, such as polling places or central offices. This includes:

• Components acquired by the jurisdiction for the purpose of voting, including

components installed at the polling place or a central office (including central site

facilities operated by vendors or contractors)

• Components acquired by others (such as school systems, libraries, military

installations and other public organizations) that are used at locations supervised by
election officials, including minimum configuration components required by the

vendor but that the vendor permits to be acquired from third party sources not under

the vendor’s control (e.g., router or modem card manufacturer or supplier)

6.1.3 Data Transmission

These requirements apply to the use of telecommunications to transmit data for the

preparation of the system for an election, the execution of an election, and the preservation of

the system data and audit trails during and following an election. While this section does not

assume a specific model of voting system operations and does not assume a specific model

for the use of telecommunications to support such operations, it does address the following

types of data, where applicable:

Voter Authentication: Coded information that confirms the identity of a voter for

security purposes for a system that transmits votes individually over a public network

Ballot Definition: Information that describes to a voting machine the content and

appearance of the ballots to be used in an election

Vote Transmission: For systems that transmit votes individually over a public network,

the transmission of a single vote within a network at a polling place and to the county

(or contractor) for consolidation with other county vote data

Vote Count: Information representing the tabulation of votes at any level within the

control of the jurisdiction, such as the polling place, precinct or central count

List of Voters: A listing of the individual voters who have cast ballots in a specific

election

Additional data transmissions used to operate a voting system in the conduct of an election,

but not explicitly listed above, are also subject to the requirements of this section.

For systems that transmit data using public networks, this section applies to

telecommunications hardware and software for transmissions within and among all

combinations of senders and receivers located at polling places, precinct count facilities and

central count facilities (whether operated by the jurisdiction or a contractor).

6.2 Design, Construction, and Maintenance Requirements

Design, construction, and maintenance requirements for telecommunications represent the

operational capability of both system hardware and software. These capabilities shall be

considered basic to all data transmissions.

6.2.1 Accuracy

The telecommunications components of all voting systems shall meet the accuracy

requirements of Subsection 4.1.1.

6.2.2 Durability

The telecommunications components of all voting systems shall meet the durability

requirements of Subsection 4.3.2.

6.2.3 Reliability

The telecommunications components of all voting systems shall meet the reliability

requirements of Subsection 4.3.3.
6.2.4 Maintainability

The telecommunications components of all voting systems shall meet the maintainability

requirements of Subsection 4.3.4.

6.2.5 Availability

The telecommunications components of all voting systems shall meet the availability

requirements of Subsection 4.3.5.

6.2.6 Integrity

For WANs using public telecommunications, boundary definition and implementation shall

meet the requirements below.

a. Outside service providers and subscribers of such providers shall not be given direct

access or control of any resource inside the boundary.

b. Voting system administrators shall not require any type of control of resources

outside this boundary. Typically, an end point of a telecommunications circuit will

be a subscriber termination on a Digital Service Unit/Customer Service Unit although

the specific technology configuration may vary. Regardless of the technology used,

the boundary point must ensure that everything on the voting system side is locally

configured and controlled by the election jurisdiction while everything on the public

network side is controlled by an outside service provider.

c. The system shall be designed and configured such that it is not vulnerable to a single

point of failure in the connection to the public network which could cause total loss of

voting capabilities at any polling place.

6.2.7 Confirmation

Confirmation occurs when the system notifies the user of the successful or unsuccessful

completion of the data transmission, where successful completion is defined as accurate

receipt of the transmitted data. To provide confirmation, the telecommunications components

of a voting system shall notify the user of the successful or unsuccessful completion of the

data transmission. In the event of unsuccessful transmission the user shall be notified of the

action to be taken.

7 Security Requirements

Table of Contents

7 Security Requirements 

7.1 Scope

7.1.1 Elements of Security Outside Vendor Control

7.1.2 Organization of This Section

7.2 Access Control 

7.2.1 General Access Control Policy 

7.2.1.1 Individual Access Privileges

7.2.1.2 Access Control Measures 
7.3 Physical Security Measures 

7.3.1 Polling Place Security

7.3.2 Central Count Location Security 

7.4 Software Security 

7.4.1 Software and Firmware Installation

7.4.2 Protection Against Malicious Software

7.4.3 Software Distribution and Setup Validation

7.4.4 Software Distribution 

7.4.5 Software Reference Information 

7.4.5.1 Hashes and Digital Signatures 

7.4.6 Software Setup Validation

7.5 Telecommunications and Data Transmission

7.5.1 Maintaining Data Integrity 

7.5.2 Protection Against External Threats

7.5.3 Monitoring and Responding to External Threats 

7.5.4 Shared Operating Environment 

7.5.5 Incomplete Election Returns 

7.6 Use of Public Communications Networks

7.6.1 Data Transmission 

7.6.2 Casting Individual Ballots 

7.6.2.1 Documentation of Mandatory Security Activities

7.6.2.2 Ability to Operate During Interruption of Service 

7.7 Wireless Communications 

7.7.1 Controlling Usage

7.7.2 Identifying Usage 

7.7.3 Protecting Transmitted Data

7.7.4 Protecting the Wireless Path

7.7.5 Protecting the Voting System

7.8 Independent Verification Systems 

7.8.1 Overview 

7.8.2 Basic Characteristics of IV Systems

7.9 Voter Verifiable Paper Audit Trail Requirements 

7.9.1 Display and Print a Paper Record

7.9.2 Approve or Void the Paper Record 

7.9.3 Electronic and Paper Record Structure

7.9.4 Equipment Security and Reliability

7.9.5 Preserving Voter Privacy

7.9.6 VVPAT Usability 

7.9.7 VVPAT Accessibility

7 Security Requirements

7.1 Scope

This section describes essential security capabilities for a voting system, encompassing the

system’s hardware, software, communications and documentation. No predefined set of

or authority of the voting jurisdiction

• Ballot printers, vote counting devices, and other hardware typically installed at

central or precinct locations (including contractor facilities)

7.1.1 Elements of Security Outside Vendor Control

The requirements of this section apply to the capabilities of a voting system that must be

provided by the vendor. However, an effective security program requires well-defined

security practices by the purchasing jurisdiction and the personnel managing and operating

the system. These practices include:

• Administrative and management controls for the voting system and election

management--including access controls

• Internal security procedures

• Adherence to, and enforcement of, operational procedures (e.g., effective password

management)

• Security of physical facilities

• Organizational responsibilities and personnel screening

Because implementation of these elements is not under the control of the vendor, they will be

addressed in the forthcoming Management Guidelines that will address the procedural

aspects of conducting elections and managing the operation of voting systems. However,

vendors must provide appropriate system capabilities to enable the implementation of

management controls.

7.1.2 Organization of This Section

The guidelines presented in this section are organized as follows:

Access Control: These standards address procedures and system capabilities that limit

or detect access to critical system components in order to guard against loss of system

integrity, availability, confidentiality, and accountability.

Physical Security: These standards address physical security measures and procedures

that prevent disruption of the voting process at the polling place and corruption of

voting data.

Software Security: These standards address the installation of software, including

firmware, in the voting system and the protection against malicious software. It should

be noted that computer-generated audit controls facilitate system security and are an

integral part of software capability. These audit requirements are presented in

Subsection 5.4.

Telecommunications and Data Transmission: These standards address security for

the electronic transmission of data between system components or locations over

private, public, and wireless networks.

Use of Public Communications Networks: These standards address security for

systems that communicate individual votes or vote totals over public communications

networks.

Wireless Communications: These standards address the security of the voting system

and voting data when wireless is used.

Independent Verification Systems: This section provides an introduction to the

concept of independent verification as a method to demonstrate voting system integrity.

This discussion provides the context for the requirements for DREs with voter verifiable
paper audit trails.

Direct-Recording Electronic Systems with Voter Verifiable Paper Audit Trails

(optional): This capability is not required for national certification. These guidelines are

provided for use by states that require this feature for DRE systems.

7.2 Access Control

Access controls are procedures and system capabilities that detect or limit access to system

components in order to guard against loss of system integrity, availability, confidentiality,

and accountability. Access controls provide reasonable assurance that system resources such

as data files, application programs, and computer-related facilities and equipment are

protected against unauthorized operation, modification, disclosure, loss or impairment.

Unauthorized operations include modification of compiled or interpreted code, run-time

alteration of flow control logic or of data, and abstraction of raw or processed voting data in

any form other than a standard output report by an authorized operator.

Access controls may include physical controls, such as keeping computers in locked rooms to

limit physical access, and technical controls, such as security software programs designed to

prevent or detect unauthorized access to sensitive files. The access controls described in this

section are limited to those controls required to be provided by system vendors.

7.2.1 General Access Control Policy

The vendor shall specify the general features and capabilities of the access control policy

recommended to provide effective voting system security.

Although the jurisdiction in which the voting system is operated is responsible for

determining the access policies for each election, the vendor shall provide a description of

recommended policies for:

a. Software access controls

b. Hardware access controls

c. Communications

d. Effective password management

e. Protection abilities of a particular operating system

f. General characteristics of supervisory access privileges

g. Segregation of duties

h. Any additional relevant characteristics

7.2.1.1 Individual Access Privileges

Voting system vendors shall:

a. Identify each person to whom access is granted, and the specific functions and data to

which each person holds authorized access

b. Specify whether an individual’s authorization is limited to a specific time, time

interval or phase of the voting or counting operations

c. Permit the voter to cast a ballot expeditiously, but preclude voter access to all aspects

of the vote counting processes

7.2.1.2 Access Control Measures

Vendors shall provide a detailed description of all system access control measures designed
to permit authorized access to the system and prevent unauthorized access. Examples of such

measures include:

a. Use of data and user authorization

b. Program unit ownership and other regional boundaries

c. One-end or two-end port protection devices

d. Security kernels

e. Computer-generated password keys

f. Special protocols

g. Message encryption

h. Controlled access security

Vendors also shall define and provide a detailed description of the methods used to prevent

unauthorized access to the access control capabilities of the system itself.

7.3 Physical Security Measures

A voting system’s sensitivity to disruption or corruption of data depends, in part, on the

physical location of equipment and data media, and on the establishment of secure

telecommunications among various locations. Most often, the disruption of voting and vote

counting results from a physical violation of one or more areas of the system thought to be

protected. Therefore, security procedures shall address physical threats and the corresponding

means to defeat them

.

7.3.1 Polling Place Security

For polling place operations, vendors shall develop and provide detailed documentation of

measures to enable poll workers to physically protect and perform orderly shutdown of

voting equipment to counteract vandalism, civil disobedience, and similar occurrences.

The measures shall allow the immediate detection of tampering with vote casting devices and

precinct ballot counters. They also shall control physical access to a telecommunications link

if such a link is used

7.3.2 Central Count Location Security

Vendors shall develop and document in detail the measures to be taken in a central counting

environment. These measures shall include physical and procedural controls related to the

handling of ballot boxes, preparing of ballots for counting, counting operations and reporting

data.

7.4 Software Security

Voting systems shall meet specific security requirements for the installation of software and

for protection against malicious software.

7.4.1 Software and Firmware Installation

The system shall meet the following requirements for installation of software, including

hardware with embedded firmware.

a. If software is resident in the system as firmware, the vendor shall require and state in

the system documentation that every device is to be retested to validate each ROM

prior to the start of elections operations.
b. To prevent alteration of executable code, no software shall be permanently installed

or resident in the voting system unless the system documentation states that the

jurisdiction must provide a secure physical and procedural environment for the

storage, handling, preparation, and transportation of the system hardware.

c. The voting system bootstrap, monitor, and device-controller software may be resident

permanently as firmware, provided that this firmware has been shown to be

inaccessible to activation or control by any means other than by the authorized

initiation and execution of the vote counting program, and its associated exception

handlers.

d. The election-specific programming may be installed and resident as firmware,

provided that such firmware is installed on a component (such as a computer chip)

other than the component on which the operating system resides.

e. After initiation of election day testing, no source code or compilers or assemblers

shall be resident or accessible.

7.4.2 Protection Against Malicious Software

Voting systems shall deploy protection against the many forms of threats to which they may

be exposed such as file and macro viruses, worms, Trojan horses, and logic bombs. Vendors

shall develop and document the procedures to be followed to ensure that such protection is

maintained in a current status.

7.4.3 Software Distribution and Setup Validation

Subsections 7.4.4, 7.4.5 and 7.4.6 specify requirements for the distribution of voting system

software and the setup validation performed on voting system equipment. These

requirements are applicable to voting systems that have completed certification testing. The

goal of the software distribution requirements is to ensure that the correct voting system

software has been distributed without modification. The goal of setup validation

requirements, including requirements for verifying the presence of certified software and the

absence of other software, is to ensure that voting system equipment is in a proper initial

state before being used.

In general, a voting system can be considered to be composed of multiple associated systems

including polling place systems, central counting/aggregation systems, and election

management systems. These other systems may reside on different computer platforms at

different locations and run different software. Voting system software is considered to be all

executable code and associated configuration files critical for the proper operation of the

voting system regardless of the location of installation and functionality provided. This

includes third party software such as operating systems, drivers, and database management

systems.

7.4.4 Software Distribution

a. The vendor shall document all software including voting system software, third party

software (such as operating systems and drivers) to be installed on the certified voting

system, and installation programs.

i. The documentation shall have a unique identifier (such as a serial number or

part number) for the following set of information: documentation, software
vendor name, product name, version, the certification application number of the

voting system, file names and paths or other location information (such as

storage addresses) of the software.

ii. The documentation shall designate all software files as static, semi-static or

dynamic.

Discussion: Static voting system software such as executable code does not change

based on the election being conducted or the voting equipment upon

which it is installed. Semi-static voting system software contains

configuration information for the voting system based on the voting

equipment that is installed and the election being conducted. Semi-static

software is only modified during the installation of (a) the voting system

software on voting equipment or (b) the election-specific software such

as ballot formats. Dynamic voting system software changes over time

once installed on voting equipment. However, the specific time or value

of the change in the dynamic software is usually unknown in advance,

making it impossible to create reference information to verify the

software.

b. The EAC accredited testing lab shall witness the final build of the executable version

of the certified voting system software performed by the vendor.

i. The testing lab shall create a complete record of the build that includes: a

unique identifier (such as a serial number) for the complete record; a list of

unique identifiers of unalterable storage media associated with the record; the

time, date, location, names and signatures of all people present; the source code

and resulting executable file names; the version of voting system software; the

certification application number of the voting system; the name and versions of

all (including third party) libraries; and the name, version, and configuration

files of the development environment used for the build.

ii. The record of the source code and executable files shall be made on unalterable

storage media. Each piece of media shall have a unique identifier.

Discussion: Unalterable storage media includes technology such as a CD-R, but not

CD-RW. The unique identifiers appear on indelibly printed labels and in

a digitally signed file on the unalterable storage media.

iii.The testing lab shall retain this record until notified by the EAC that it can be

archived.

c. After EAC certification has been granted, the testing lab shall create a subset of the

complete record of the build that includes a unique identifier (such as a serial number)

of the subset, the unique identifier of the complete record, a list of unique identifiers

of unalterable storage media associated with the subset, the vendor and product name,

the version of voting system software, the certification number of the voting system,

and all the files that resulted from the build and binary images of all installation

programs.

iii.The record of the software shall be made on unalterable storage media. Each

piece of media shall have a unique identifier.

iv. The testing lab shall retain a copy, send a copy to the vendor, and send a copy

to the NIST National Software Reference Library (NSRL)2 and/or to any

repository designated by a State.

2 The National Software Reference Library (NSRL) is a repository of software maintained by the National

Institute of Standards and Technology. It was designed to meet the need for court admissible evidence in the
identification of software files. The EAC has designated the NSRL as a repository for voting system software.

Information is available at www.nsrl.nist.gov.

v. The NSRL shall retain this software until notified by the EAC that it can be

archived.

d. The vendor shall provide the NSRL and any repository designated by a state with a

copy of the software installation disk, which the vendor will distribute to purchasers--

including the executable binary images of all third party software.

i. All voting system software, installation programs and third party software (such

as operating systems and drivers) used to install or to be installed on voting

system equipment shall be distributed using unalterable storage media.

ii. The vendor shall document that the process used to verify the software

distributed on unalterable storage media is the certified software by using the

reference information provided by the NSRL or other designated repository

before installing the software.

e. The voting system equipment shall be designed to allow the voting system

administrator to verify that the software is the certified software by comparing it to

reference information produced by the NSRL or other designated repository.

f. The vendors and testing labs shall document to whom they provide voting system

software.

7.4.5 Software Reference Information

The NSRL or other repository designated by a state election office shall generate reference

information using the binary images of the (a) certified voting system software received on

unalterable storage media from testing labs and (b) election- specific software received on

unalterable storage media from jurisdictions.

a. The NSRL or other designated repository shall generate reference information in at

least one of the following forms: (a) complete binary images, (b) cryptographic hash

values or (c) digital signatures of the software.

Discussion: Although binary images, cryptographic hashes, and digital signatures

can detect a modification or alteration in the software, they cannot

determine if the change to the software was accidental or intentional.

b. The NSRL or other designated repository shall create a record of the creation of

reference information that includes: a unique identifier (such as a serial number) for

the record; the file names of software and associated unique identifier(s) of the

unalterable storage media from which reference information is generated; the time,

date and name of people who generated reference information; the type of reference

information created; the certification number of the voting system; the voting system

software version; the product name; and the vendor name.

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c. The NSRL or other designated repository shall retain the unalterable storage media

used to generate the reference information until notified by the EAC that it can be

archived.

7.4.5.1 Hashes and Digital Signatures
a. The NSRL or other designated repository that generates hash value and/or digital

signature reference information shall use FIPS-approved algorithms for hashing and

signing.

i. The NSRL or other designated repository that generates hash values, digital

signatures reference information or cryptographic keys shall use a FIPS 140-2

level 1 or higher validated cryptographic module.

Discussion: See http://www.csrc.nist.gov/cryptval/ for information on FIPS 140-2.

ii. The NSRL or other designated repository that generates sets of hash values and

digital signatures for reference information shall include a hash value or digital

signature covering the set of reference information.

b. If the NSRL or other designated repository uses public key technology, the following

requirements shall be met:

i. Public and private key pairs used by the repository to generate digital signatures

shall be 2048-bits or greater in length

ii. The repository’s private keys used to generate digital signature reference

information shall be used for no more than three years

iii.Public keys used to verify digital signature reference information shall be

placed on unalterable storage media if not contained in a signed non-proprietary

format for distribution.

Discussion: Examples of non-proprietary standard formats include X.509 or

PKCS#7.

iv. All copies of public key unalterable storage media made by the repository shall

be labeled so that they are uniquely identifiable, including at a minimum: a

unique identifier (such as a serial number) for the unalterable storage media; the

time, date, location and name(s) of the repository owning the associated private

keys; documentation about its creation; and an indication that the contents are

public keys.

v. The NSRL or other designated repository shall document to whom they provide

unalterable storage media containing their public keys used to verify digital

signature reference information including at a minimum: the uniquely identified

public keys, the time and date provided, the name of the organization, and the

name and contact information (phone, address, email address) of the recipient.

vi. When a private key used to generate digital signature reference information

becomes compromised, the NSRL or other designated repository shall provide

notification to recipients of the associated public key that the private key has

been compromised and the date on which it was compromised.

c. The NSRL or other designated repository shall make both the reference information

available on unalterable storage media and its associated documentation that is

labeled by the repository that created it uniquely identifiable by including at a

minimum: a unique identifier (such as a serial number) for the storage media; the

time, date, location and name of the creating repository; and an indication that the

contents are reference information.

7.4.6 Software Setup Validation

a. Setup validation methods shall verify that no unauthorized software is present on the

voting equipment.
b. The vendor shall have a process to verify that the correct software is loaded, that there

is no unauthorized software, and that voting system software on voting equipment has

not been modified, using the reference information from the NSRL or from a State

designated repository.

i. The process used to verify software should be possible to perform without

using software installed on the voting system.

ii. The vendor shall document the process used to verify software on voting

equipment.

iii.The process shall not modify the voting system software on the voting system

during the verification process.

c. The vendor shall provide a method to comprehensively list all software files that are

installed on voting systems.

d. The verification process should be able to be performed using COTS software and

hardware available from sources other than the voting system vendor.

i. If the process uses hashes or digital signatures, then the verification software

shall use a FIPS 140-2 level 1 or higher validated cryptographic module.

ii. The verification process shall either (a) use reference information on

unalterable storage media received from the repository or (b) verify the digital

signature of the reference information on any other media.

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e. Voting system equipment shall provide a means to ensure that the system software

can be verified through a trusted external interface, such as a read-only external

interface, or by other means.

i. The external interface shall be protected using tamper evident techniques

ii. The external interface shall have a physical indicator showing when the

interface is enabled and disabled

iii.The external interface shall be disabled during voting

iv. The external interface should provide a direct read-only access to the location

of the voting system software without the use of installed software

f. Setup validation methods shall verify that registers and variables of the voting system

equipment contain the proper static and initial values.

i. The vendor should provide a method to query the voting system to determine

the values of all static and dynamic registers and variables including the values

that jurisdictions are required to modify to conduct a specific election.

ii. The vendor shall document the values of all static registers and variables, and

the initial starting values of all dynamic registers and variables listed for voting

system software, except for the values set to conduct a specific election.

7.5 Telecommunications and Data Transmission

There are four areas that must be addressed by telecommunications and data transmission

security capabilities: access control, data integrity, detection and prevention of data

interception, and protection against external threats.
7.5.1 Maintaining Data Integrity

Voting systems that use telecommunications to communicate between system components

and locations are subject to the same security requirements governing access to any other

system hardware, software, and data function.

a. Voting systems that use electrical or optical transmission of data shall ensure the

receipt of valid vote records is verified at the receiving station. This should include

standard transmission error detection and correction methods such as checksums or

message digest hashes. Verification of correct transmission shall occur at the voting

system application level and ensure that the correct data is recorded on all relevant

components consolidated within the polling place prior to the voter completing

casting of his or her ballot.

b. Voting systems that use telecommunications to communicate between system

components and locations before the polling place is officially closed shall:

i. Implement an encryption standard currently documented and validated for use

by an agency of the U.S. government

ii. Provide a means to detect the presence of an intrusive process, such as an

Intrusion Detection System

7.5.2 Protection Against External Threats

a. Voting systems that use public telecommunications networks shall implement

protections against external threats to which commercial products used in the system

may be susceptible.

b. Voting systems that use public telecommunications networks shall provide system

documentation that clearly identifies all COTS hardware and software products and

communications services used in the development and/or operation of the voting

system, including operating systems, communications routers, modem drivers and

dial-up networking software.

i. Such documentation shall identify the name, vendor, and version used for each

such component.

c. Voting systems that use public telecommunications networks shall use protective

software at the receiving-end of all communications paths to:

i. Detect the presence of a threat in a transmission

ii. Remove the threat from infected files/data

iii.Prevent against storage of the threat anywhere on the receiving device

iv. Provide the capability to confirm that no threats are stored in system memory

and in connected storage media

v. Provide data to the system audit log indicating the detection of a threat and the

processing performed

d. Vendors shall use multiple forms of protective software as needed to provide

capabilities for the full range of products used by the voting system.

7.5.3 Monitoring and Responding to External Threats

Voting systems that use public telecommunications networks may become vulnerable, by

virtue of their system components, to external threats to the accuracy and integrity of vote

recording, vote counting, and vote consolidation and reporting processes. Therefore, vendors
of such systems shall document how they plan to monitor and respond to known threats to

which their voting systems are vulnerable. This documentation shall provide a detailed

description, including scheduling information, of the procedures the vendor will use to:

a. Monitor threats, such as through the review of assessments, advisories, and alerts for

COTS components issued by the Computer Emergency Response Team (CERT), for

which a current listing can be found at http://www.cert.org, the National

Infrastructure Protection Center (NIPC), and the Federal Computer Incident Response

Capability (FedCIRC), for which additional information can be found at www.uscert.

gov

b. Evaluate the threats and, if any, proposed responses

c. Develop responsive updates to the system and/or corrective procedures

d. Submit the proposed response to the test labs and appropriate states for approval,

identifying the exact changes and whether or not they are temporary or permanent

e. After implementation of the proposed response is approved by the state, assist clients,

either directly or through detailed written procedures, how to update their systems

and/or to implement the corrective procedures within the timeframe established by

the state

f. Address threats emerging too late to correct the system by:

i. Providing prompt, emergency notification to the accredited test labs and the

affected states and user jurisdictions

ii. Assisting client jurisdictions directly or advising them through detailed written

procedures to disable the public telecommunications mode of the system

iii.Modifying the system after the election to address the threat, submitting the

modified system to an accredited test lab and the EAC or state certification

authority for approval, and assisting client jurisdictions directly or advising

them through detailed written procedures, to update their systems and/or to

implement the corrective procedures after approval

7.5.4 Shared Operating Environment

Ballot recording and vote counting can be performed in either a dedicated or non-dedicated

environment. If ballot recording and vote counting operations are performed in an

environment that is shared with other data processing functions, both hardware and software

features shall be present to protect the integrity of vote counting and of vote data.

Systems that use a shared operating environment shall:

a. Use security procedures and logging records to control access to system functions

b. Partition or compartmentalize voting system functions from other concurrent

functions at least logically, and preferably physically as well

c. Control system access by means of passwords, and restrict account access to

necessary functions only

d. Have capabilities in place to control the flow of information, precluding data leakage

through shared system resources

7.5.5 Incomplete Election Returns

If the voting system provides access to incomplete election returns and interactive inquiries

before the completion of the official count, the system shall:
a. Be designed to provide external access to incomplete election returns (for equipment

that operates in a central counting environment), only if that access for these purposes

is authorized by the statutes and regulations of the using agency. This requirement

applies as well to polling place equipment that contains a removable memory module

or that may be removed in its entirety to a central place for the consolidation of

polling place returns

b. Design voting system software and its security environment such that data accessible

to interactive queries resides in an external file or database created and maintained by

the elections software under the restrictions applying to any other output report:

i. The output file or database has no provision for write access back to the system

ii. Persons whose only authorized access is to the file or database are denied write

access, both to the file or database, and to the system

7.6 Use of Public Communications Networks

Voting systems that transmit data over public telecommunications networks face security

risks that are not present in other voting systems. This section describes standards applicable

to voting systems that use public telecommunications networks.

7.6.1 Data Transmission

All systems that transmit data over public telecommunications networks shall:

a. Preserve the secrecy of voter ballot selections and prevent anyone from violating

ballot privacy

b.Employ digital signatures for all communications between the vote server and other

devices that communicate with the server over the network

c. Require that at least two authorized election officials activate any critical operation

regarding the processing of ballots transmitted over a public communications

network, i.e. the passwords or cryptographic keys of at least two employees are

required to perform processing of votes

7.6.2 Casting Individual Ballots

Systems designed for transmission of telecommunications over public networks shall meet

security standards that address the security risks attendant with the casting of ballots from

polling places controlled by election officials using voting devices configured and installed

by election officials and/or their vendor or contractor, and using in-person authentication of

individual voters.

7.6.2.1 Documentation of Mandatory Security Activities

Vendors of voting systems that cast individual ballots over a public telecommunications

network shall provide detailed descriptions of:

a. All activities mandatory to ensuring effective voting system security to be

performed in setting up the system for operation, including testing of security before

an election

b. All activities that should be prohibited during voting equipment setup and during the

timeframe for voting operations, including both the hours when polls are open and

when polls are closed
7.6.2.2 Ability to Operate During Interruption of Service

These systems shall provide the following capabilities to provide resistance to interruptions

of telecommunications service that prevent voting devices at the polling place from

communicating with external components via telecommunications:

a. Detect the occurrence of a telecommunications interruption at the polling place and

switch to an alternative mode of operation that is not dependent on the connection

between polling place voting devices and external system components

b. Provide an alternate mode of operation that includes the functionality of a

conventional electronic voting system without losing any single vote

c. Create and preserve an audit trail of every vote cast during the period of interrupted

communication and system operation in conventional electronic voting system mode

d. Upon reestablishment of communications, transmit and process votes accumulated

while operating in conventional electronic voting system mode with all security

safeguards in effect

e. Ensure that all safeguards related to voter identification and authentication are not

affected by the procedures employed by the system to counteract potential

interruptions of telecommunications capabilities

7.7 Wireless Communications

This section provides requirements for implementing and using wireless communications

within a voting system. These requirements reduce, but do not eliminate, the risk of using

wireless communications for voting systems.

Wireless is defined as any means of communications that occurs without wires. This

normally covers the entire electromagnetic spectrum. For the purposes of this section,

wireless includes radio frequency, infrared, and microwave. This section provides

requirements and considerations that apply to external wireless communications capabilities

existing on voting equipment or as a component within a voting system. These requirements

may be applied to internal wireless communications, but this is not required when the

physical container that houses the voting equipment or voting system is considered adequate

to protect the internal wireless between or among voting system components.

Since the wireless communications path on which the signals travel is via the air and not a

wire or cable, devices other than those intended to receive the wireless signal (e.g. voting

data) can receive (intentionally and unintentionally) the wireless signals. Some of the

wireless communications paths (i.e. signals) are weakened by walls and distance, but are not

stopped. This makes it possible to eavesdrop from a distance as well as transmit wireless

signals (e.g., interference or intrusive data) from a distance. In many cases, the wireless

signals cannot be seen, heard, or felt, thus making the presence of wireless communication

hard to determine by the human senses. The requirements in this section mitigate the risks

associated with wireless by controlling and identifying usage, and protecting the transmitted

data and path.

There are other concerns when evaluating wireless usage; specifically radio frequency (RF).

A device’s radio frequencies usage and the power output are governed by Federal

Communications Commission (FCC) regulations and therefore all RF wireless

communications devices are subject to the applicable FCC requirements. However, these

FCC regulations do not fully address RF wireless interference caused by multiple FCC
compliant devices. That is, the RF wireless used in a voting system may be using the same

radio frequency as another non-voting wireless system and which may potentially cause a

degradation of the wireless performance or a complete wireless failure for the voting system.

Sometimes a particular wireless technology permits a power output range, which may be

used to overcome interference received from another device. A radio emissions site test can

determine the extent of potential existing interference at the location where the wireless

voting system is to be used. A radio emission site test can also determine the extent that the

RF wireless transmission of the voting system escapes the building in which the RF wireless

voting system is used.

7.7.1 Controlling Usage

a. If wireless communications are used in a voting system, then the vendor shall supply

documentation describing how to use all aspects of wireless communications in a

secure manner. This documentation shall include:

i. A complete description of the uses of wireless in the voting system including

descriptions of the data elements and signals that are to be carried by the

wireless mechanism

ii. A complete description of the vulnerabilities associated with this proposed use

of wireless, including vulnerabilities deriving from the insertion, deletion,

modification, capture or suppression of wireless messages

iii.A complete description of the techniques used to mitigate the risks associated

with the described vulnerabilities including techniques used by the vendor to

ensure that wireless cannot send or receive messages other than those situations

specified in the documentation. Cryptographic techniques shall be carefully and

fully described, including a description of cryptographic key generation,

management, use, certification, and destruction

iv. A rationale for the inclusion of wireless in the proposed voting system, based

on a careful and complete description of the perceived advantages and

disadvantages of using wireless for the documented uses compared to using

non-wireless approaches

Discussion: In general, convenience is not a sufficiently compelling reason, on its

own, to justify the inclusion of wireless communications in a voting

system. Convenience must be balanced against the difficulty of working

with cryptographic keys.

b. The details of all cryptographic protocols used for wireless communications,

including the specific features and data, shall be documented.

c. The wireless documentation shall be closely reviewed for accuracy, completeness,

and correctness.

d. There shall be no undocumented use of the wireless capability, nor any use of the

wireless capability that is not entirely controlled by an election official.

Discussion: This can be tested by reviewing all of the software, hardware, and

documentation, and by testing the status of wireless activity during all

phases of testing.

e. If a voting system includes wireless capabilities, then the voting system shall be able

to accomplish the same function if wireless capabilities are not available due to an

error or no service.

i. The vendor shall provide documentation how to accomplish these functions
when wireless is not available.

f. The system shall be designed and configured so it is not vulnerable to a single point

of failure using wireless communications that causes a total loss of any voting

capabilities.

g. If a voting system includes wireless capabilities, then the system shall have the ability

to turn on the wireless capability when it is to be used and to turn off the wireless

capability when the wireless capability is not in use.

h. If a voting system includes wireless capabilities, then the system shall not activate the

wireless capabilities without confirmation from an elections official.

7.7.2 Identifying Usage

Since there are a wide variety of wireless technologies (both standard and proprietary) and

differing physical properties of wireless signals, it is important to identify some of the

characteristics of the wireless technologies used in the voting system.

a. If a voting system provides wireless communications capabilities, then there shall be

a method for determining the existence of the wireless communications capabilities.

b. If a voting system provides wireless communications capabilities, then there shall be

an indication that allows one to determine when the wireless communications (such

as radio frequencies) capability is active.

c. The indication shall be visual.

d. If a voting system provides wireless communications capabilities, then the type of

wireless communications used (such as radio frequencies) shall be identified either

via a label or via the voting system documentation.

7.7.3 Protecting Transmitted Data

The transmitted data, especially via wireless communications, needs to be protected to ensure

confidentiality and integrity. Examples of election information that needs to be protected

include: ballot definitions, voting device counts, precinct counts, opening of poll signal, and

closing of poll signal. Examples of other information that needs to be protected include:

protocol messages, address or device identification information, and passwords.

Since radio frequency wireless signals radiate in all directions and pass through most

construction material, anyone may easily receive the wireless signals. In contrast, infrared

signals are line of sight and do not pass through most construction material. However,

infrared signals can still be received by other devices that are in the line of sight. Similarly,

wireless signals can be transmitted by others to create unwanted signals. Thus, encryption is

required to protect the privacy and confidentiality of the voting information.

a. All information transmitted via wireless communications shall be encrypted and

authenticated--with the exception of wireless T-coil coupling--to protect against

eavesdropping and data manipulation including modification, insertion, and deletion.

i. The encryption shall be as defined in Federal Information Processing Standards

(FIPS) 197, “Advanced Encryption Standard (AES).”

ii. The cryptographic modules used shall comply with FIPS 140-2, Security

Requirements for Cryptographic Modules.

b. The capability to transmit non-encrypted and non-authenticated information via

wireless communications shall not exist.

c. If audible wireless communication is used, and the receiver of the wireless
transmission is the human ear, then the information shall not be encrypted.

Discussion: This specifically covers wireless T-Coil coupling for assistive devices

used by people who are hard of hearing.

7.7.4 Protecting the Wireless Path

If wireless communications are used, then the following capabilities shall exist in order to

mitigate the effects of a denial of service (DoS) attack:

a. The voting system shall be able to function properly throughout a DoS attack, since

the DoS attack may continue throughout the voting period.

b. The voting system shall function properly as if the wireless capability were never

available for use.

c. Alternative procedures or capabilities shall exist to accomplish the same functions

that the wireless communications capability would have done.

d. If infrared is being used, the shielding shall be strong enough to prevent escape of the

voting system signal, as well as strong enough to prevent infrared saturation jamming.

Discussion: Since infrared has the line-of-sight property, securing the wireless path

can be accomplished by shielding the path between the communicating

devices with an opaque enclosure. However, this is only practical for

short distances. This shielding would also help prevent accidental eye

damage from the infrared signal.

7.7.5 Protecting the Voting System

Physical security measures to prevent access to a voting system are not possible when using a

wireless communications interface because there is no discrete physical communications path

that can be secured.

a. The security requirements in Subsection 2.1.1 shall be applicable to systems with

wireless communications.

b. The accuracy requirements in Subsection 2.1.2 shall be applicable to systems with

wireless communications.

c. The use of wireless communications that may cause impact to the system accuracy

through electromagnetic stresses is prohibited.

d. The error recovery requirements in Subsection 2.1.3 shall be applicable to systems

with wireless communications.

e. All wireless communications actions shall be logged.

i. The log shall contain at least the following entries: times when the wireless is

activated and deactivated, services accessed, identification of device to which

data was transmitted to or received from, identification of authorized user, and

successful and unsuccessful attempts to access wireless communications or

service.

Discussion: Other information such as the number of frames or packets transmitted or

received at various logical layers may be useful, but is dependent on the

wireless technology used.

f. Device authentication shall occur before any access to, or services from, the voting

system are granted through wireless communications.

Discussion: Authentication is an important element to protect the security of

wireless communications. Authentication verifies the identity and

legitimacy of users, devices, and services.
i. User authentication shall be at least level 2 as per NIST Special Publication

800-63 Version 1.0.1, Electronic Authentication Guideline.

7.8 Independent Verification Systems

7.8.1 Overview

Independent verification (IV) systems are electronic voting systems that produce multiple

independent cast vote records of voter ballot selections, which can be audited to a high level

of precision. For this to happen, the cast vote records must be handled according to the

following protocol:

• At least two cast vote records of the voter’s selections are produced and one of the

records is then stored in a manner that it cannot be modified by the voting system.

For example, the voting system creates a record of the voter’s selections and then

copies it to unalterable storage media.

• The voter must be able to verify that both cast vote records are correct and match

before leaving the polling place, e.g., verify his or her selections on the voting

machine summary screen and also verify the second record on the unalterable storage

media.

• The verification processes for the two cast vote records must be independent of each

other, and at least one of the records must be verified directly by the voter.

• The contents of the two cast vote records also can be checked later for consistency

through the use of unique identifiers that allow the records to be linked.

The cast vote records would be formatted so that at least one set is usable in an efficient

counting process by the electronic voting system and the other set is usable in an efficient

process of auditing or verifying the agreement between the two sets.

Given these conditions, the multiple cast vote records are considered to be distinct and

independently verifiable, that is, both records are not under the control of the same system

processes. As a result of this independence, the audit records can be used to check the

accuracy of the counted records. Because the records are separately stored, an attacker who

can compromise one will also have to compromise the other.

The voter verifiable paper audit trail (VVPAT) methodology is one of several classes of IV

systems. In this approach, the voter can directly compare the electronic summary screen of

the voting machine with the printed paper audit record. (This is not to be confused with the

paper ballot that is produced by optical scan voting systems that the voter visually verifies

before placing it in the ballot box or tabulator.) Requirements for DREs with a VVPAT

feature are provided below to reflect the fact that a number of States currently require this

feature.

There are a variety of other IV approaches for the voter to verify his or her selections with

systems that produce an electronic record for verification. Appendix C describes the

characteristics of these systems in more detail. They include:

• Split process systems, which use separate devices for the voters to record and verify

their ballot selections

• Cryptographic systems, which provide voters with coded receipts that can be used to

verify their ballot selections

• Witness systems, which use an independent module to create the second record
7.8.2 Basic Characteristics of IV Systems

This section describes a preliminary set of basic characteristics that apply to all types of IV

systems. This information is provided for the purpose of introducing these concepts for

consideration in voting system design. It is anticipated that future voting systems will be

required to provide some type of independent verification feature to enable voters to have

confidence that their ballot selections are correctly recorded and counted.

An independent verification system produces at least two independent cast vote records of

ballot selections via interactions with the voter, such that one record can be compared against

the other to check their equality of content.

Discussion: This is the fundamental characteristic of IV systems. The records can be

checked against one another to determine whether or not the voter

selections are correctly recorded.

The voter verifies the content of each cast vote record and either (a) verifies at least one of

the records directly or (b) verifies both records indirectly if the records are each under the

control of independent processes.

Discussion: Direct verification involves using human senses; for example, directly

reading a paper record via one’s eyesight. Indirect verification involves

using an intermediary to perform the verification; for example, verifying

an electronic ballot image on the voting machine.

The creation, storage and handling of the cast vote records are sufficiently separate that the

failure or compromise of one record does not cause the failure or compromise of another.

Discussion: The records must be stored on different media and handled

independently of each other so that no one process could compromise

all records. If an attack can alter one record, it should still be very

difficult to alter the other record.

Both cast vote records are highly resistant to damage or alteration and capable of long-term

storage.

Discussion: The records should be difficult to alter or damage so that they could be

used in case the counted records are damaged or lost.

The processes of verification for the cast vote records do not all depend on the same device,

software module, or system for their integrity, and are sufficiently separate that each record

provides evidence of the voter’s selections independently of its corresponding record.

Discussion: For example, the verification of the summary screen (electronic record)

of a DRE is sufficiently separate from the verification of a paper record

printed by a VVPAT component or a copy of the electronic record

stored on a separate system.

The multiple cast vote records are linked to their corresponding audit records by including a

unique identifier within each record.

Discussion: The identifier serves the purpose of uniquely identifying and linking the

records for cross-checking.

Each cast vote record includes information identifying the following:

• An identification of the polling place and precinct

• Whether the balloting is provisional, early, or on election day

• Ballot style

• A timestamp generated when the voting machine is enabled to begin a voting session

that can be used to correctly group the cast vote records

• A unique identifier associated with the voting machine
Discussion: The identifier could be a serial number or other unique ID.

The cryptographic software used in IV systems is approved by the U.S. Government’s

Cryptographic Module Validation Program, as applicable.

Discussion: IV voting systems may use cryptographic software for a number of

different purposes, including calculating checksums, encrypting records,

authentication, generating random numbers, and for digital signatures.

This software should be reviewed and approved by the Cryptographic

Module Validation Program (CMVP). There may by cryptographic

voting schemes where the cryptographic algorithms used are necessarily

different from any algorithms that have approved CMVP

implementations, thus CMVP-approved software shall be used where

feasible. The CMVP website is http://csrc.nist.gov/cryptval.

7.9 Voter Verifiable Paper Audit Trail Requirements

This section contains requirements for DREs with a Voter Verifiable Paper Audit Trail

(VVPAT) component. VVPAT capability is not required for national certification.

However, these requirements will be applied for certification testing of DRE systems that are

intended for use in states that require DREs to provide this capability. The vendor’s

certification testing application to the EAC must indicate whether the system being presented

for testing includes this capability, as provided under Subsection 1.6.2.5 extensions.

7.9.1 Display and Print a Paper Record

a. The voting system shall print and display a paper record of the voter ballot selections

prior to the voter making his or her selections final by casting the ballot.

Discussion: This is the basic requirement for VVPAT capability. It requires the

paper record to be created as a distinct representation of the voter ballot

selections. It requires the paper record to contain the same information

as the electronic record and be suitable for use in verifications of the

voting machine’s electronic records.

b. The paper record shall constitute a complete record of ballot selections that can be

used to assess the accuracy of the voting machine’s electronic record, to verify the

election results, and, if required by state law, in full recounts.

Discussion: This requirement exists to make clear that it is possible to use the paper

record for checks of the voting machine’s accuracy in recording voter

ballot selections, as well as usable for election audits (such as

mandatory 1% recounts). The paper record shall also be suitable for use

in full recounts of the election if required by state law.

c. The paper record shall contain all voter selection information stored in the electronic

(ballot image) record.

Discussion: The electronic ballot image record cannot hide any information related to

ballot selections; all information relating to voter selections must be

equally present in both records. The electronic record may contain other

items that don't necessarily need to be on the paper record, such as

digital signature information.

7.9.2 Approve or Void the Paper Record

a. The voting equipment shall allow the voter to approve or void the paper record.
Discussion: There are three possible scenarios regarding the voter’s disposition of the

paper record.

• The voter can verify that the ballot selections displayed on the DRE summary

screen and those printed on the paper record are the same. If they are, and the

voter is satisfied with these selections, the voter can proceed to cast his or her

ballot, thereby approving the paper record.

• If the selections match, but the voter wishes to change one or more selections,

the paper record must be voided so a new paper record can be created to

compare to the new summary screen displayed after the voter changes his or

her ballot selections.

• In the event the selections do not match between the summary screen and the

paper record, the voter shall immediately request assistance from a poll

worker. A non-match could indicate a potential voting machine or printer

malfunction.

b. The voting equipment shall, in the presence of the voter, mark the paper record as

being approved by the voter if the ballot selections are accepted; or voided or if the

voter decides to change one or more selections.

c. If the records do not match, the voting equipment shall mark and preserve the paper

record and shall provide a means to preserve the corresponding electronic record so

the source of error or malfunction can be analyzed.

Discussion: The voting machine shall be withdrawn from service immediately and its

use discontinued in accordance with jurisdiction procedures.

d. The voting machine shall not record the electronic record until the paper record has

been approved by the voter.

e. Vendor documentation shall include procedures to enable the election official to

return a voting machine to correct operation after a voter has used it incompletely or

incorrectly. This procedure shall not cause discrepancies between

the tallies of the electronic and paper records.

7.9.3 Electronic and Paper Record Structure

a. All cryptographic software in the voting system shall be approved by the U.S.

Government’s Cryptographic Module Validation Program, as applicable.

Discussion: Cryptographic software may be used for a number of different purposes,

including calculating checksums, encrypting records, authentication,

generating random numbers, and digital signatures. This software

should be reviewed and approved by the Cryptographic Module

Validation Program (CMVP). There may be cryptographic voting

schemes where the cryptographic algorithms used are necessarily

different from any algorithms that have approved CMVP

implementations, thus CMVP approved software should be used where

feasible but is not required. The CMVP website is

http://csrc.nist.gov/cryptval.

b. The electronic ballot image and paper records shall include information about the

election.

i. The voting equipment shall be able to include an identification of the particular

election, the voting site and precinct, and the voting machine.

Discussion: If the voting site and precinct are different, both should be included.
ii. The records shall include information identifying whether the balloting

is provisional, early, or on election day, and information that identifies

the ballot style in use.

iii.The records shall include a voting session identifier that is generated when the

voting equipment is placed in voting mode, and that can be used to identify the

records as being created during that voting session.

Discussion: If there are several voting sessions on the same voting machine on the

same day, the voting session identifiers must be different. They should

be generated from a random number generator.

c. 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.

Discussion: The identifier serves the purpose of uniquely identifying and linking the

records for cross-checking.

d. The voting machine should generate and store a digital signature for each electronic

record.

e. The electronic ballot image records shall be able to be exported for auditing or

analysis on standards-based and /or COTS information technology computing

platforms.

i. The exported electronic ballot image records shall be in a publicly

available, non-proprietary format.

Discussion: It is advantageous when all electronic records, regardless of

manufacturer, use the same format or can easily be converted to a

publicly available, non-proprietary format; for example, the OASIS

Election Markup Language (EML) Standard.

ii. The records should be exported with a digital signature, which shall be

calculated on the entire set of electronic records and their associated digital

signatures.

Discussion: This is necessary to determine if records are missing or

substituted.

iii.The voting system vendor shall provide documentation as to the

structure of the exported ballot image records and how they shall be

read and processed by software.

iv. The voting system vendor shall provide a software program that will

display the exported ballot image records and that may include other

capabilities such as providing vote tallies and indications of

undervotes.

v. The voting system vendor shall provide full documentation of procedures for

exporting electronic ballot image records and reconciling those records with the

paper audit records.

f. The paper record should be created in a format that may be made available across

different manufacturers of electronic voting systems.

Discussion: There may be a future requirement for some commonality in the format

of paper records.

g. The paper record shall be created such that its contents are machine readable.

Discussion: This can be done by using specific OCR fonts or barcodes.

i. The paper record shall contain error correcting codes for the purpose of

detecting read errors and for preventing other markings on the paper record
from being misinterpreted when machine reading the paper record.

Discussion: This requirement is not mandatory if a state prohibits the paper record

from containing any information that cannot be read and understood by

the voter. This requirement serves the purpose of detecting scanning

errors and preventing stray or deliberate markings on the paper from

being interpreted as valid data.

h. If barcode is used, the voting equipment shall be able to print a barcode with each

paper record that contains the human-readable contents of the paper record.

Discussion: This requirement is not mandatory if a state prohibits the paper record

from containing any information that cannot be read and understood by

the voter.

i. The barcode shall use an industry standard format and shall be able to be read

using readily available commercial technology.

Discussion: Examples of such codes are Maxi Code or PDF417.

ii. If the corresponding electronic record contains a digital signature, the digital

signature shall be included in the barcode on the paper record.

iii.The barcode shall not contain any information other than the paper record’s

human-readable content, error correcting codes, and digital signature

information.

7.9.4 Equipment Security and Reliability

a. The voting machine shall provide a standard, publicly documented printer port (or the

equivalent) using a standard communication protocol.

Discussion: Using a standard, publicly documented printer protocol assists in

security evaluations of system software.

b.Tamper-evident seals or physical security measures shall protect the connection

between the printer and the voting machine.

c. If the connection between the voting machine and the printer has been broken, the

voting machine shall detect this event and record it in the DRE internal audit log.

d. The paper path between the printing, viewing and storage of the paper record shall be

protected and sealed from access except by authorized election officials.

e. The printer shall not be permitted to communicate with any system or machine other

than the voting machine to which it is connected.

f. The printer shall only be able to function as a printer; it shall not contain any other

services (e.g., provide copier or fax functions) or network capability.

g. The voting machine shall detect errors and malfunctions such as paper jams or low

supplies of consumables such as paper and ink that may prevent paper records from

being correctly displayed, printed or stored.

Discussion: This could be accomplished in a variety of different ways; for example,

a printer that is out of paper or jammed could issue a different audible

alarm for each condition.

h. If an error or malfunction occurs, the voting machine shall suspend voting operations

and should present a clear indication to the voter and election officials of the

malfunction.

i. The voting machine shall not record votes if an error or malfunction occurs.

j. Printing devices should contain sufficient supplies of paper and ink to avoid reloading

or opening equipment covers or enclosures and thus potential circumvention of
security features; or be able to reload paper and ink with minimal disruption to voting

and without circumvention of security features such as seals.

k. Vendor documentation shall include procedures for investigating and resolving

printer malfunctions including, but not limited to; printer operations, misreporting of

votes, unreadable paper records, and power failures.

l. Vendor documentation shall include printer reliability specifications including Mean

Time Between Failure estimates, and shall include recommendations for appropriate

quantities of backup printers and supplies.

m. Protective coverings intended to be transparent on voting equipment shall be

maintainable via a predefined cleaning process. If the coverings become damaged

such that they obscure the paper record, they shall be replaceable.

n. The paper record shall be sturdy, clean, and of sufficient durability to be used for

verifications, reconciliations, and recounts conducted manually or by automated

processing.

7.9.5 Preserving Voter Privacy

VVPAT records can be printed and stored by two different methods:

• Printed and stored on a continuous spool-to-spool paper roll where the voter views

the paper record in a window

• Printed on separate pieces of paper, which are deposited in a secure receptacle.

If a requirement applies to only one method, that will be specified. Otherwise, the

requirement applies to both.

a. Voter privacy shall be preserved during the process of recording, verifying and

auditing his or her ballot selections.

Discussion: The privacy requirements from Section 3 also apply to voting equipment

with VVPAT.

b. When a VVPAT with a spool-to-spool continuous paper record is used, a means shall

be provided to preserve the secrecy of the paper record of voter selections.

c. When a VVPAT with a spool-to-spool continuous paper record is used, no record

shall be maintained of which voters used which voting machine or the order in which

they voted.

d. The electronic and paper records shall be created and stored in ways that preserve the

privacy of the voter.

Discussion: For VVPAT systems that use separate pieces of paper for the record, this

can be accomplished in various ways including shuffling the order of

the records or other methods to separate the order of stored records.

e. The privacy of voters whose paper records contain an alternative language shall be

maintained.

f. Unique identifiers shall not be displayed in a way that is easily memorable by the

voter.

Discussion: Unique identifiers on the paper record are displayed or formatted in such

a way that they are not memorable to voters, such as by obscuring them

in other characters.

g. Both paper rolls and paper record secure receptacles shall be controlled,

protected, and preserved with the same security as a ballot box.
7.9.6 VVPAT Usability

a. All usability requirements from Subsection 3.1 shall apply to voting machines with

VVPAT.

Discussion: The requirements in this section are in addition to those in

Subsection 3.1.

b. The voting equipment shall be capable of showing the information on the paper in a

font size of at least 3.0 mm and should be capable of showing the information in at

least two font ranges; 3.0-4.0 mm, and 6.3-9.0 mm, under control of the voter or poll

worker.

Discussion: In keeping with requirements in Subsection 3.1, the paper record should

use the same font sizes as displayed by the voting machine, but at least

be capable of 3.0 mm. While larger font sizes may assist voters with

poor vision, certain disabilities such as tunnel vision are best addressed

by smaller font sizes.

c. The voting equipment shall display, print and store the paper record in any of the

written alternative languages chosen for the ballot.

i. To assist with manual auditing, candidate names on the paper record shall be

presented in the same language as used on the DRE summary screen.

ii. Information on the paper record not needed by the voter to perform verification

shall be in English.

Discussion: In addition to the voter ballot selections, the marking of the paper record

as accepted or void, and the indication of the ballot page number need to

be printed in the alternative language. Other information, such as

precinct and election identifiers, shall be in English to facilitate use of

the paper record for auditing.

d. The paper and electronic records shall be presented to allow the voter to read and

compare the records without the voter having to shift his or her position.

e. If the paper record cannot be displayed in its entirety on a single page, a means shall

be provided to allow the voter to view the entire record.

Discussion: Possible solutions include scrolling the paper or printing a new sheet of

paper. The voter should be notified if it is not possible to scroll in

reverse, so they will know to complete verification in one pass.

f. If the paper record cannot be displayed in its entirety on a single page, each page of

the record shall be numbered and shall include the total count of pages for the record.

Discussion: Possible numbering schemes include “Page X of Y.”

g. The instructions for performing the verification process shall be made available to the

voter in a location on the voting machine.

Discussion: All instructions must meet the usability requirements contained in

Subsection 3.1.

7.9.7 VVPAT Accessibility

a. All accessibility requirements from Subsection 3.2 shall apply to voting machines

with VVPAT.

b. If the normal voting procedure includes VVPAT, the accessible voting equipment

should provide features that enable voters who are visually impaired and voters with

an unwritten language to perform this verification. If state statute designates the paper

record produced by the VVPAT to be the official ballot or the determinative record
on a recount, the accessible voting equipment shall provide features that enable

visually impaired voters and voters with an unwritten language to review the paper

record.

Discussion: For example, the accessible voting equipment might provide an

automated reader that converts the paper record contents into audio

output.

8 Quality Assurance Requirements

Table of Contents

8 Quality Assurance Requirements................................................................. 147

8.1 Scope.................................................................................................. 147

8.2 General Requirements ..................................................................... 147

8.3 Components from Third Parties..................................................... 148

8.4 Responsibility for Tests.................................................................... 148

8.5 Parts and Materials Special Tests and Examinations................... 148

8.6 Quality Conformance Inspections .................................................. 148

8.7 Documentation.................................................................................. 149

8 Quality Assurance Requirements

8.1Scope

Quality assurance provides continuous confirmation that a voting system conforms with the

Guidelines and to the requirements of state and local jurisdictions. Quality assurance is a

vendor function that is initiated prior to system development and continues throughout the

maintenance life cycle of the voting system. Quality assurance focuses on building quality

into a voting system and reducing dependence on system tests at the end of the life cycle to

detect deficiencies, thus helping ensure the system:

• Meets stated requirements and objectives

• Adheres to established standards and conventions

• Functions consistently with related components and meets dependencies for use

within the jurisdiction

• Reflects all changes approved during its initial development, internal testing, national

certification, and, if applicable, state certification processes

8.2 General Requirements

The voting system vendor is responsible for designing and implementing a quality assurance

program to ensure that the design, workmanship, and performance requirements are achieved

in all delivered systems and components. At a minimum, this program shall:

a. Include procedures for specifying, procuring, inspecting, accepting, and controlling

parts and raw materials of the requisite quality

b. Require the documentation of the hardware and software development process

c. Identify and enforce all requirements for:
i. In-process inspection and testing that the manufacturer deems necessary to

ensure proper fabrication and assembly of hardware

ii. Installation and operation of software and firmware

d. Include plans and procedures for post-production environmental screening and

acceptance testing

e. Include a procedure for maintaining all data and records required to document and

verify the quality inspections and tests

8.3 Components from Third Parties

A vendor who does not manufacture all the components of its voting system, but instead

procures components as standard commercial items for assembly and integration into a

voting system, shall verify that the supplier vendors follow documented quality assurance

procedures that are at least as stringent as those used internally by the voting system vendor.

8.4 Responsibility for Tests

The manufacturer or vendor shall be responsible for performing all quality assurance tests,

acquiring and documenting test data, and providing test reports for examination by the test

lab as part of the national certification process. These reports shall also be provided to the

purchaser upon request.

8.5 Parts and Materials Special Tests and Examinations

In order to ensure that voting system parts and materials function properly, vendors shall:

a. Select parts and materials to be used in voting systems and components according to

their suitability for the intended application. Suitability may be determined by

similarity of this application to existing standard practice or by means of special tests

b. Design special tests, if needed, to evaluate the part or material under conditions

accurately simulating the actual voting system operating environment

c. Maintain the resulting test data as part of the quality assurance program

documentation

8.6 Quality Conformance Inspections

The vendor performs conformance inspections to ensure the overall quality of the voting

system and components delivered to the test lab for national certification testing and to the

jurisdiction for implementation.

To meet the conformance inspection requirements the vendor or manufacturer shall:

a. Inspect and test each voting system or component to verify that it meets all inspection

and test requirements for the system

b. Deliver a record of tests or a certificate of satisfactory completion with each system

or component

8.7 Documentation

Vendors are required to produce documentation to support the independent testing required

for their products to be granted national certification. Volume II, Section 2, Description of

the Technical Data Package, identifies the documentation required for the national

certification testing process. This documentation shall be sufficient to serve the needs of the
test lab, election officials, and maintenance technicians. It shall be prepared and published in

accordance with standard commercial practice for information technology and electronic and

mechanical equipment. It shall include, at a minimum, the following:

• System overview

• System functionality description

• System hardware specification

• Software design and specifications

• System security specification

• System test and verification specification

• System operations procedures

• System maintenance procedures

• Personnel deployment and training requirements

• Configuration management plan

• Quality assurance program

• System change notes

9 Configuration Management Requirements

Table of Contents

9 Configuration Management Requirements .................................................. 153

9.1 Scope.................................................................................................. 153

9.1.1 Configuration Management Requirements.................................... 153

9.1.2 Organization of Configuration Management Requirements ......... 153

9.1.3 Application of Configuration Management Requirements ........... 154

9.2 Configuration Management Policy................................................. 154

9.3 Configuration Identification............................................................ 154

9.3.1 Classification and Naming Configuration Items ........................... 154

9.3.2 Versioning Conventions ................................................................155

9.4 Baseline and Promotion Procedures............................................... 155

9.5 Configuration Control Procedures ................................................. 155

9.6 Release Process ................................................................................. 156

9.7 Configuration Audits ....................................................................... 156

9.7.1 Physical Configuration Audit ........................................................156

9.7.2 Functional Configuration Audit ....................................................157

9.8 Configuration Management Resources.......................................... 157

9 Configuration Management Requirements

9.1 Scope

This section contains specific requirements for configuration management of voting systems.

For the purpose of the Guidelines, configuration management is defined as a set of activities

and associated practices that ensures full knowledge and control of the components of a

system, starting with its initial development and progressing through its ongoing maintenance
and enhancement. This section describes activities in terms of their purposes and outcomes.

It does not describe specific procedures or steps to be employed to accomplish them. Specific

steps and procedures are left to the vendor to select.

Vendors are required to submit these procedures as part of the Technical Data Package for

system certification. State or local election legislation, regulations, or contractual agreements

may require the vendor to conform to additional requirements for configuration management

or to adopt specific required procedures. EAC and state and local election officials reserve

the right to inspect vendor facilities and operations to determine conformance with the

vendor’s reported procedures and with these requirements.

9.1.1 Configuration Management Requirements

Configuration management addresses a broad set of record keeping, auditing, and reporting

activities that contribute to full knowledge and control of a system and its components. These

activities include:

• Identifying discrete system components

• Creating records of a formal baseline and later versions of components

• Controlling changes made to the system and its components

• Releasing new versions of the system

• Auditing the system, including its documentation, against configuration management

records

• Controlling interfaces to other systems

• Identifying tools used to build and maintain the system

9.1.2 Organization of Configuration Management Requirements

The requirements for configuration management include:

• Application of configuration management requirements

• Configuration management policy

• Configuration identification

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• Baseline, promotion, and demotion procedures

• Configuration control procedures

• Release process

• Configuration audits

• Configuration management resources

9.1.3 Application of Configuration Management Requirements

Requirements for configuration management apply to all components of voting systems

regardless of the specific technologies employed. These components include:

• Software

• Hardware

• Communications

• Documentation

• Identification and naming conventions (including changes to these conventions) for
software programs and data files

• Development and testing artifacts such as test data and scripts

• File archiving and data repositories

9.2 Configuration Management Policy

The vendor shall describe its policies for configuration management in the Technical Data

Package. This description shall address the following elements:

• Scope and nature of configuration management program activities

• Breadth of application of the vendor’s policies and practices to the voting system, i.e.,

extent to which policies and practices apply to the total system, and extent to which

policies and practices of suppliers apply to particular components, subsystems or

other defined system elements

9.3 Configuration Identification

Configuration identification is the process of identifying, naming, and acquiring

configuration items. Configuration identification encompasses all system components.

9.3.1 Classification and Naming Configuration Items

The vendor shall describe the procedures and conventions used to classify configuration

items into categories and subcategories, uniquely number or otherwise identify configuration

items and name configuration items.

9.3.2 Versioning Conventions

When a system component is part of a higher level system element such as a subsystem, the

vendor shall describe the conventions used to:

a. Identify the specific versions of individual configuration items and sets of items that

are incorporated in higher level system elements such as subsystems

b. Uniquely number or otherwise identify versions

c. Name versions

9.4 Baseline and Promotion Procedures

The vendor shall establish formal procedures and conventions for establishing and providing

a complete description of the procedures and related conventions used to:

a. Establish a particular instance of a component as the starting baseline

b. Promote subsequent instances of a component to baseline status as development

progresses through to completion of the initial completed version released to the

accredited test lab for testing

c. Promote subsequent instances of a component to baseline status as the component is

maintained throughout its life cycle until system retirement (i.e., the system is no

longer sold or maintained by the vendor)

9.5 Configuration Control Procedures

Configuration control is the process of approving and implementing changes to a

configuration item to prevent unauthorized additions, changes or deletions. The vendor shall

establish such procedures and related conventions, providing a complete description of those
procedures used to:

a. Develop and maintain internally developed items

b. Acquire and maintain third-party items

c. Resolve internally identified defects for items regardless of their origin

d. Resolve externally identified and reported defects (i.e., by customers and accredited

test labs)

9.6 Release Process

The release process is the means by which the vendor installs, transfers or migrates the

system to the accredited test lab and, eventually, to its customers. The vendor shall establish

such procedures and related conventions, providing a complete description of those used to:

a. Perform a first release of the system to an accredited test lab

b. Perform a subsequent maintenance or upgrade release of the system or particular

components, to an accredited test lab

c. Perform the initial delivery and installation of the system to a customer, including

confirmation that the installed version of the system matches exactly the certified

system version

d. Perform a subsequent maintenance or upgrade release of the system or a particular

component to a customer, including confirmation that the installed version of the

system matches exactly the certified system version

9.7 Configuration Audits

The Guidelines require two types of configuration audits: Physical Configuration Audits

(PCA) and Functional Configuration Audits (FCA).

9.7.1 Physical Configuration Audit

The Physical Configuration Audit is conducted by the accredited test lab to compare the

voting system components submitted for certification to the vendor’s technical

documentation.

For the PCA, a vendor shall provide:

a. Identification of all items that are to be a part of the software release

b. Specification of compiler (or choice of compilers) to be used to generate executable

programs

c. Identification of all hardware that interfaces with the software

d. Configuration baseline data for all hardware that is unique to the system

e. Copies of all software documentation intended for distribution to users, including

program listings, specifications, operations manual, voter manual, and maintenance

manual

f. User acceptance test procedures and acceptance criteria

g. Identification of any changes between the physical configuration of the system

submitted for the PCA and that submitted for the FCA, with a certification that any

differences do not degrade the functional characteristics

h.Complete descriptions of its procedures and related conventions used to support this

audit by:

i. Establishing a configuration baseline of the software and hardware to be tested

ii. Confirming whether the system documentation matches the corresponding
system components

9.7.2 Functional Configuration Audit

The Functional Configuration Audit is conducted by the accredited test lab to verify that the

system performs all the functions described in the system documentation. The vendor shall:

a. Completely describe its procedures and related conventions used to support this audit

for all system components

b. Provide the following information to support this audit:

i. Copies of all procedures used for module or unit testing, integration testing, and

system testing

ii. Copies of all test cases generated for each module and integration test, and

sample ballot formats or other test cases used for system tests

iii. Records of all tests performed by the procedures listed above, including error

corrections and retests

In addition to such audits performed by the accredited test lab during the national

certification process, elements of this audit may also be performed by state election

organizations during the system certification process and individual jurisdictions during

system acceptance testing.

9.8 Configuration Management Resources

Often, configuration management activities are performed with the aid of automated tools.

Assuring that such tools are available throughout the system life cycle--including whether the

vendor is acquired by or merged with another organization--is critical to effective

configuration management. Vendors may choose the specific tools they use to perform the

record keeping, auditing, and reporting activities of the configuration management standards.

The resources documentation requirements focus on assuring that procedures are in place to

record information about the tools to help ensure that they, and the data they contain, can be

transferred effectively and promptly to a third party should the need arise. Within this

context, a vendor is required to develop and provide a complete description of the procedures

and related practices for maintaining information about:

a. Specific tools used, current version, and operating environment specifications

b. Physical location of the tools, including designation of computer directories and files

c. Procedures and training materials for using the tools

Appendix A: Glossary

Table of Contents

A Glossary.......................................................................................................A-3

A.1 Glossary ............................................................................................. A-3

A.2 Sources ............................................................................................... A-20

Appendix A: Glossary

This glossary contains terms needed to understand voting systems and related areas such as
security, human factors, and testing. Sources consulted in preparing the definitions are listed

in section A.2.

A.1 Glossary

A

abandoned ballot: Ballot that the voter did not place in the ballot box or record as cast on

DRE before leaving the polling place

absentee ballot: Ballot cast by a voter unable to vote in person at his or her polling place on

election day

acceptance testing: Examination of a voting system and its components by the purchasing

election authority (usually in a simulated-use environment) to validate performance of

delivered units in accordance with procurement requirements, and to validate that the

delivered system is, in fact, the certified system purchased

Access Board: Independent federal agency whose primary mission is accessibility for people

with disabilities and a leading source of information on accessible design

accessibility: Measurable characteristics that indicate the degree to which a system is

available to, and usable by, individuals with disabilities. The most common disabilities

include those associated with vision, hearing and mobility, as well as cognitive disabilities.

accessible voting station: Voting station equipped for individuals with disabilities

accreditation: Formal recognition that a laboratory is competent to carry out specific tests or

calibrations

accreditation body: (1) Authoritative body that performs accreditation (2) An independent

organization responsible for assessing the performance of other organizations against a

recognized standard, and for formally confirming the status of those that meet the standard

accuracy: (1) Extent to which a given measurement agrees with an accepted standard for that

measurement (2) Closeness of the agreement between the result of a measurement and a true

value of the particular quantity subject to measurement. Accuracy is a qualitative concept and

is not interchangeable with precision.

accuracy for voting systems: Ability of the system to capture, record, store, consolidate and

report the specific selections and absence of selections, made by the voter for each ballot

position without error. Required accuracy is defined in terms of an error rate that for testing

purposes represents the maximum number of errors allowed while processing a specified

volume of data.

adequate security: Security commensurate with the risk and the magnitude of harm resulting

from the loss, misuse, unauthorized access to, or modification of, information. This includes

ensuring that systems and applications operate effectively and provide appropriate

confidentiality, integrity, and availability, through the use of cost-effective management,

personnel, operational, and technical controls.

alternative format: The ballot or accompanying information is said to be in an alternative

format if it is in a representation other than the standard ballot language and format.

Examples include, but are not limited to languages other than English, Braille, ASCII text,

large print, recorded audio.

audio ballot: a ballot in which a set of offices is presented to the voter in spoken, rather than
written, form

audio-tactile interface (ATI): Voter interface designed to not require visual reading of a

ballot. Audio is used to convey information to the voter and sensitive tactile controls allow

the voter to communicate ballot selections to the voting system.

audit: Systematic, independent, documented process for obtaining records, statements of fact

or other relevant information and assessing them objectively to determine the extent to which

specified requirements are fulfilled

audit trail: Recorded information that allows election officials to review the activities that

occurred on the voting equipment to verify or reconstruct the steps followed without

compromising the ballot or voter secrecy

audit trail for direct-recording equipment: Paper printout of votes cast, produced by

direct-recording electronic (DRE) voting machines, which election officials may use to

crosscheck electronically tabulated totals

availability: The percentage of time during which a system is operating properly and

available for use

B

ballot: The official presentation of all of the contests to be decided in a particular election.

See also, audio ballot, ballot image, video ballot, electronic voter interface.

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ballot configuration: Particular set of contests to appear on the ballot for a particular

election district, their order, the list of ballot positions for each contest, and the binding of

candidate names to ballot positions

ballot counter: Process in a voting device that counts the votes cast in an election

ballot counting logic: The software logic that defines the combinations of voter choices that

are valid and invalid on a given ballot and that determines how the vote choices are totaled in

a given election

ballot format: The concrete presentation of the contents of a ballot appropriate to the

particular voting technology being used. The contents may be rendered using various

methods of presentation (visual or audio), language or graphics.

ballot image: Electronically produced record of all votes cast by a single voter. See also cast

vote record.

ballot instructions: Information provided to the voter during the voting session that

describes the procedure for executing a ballot. Such material may (but need not) appear

directly on the ballot.

ballot measure: (1) A question that appears on the ballot for approval or rejection. (2) A

contest on a ballot where the voter may vote yes or no.

ballot position: A specific place in a ballot where a voter's selection for a particular contest

may be indicated. Positions may be connected to row and column numbers on the face of a

voting machine or ballot, particular bit positions in a binary record of a ballot (for example,

an electronic ballot image), the equivalent in some other form. Ballot positions are bound to

specific contests and candidate names by the ballot configuration.

ballot preparation: Selecting the specific contests and questions to be contained in a ballot

format and related instructions; preparing and testing election-specific software containing
these selections; producing all possible ballot formats; and validating the correctness of ballot

materials and software containing these selections for an upcoming election

ballot production: Process of generating ballots for presentation to voters, e.g., printing

paper ballots or configuring the ballot presentation on a DRE

ballot rotation: Process of varying the order of the candidate names within a given contest

ballot scanner: Device used to read the voter selection data from a paper ballot or ballot card

ballot style: See ballot configuration

C

candidate: Person contending in a contest for office. A candidate may be explicitly

presented as one of the choices on the ballot or may be a write-in candidate.

candidate register: Record that reflects the total votes cast for the candidate. This record is

augmented as each ballot is cast on a DRE or as digital signals from the conversion of voted

paper ballots are logically interpreted and recorded.

canvass: Compilation of election returns and validation of the outcome that forms the basis

of the official results by political subdivision

cast ballot: Ballot that has been deposited by the voter in the ballot box or electronically

submitted for tabulation

cast vote record: Permanent record of all votes produced by a single voter whether in

electronic, paper or other form. Also referred to as ballot image when used to refer to

electronic ballots.

catastrophic system failure: Total loss of function or functions, such as the loss or

unrecoverable corruption of voting data or the failure of an on board battery of volatile

memory

central count voting system: A voting system that tabulates ballots from multiple precincts

at a central location. Voted ballots are placed into secure storage at the polling place. Stored

ballots are transported or transmitted to a central counting place which produces the vote

count report.

certification: Procedure by which a third party gives written assurance that a product,

process or service conforms to specified requirements. See also state certification and

national certification.

certification testing: Testing performed under either national or state certification processes

to verify voting system conformance to requirements

challenged ballot: Ballot provided to an individual who claim they are registered and

eligible to vote but whose eligibility or registration status cannot be confirmed when they

present themselves to vote. Once voted, such ballots must be kept separate from other ballots

and are not included in the tabulation until after the voter’s eligibility is confirmed. Michigan

is an exception in that they determine voter eligibility before a ballot is issued. See also

provisional ballot

checksum: Value computed from the content of a document or data record. Typically this is

the sum of the numeric representations of all the characters in the text. Checksums are used

to aid in detecting errors or alterations during transmission or storage.

claim of conformance: Statement by a vendor declaring that a specific product conforms to

a particular standard or set of standard profiles; for voting systems, NASED qualification or

EAC certification provides independent verification of a claim

closed primary: Primary election in which voters receive a ballot listing only those
candidates running for office in the political party with which the voters are affiliated. In

some states, non-partisan contests and ballot issues may be included. In some cases, political

parties may allow unaffiliated voters to vote in their party’s primary

commercial off-the-shelf (COTS): Commercial, readily available hardware devices (such as

card readers, printers or personal computers) or software products (such as operating

systems, programming language compilers, or database management systems)

Common Industry Format (CIF): Refers to the format described in ANSI/INCITS 354-

2001 "Common Industry Format (CIF) for Usability Test Reports

component: Element within a larger system; a component can be hardware or software. For

hardware, it is a physical part of a subsystem that can be used to compose larger systems

(e.g., circuit boards, internal modems, processors, computer memory). For software, it is a

module of executable code that performs a well-defined function and interacts with other

components.

confidentiality: Prevention of unauthorized disclosure of information

configuration management: Discipline applying technical and administrative direction and

surveillance to identify and document functional and physical characteristics of a

configuration item, control changes to these characteristics, record and report change

processing and implementation status, and verify compliance with specified requirements

configuration management plan: Document detailing the process for identifying,

controlling and managing various released items (such as code, hardware and documentation)

configuration status accounting: An element of configuration management, consisting of

the recording and reporting of information needed to manage a configuration effectively.

This includes a listing of the approved configuration identification, the status of proposed

changes to the configuration, and the implementation status of approved changes.

conformance: Fulfillment of specified requirements by a product, process or service

conformance testing: Process of testing an implementation against the requirements

specified in one or more standards. The outcomes of a conformance test are generally a pass

or fail result, possibly including reports of problems encountered during the execution. Also

known as certification testing.

contest: Decision to be made within an election, which may be a contest for office or a

referendum, proposition and/or question. A single ballot may contain one or more contests.

count: Process of totaling votes. See tabulation.

counted ballot: Ballot that has been processed and whose votes are included in the

candidates and measures vote totals

corrective action: Action taken to eliminate the causes of an existing deficiency or other

undesirable situation in order to prevent recurrence

cross filing: Endorsement of a single candidate or slate of candidates by more than one

political party. The candidate or slate appears on the ballot representing each endorsing

political party. Also referred to as cross-party endorsement.

cryptographic key: Value used to control cryptographic operations, such as decryption,

encryption, signature generation or signature verification

cryptography: Discipline that embodies the principles, means, and methods for the

transformation of data in order to hide their semantic content, prevent their unauthorized use,

prevent their undetected modification and establish their authenticity

cumulative voting: A method of voting exclusive to multi-member district election (e.g.

county board) in which each voter may cast as many votes as there are seats to be filled and
may cast two or more of those votes for a single candidate

D

data accuracy: (1) Data accuracy is defined in terms of ballot position error rate. This rate

applies to the voting functions and supporting equipment that capture, record, store,

consolidate and report the specific selections, and absence of selections, made by the voter

for each ballot position. (2) The system's ability to process voting data absent internal errors

generated by the system. It is distinguished from data integrity, which encompasses errors

introduced by an outside source.

data integrity: Invulnerability of the system to accidental intervention or deliberate,

fraudulent manipulation that would result in errors in the processing of data. It is

distinguished from data accuracy that encompasses internal, system-generated errors.

decertification: Revocation of national or state certification of voting system hardware and

software

decryption: Process of changing encrypted text into plain text

device: Functional unit that performs its assigned tasks as an integrated whole

digital signature: An asymmetric key operation where the private key is used to digitally

sign an electronic document and the public key is used to verify the signature. Digital

signatures provide data authentication and integrity protection

direct-recording electronic (DRE) voting system: An electronic voting system that utilizes

electronic components for the functions of ballot presentation, vote capture, vote recording,

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and tabulation which are logically and physically integrated into a single unit. A DRE

produces a tabulation of the voting data stored in a removable memory component and in

printed hardcopy.

directly verifiable: Voting system feature that allows the voter to verify at least one

representation of his or her ballot with his/her own senses, not using any software or

hardware intermediary. Examples include a marksense paper ballot and a DRE with a voter

verifiable paper record feature.

disability: With respect to an individual; (1) a physical or mental impairment that

substantially limits one or more of the major life activities of such individual; (2) a record of

such an impairment; (3) being regarded as having such an impairment (definition from the

Americans with Disabilities Act).

dynamic voting system software: Software that changes over time once it is installed on the

voting equipment. See also voting system software.

E

EAC: Election Assistance Commission (www.eac.gov)

early voting: Broadly, voting conducted before election day where the voter completes the

ballot in person at a county office or other designated polling place or ballot drop site prior to

election day

election: A formal process of selecting a person for public office or of accepting or rejecting

a political proposition by voting
election databases: Data file or set of files that contain geographic information about

political subdivisions and boundaries, all contests and questions to be included in an election,

and the candidates for each contest

election definition: Definition of the contests and questions that will appear on the ballot for

a specific election

election district: Contiguous geographic area represented by a public official who is elected

by voters residing within the district boundaries. The district may cover an entire state or

political subdivision, may be a portion of the state or political subdivision, or may include

portions of more than one political subdivision.

election management system: Set of processing functions and databases within a voting

system that defines, develops and maintains election databases, performs election definitions

and setup functions, format ballots, count votes, consolidates and report results, and

maintains audit trails

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election officials: The people associated with administering and conducting elections,

including government personnel and poll workers

election programming: Process by which election officials or their designees use voting

system software to logically define the ballot for a specific election

electronic cast vote record: An electronic version of the cast vote record

electronic voter interface: Subsystem within a voting system which communicates ballot

information to a voter in video, audio or other alternative format which allows the voter to

select candidates and issues by means of vocalization or physical actions

electronic voting machine: Any system that utilizes an electronic component. Term is

generally used to refer to DREs. See also voting equipment, voting system.

electronic voting system: An electronic voting system is one or more integrated devices

that utilize an electronic component for one or more of the following functions: ballot

presentation, vote capture, vote recording, and tabulation. A DRE is a functionally and

physically integrated electronic voting system which provides all four functions

electronically in a single device. An optical scan (also known as marksense) system where

the voter marks a paper ballot with a marking instrument and then deposits the ballot in a

tabulation device is partially electronic in that the paper ballot provides the presentation, vote

capture and vote recording functions. An optical scan system employing a ballot marking

device adds a second electronic component for ballot presentation and vote capture functions.

encryption: Process of obscuring information by changing plain text into ciphertext for the

purpose of security or privacy. See also cryptography and decryption.

error correcting code: coding system that allows data being read or transmitted to be

checked for errors and, when detected, corrects those errors

F

Federal Information Processing Standards: Standards for federal computer systems

developed by NIST. These standards are developed when there are no existing industry

standards to address federal requirements for system interoperability, portability of data and

software, and computer security.

firmware: Computer programming stored in programmable read-only memory thus
becoming a permanent part of the computing device. It is created and tested like software.

Functional Configuration Audit (FCA): Exhaustive verification of every system function

and combination of functions cited in the vendor’s documentation. The FCA verifies the

accuracy and completeness of the system’s Voter Manual, Operations Procedures,

Maintenance Procedures, and Diagnostic Testing Procedures.

functional test: Test performed to verify or validate the accomplishment of a function or a

series of functions

G

general election: Election in which voters, regardless of party affiliation, are permitted to

select candidates to fill public office and vote on ballot issues

guidelines: See product standard

H

hash: Algorithm that maps a bit string of arbitrary length to a fixed-length bit string.

hash function: A function that maps a bit string of arbitrary length to a fixed length bit

string. Approved hash functions satisfy the following properties: 1. (One-way) It is

computationally infeasible to find any input that maps to any pre-specified output, and 2.

(Collision resistant) It is computationally infeasible to find any two distinct inputs that map

to the same output.

I

indirectly verifiable: Voting system feature that allows a voter to verify his or her

selections via a hardware or software intermediary. An example is a touch screen DRE where

the voter verifies the ballot selections through the assistance of audio stimuli.

implementation statement: Statement by a vendor indicating the capabilities, features, and

optional functions as well as extensions that have been implemented. Also known as

implementation conformance statement.

Independent Testing Authority (ITA): Replaced by “accredited testing laboratories” and

“test labs.” Prior usage referred to independent testing organizations accredited by the

National Association of State Election Directors (NASED) to perform voting system

qualification testing.

information security: Protecting information and information systems from unauthorized

access, use, disclosure, disruption, modification, or destruction in order to provide integrity,

confidentiality, and availability

inspection: Examination of a product design, product, process or installation and

determination of its conformity with specific requirements or, on the basis of professional

judgment, with general requirements. Inspection of a process may include inspection of

staffing, facilities, technology and methodology.

integrity: Guarding against improper information modification or destruction, and ensuring

information non-repudiation and authenticity

internal audit log: A human readable record, resident on the voting machine, used to track

all activities of that machine. This log records every activity performed on or by the machine

indicating the event and when it happened.
K

key management: Activities involving the handling of cryptographic keys and other related

security parameters (e.g., passwords) during the entire life cycle of the keys, including their

generation, storage, establishment, entry and output, and zeroization.

L

logic and accuracy testing: Testing of the tabulator setups of a new election definition to

ensure that the content correctly reflects the election being held (i.e., contests, candidates,

number to be elected, ballot styles) and that all voting positions can be voted for the

maximum number of eligible candidates and that results are accurately tabulated and

reported.

logical correctness: Condition signifying that, for a given input, a computer program will

satisfy the program specification and produce the required output

M

marksense: System by which votes are recorded by means of marks made in voting response

fields designated on one or both faces of a ballot card or series of cards. Marksense systems

may use an optical scanner or similar sensor to read the ballots. Also known as optical scan.

measure register: Record that reflects the total votes cast for and against a specific ballot

issue. This record is augmented as each ballot is cast on a DRE or as digital signals from the

conversion of voted paper ballots are logically interpreted and recorded.

mechanical lever voting machine: Machine that directly records a voter’s choices via

mechanical lever-actuated controls into a counting mechanism that tallies the votes without

using a physical ballot

multi-seat contest: Contest in which multiple candidates can run, up to a specified number

of seats. Voters may vote for no more than the specified number of candidates

N

NASED: National Association of State Election Directors, (www.nased.org)

national certification testing: Examination and testing of a voting system to determine if

the system complies with the performance and other requirements of the national certification

standards and with its own specifications

national certification test report: Report of results of independent testing of a voting

system by an accredited test lab delivered to the EAC with a recommendation regarding

granting a certification number

NIST: National Institute of Standards and Technology

non-partisan office: Elected office for which candidates run without political party

affiliation

nonvolatile memory: Memory in which information can be stored indefinitely with no

power applied. ROMs and PROMs are examples of nonvolatile memory.

NVLAP: The National Voluntary Laboratory Accreditation Program operated by NIST

O

open primary: Primary election in which any voters can participate, regardless of their

political affiliation. Some states require voters to publicly declare their choice of party ballot
at the polling place, after which the poll worker provides or activates the appropriate ballot.

Other states allow the voters to make their choice of party ballot within the privacy of the

voting booth.

operational environment: All software, hardware (including facilities, furnishings and

fixtures), materials, documentation, and the interface used by the election personnel,

maintenance operator, poll worker, and voter, required for voting equipment operations.

optical scan, optical scan system: System by which votes are recorded by means of marks

made in voting response fields designated on one or both faces of a ballot card or series of

cards. An optical scan system reads and tabulates ballots, usually paper ballots, by scanning

the ballot and interpreting the contents. Also known as marksense.

overvote: Voting for more than the maximum number of selections allowed in a contest

P

paper-based voting system: Voting system that records votes, counts votes, and tabulates

the vote count, using one or more ballot cards or paper ballots

paper record: Paper cast vote record that can be directly verified by a voter. See also ballot

image, cast vote record.

partisan office: An elected office for which candidates run as representatives of a political

party

personal assistive device: A device that is carried or worn by an individual with some

physical impairment whose primary purpose is to help compensate for that impairment

Physical Configuration Audit (PCA): Inspection by an accredited test laboratory that

compares the voting system components submitted for certification testing to the vendor’s

technical documentation and confirms that the documentation submitted meets the national

certification requirements. Includes witnessing of the build of the executable system to

ensure that the certified release is built from the tested components.

political subdivision: Any unit of government, such as counties and cities, school districts,

and water and conservation districts having authority to hold elections for public offices or

on ballot issues

polling location: Physical address of a polling place

polling place: Facility to which voters are assigned to cast in-person ballots

precinct: Election administration division corresponding to a contiguous geographic area

that is the basis for determining which contests and issues the voters legally residing in that

area are eligible to vote on

precinct count: Counting of ballots in the same precinct in which those ballots have been

cast

precinct count voting system: a voting system that tabulates ballots at the polling place.

These systems typically tabulate ballots as they are cast and print the results after the close of

polling. For DREs, and for some paper-based systems, these systems provide electronic

storage of the vote count and may transmit results to a central location over public

telecommunication networks.

precision: (1) Extent to which a given set of measurements of the same sample agree with

their mean. Thus, precision is commonly taken to be the standard deviation estimated from

sets of duplicate measurements made under conditions of repeatability, that is, independent

test results obtained with the same method on identical test material, in the same laboratory

or test facility, by the same operator using the same equipment within short intervals of time.
(2) Degree of refinement in measurement or specification, especially as represented by the

number of digits given.

primary election: Election held to determine which candidate will represent a political party

for a given office in the general election. Some states have an open primary, while others

have a closed primary. Sometimes elections for nonpartisan offices and ballot issues are held

during primary elections.

primary presidential delegation nomination: Primary election in which voters choose the

delegates to the presidential nominating conventions allotted to their states by the national

party committees

privacy: The ability to prevent others from determining how an individual voted

private key: The secret part of an asymmetric key pair that is typically used to digitally sign

or decrypt data

product standard: Standard that specifies requirements to be fulfilled by a product or a

group of products, to establish its fitness for purpose

provisional ballot: Ballot provided to individuals who claim they are registered and eligible

to vote but whose eligibility or registration status cannot be confirmed when they present

themselves to vote. Once voted, such ballots must be kept separate from other ballots and are

not included in the tabulation until after the voter’s eligibility is confirmed. In some

jurisdictions called an affidavit ballot. See also challenged ballot.

public key: Public part of an asymmetric key pair that is typically used to verify digital

signatures or encrypt data

public network direct-recording electronic (DRE) voting system: A DRE that transmits

vote counts to a central location over a public telecommunication network

Q

qualification number: A number issued by NASED (National Association of State Election

Directors) to a system that has been tested by an accredited Independent Testing Authority

for compliance with the voting system standards. Issuance of a qualification number

indicates that the system conforms to the national standards.

qualification test report: Report of results of independent testing of a voting system by an

Independent Test Authority documenting the specific system configuration tested, the scope

of tests conducted and when testing was completed.

qualification testing: Examination and testing of a voting system by a NASED-accredited

Independent Test Authority to determine if the system conforms to the performance and

other requirements of the national certification standards and the vendor’s own

specifications.

R

ranked order voting: Practice that allows voters to rank candidates in a contest in order of

choice: 1, 2, 3 and so on. A candidate receiving a majority of the first choice votes wins that

election. If no candidate receives a majority, the last place candidate is deleted, and all

ballots are counted again, with each ballot cast for the deleted candidate applied to the next

choice candidate listed on the ballot. The process of eliminating the last place candidate and

recounting the ballots continues until one candidate receives a majority of the vote. The

practice is also known as instant runoff voting, preferences or preferential voting, or choice

voting.
recall issue with options: Process that allows voters to remove elected representatives from

office prior to the expiration of their terms of office. The recall may involve not only the

question of whether a particular officer should be removed, but also the question of naming a

successor in the event that there is an affirmative vote for the recall.

recertification: Re-examination, and possibly retesting of a voting system that was modified

subsequent to receiving national and/or state certification. The object of is to determine if the

system as modified still conforms to the requirements.

recount: Retabulation of the votes cast in an election

referendum: Process whereby a state law or constitutional amendment may be referred to

the voters before it goes into effect

reproducibility: Ability to obtain the same test results by using the same test method on

identical test items in different testing laboratories with different operators using different

equipment

requirement: Provision that conveys criteria to be fulfilled

residual vote: Total number of votes that cannot be counted for a specific contest. There

may be multiple reasons for residual votes (e.g., declining to vote for the contest, overvoting

in a contest).

risk assessment: The process of identifying the risks to system security and determining the

probability of occurrence, the resulting impact, and safeguards that would mitigate this

impact

runoff election: Election to select a winner following a primary or a general election, in

which no candidate in the contest received the required minimum percentage of the votes

cast. The two candidates receiving the most votes for the contest in question proceed to the

runoff election.

S

secure receptacle: The container for storing VVPAT paper audit records

security analysis: An inquiry into the potential existence of security flaws in a voting

system. Includes an analysis of the system's software, firmware, and hardware, as well as the

procedures associated with system development, deployment, operation and management.

security controls: Management, operational, and technical controls (i.e., safeguards or

countermeasures) prescribed for an information system to protect the confidentiality,

integrity, and availability of the system and its information.

semi-static voting system software: Software that may change in response to the voting

equipment on which it is installed or to election-specific programming.

split precinct: A precinct that contains an election district subdivision, e.g., a water district

or school board district, requiring an additional ballot configuration

spoiled ballot: Ballot that has been voted but will not be cast

state certification: State examination and possibly testing of a voting system to determine its

compliance with state requirements for voting systems

static voting system software: Software that does not change based on the election being

conducted or the voting equipment upon which it is installed, e.g., executable code

straight party voting: Mechanism that allows voters to cast a single vote to select all

candidates on the ballot from a single political party

support software: Software that aids in the development, maintenance, or use of other

software, for example, compilers, loaders and other utilities
symmetric (secret) encryption algorithm: Encryption algorithms using the same secret key

for encryption and decryption

T

tabulation: Process of totaling votes. See also count.

t-coil: Inductive coil used in some hearing aids to allow reception of an audio band magnetic

field signal, instead of an acoustic signal. The magnetic or inductive mode of reception is

commonly used in conjunction with telephones, auditorium loop systems and other systems

that provide the required magnetic field output.

tabulator: Device that counts votes

technical data package: Vendor documentation relating to the voting system required to be

submitted with the system as a precondition of certification testing

telecommunications: Transmission, between or among points specified by the user, of

information of the user's choosing, without change in the form or content of the information

as sent and received

test: Technical operation that consists of the determination of one or more characteristics of a

given product, process or service according to a specified procedure

test campaign: Sum of the work by a voting system test lab on a single product or system

from contract through test plan, conduct of testing for each requirement (including hardware,

software, and systems), reporting, archiving, and responding to issues afterwards

testing standard: Standard that is concerned with test methods, sometimes supplemented

with other provisions related to testing, such as sampling, use of statistical methods or

sequence of tests

test method: Specified technical procedure for performing a test

test plan: Document created prior to testing that outlines the scope and nature of testing,

items to be tested, test approach, resources needed to perform testing, test tasks, risks and

schedule

touch screen voting machine: A voting machine that utilizes a computer screen to display

the ballot and allows the voter to indicate his or her selections by touching designated

locations on the screen

U

undervote: Occurs when the number of choices selected by a voter in a contest is less than

the maximum number allowed for that contest or when no selection is made for a single

choice contest

usability: Effectiveness, efficiency and satisfaction with which a specified set of users can

achieve a specified set of tasks in a particular environment. Usability in the context of voting

refers to voters being able to cast valid votes as they intended quickly, without errors, and

with confidence that their ballot choices were recorded correctly. It also refers to the

usability of the setup and operation in the polling place of voting equipment.

usability testing: Encompasses a range of methods that examine how users in the target

audience actually interact with a system, in contrast to analytic techniques such as usability

inspection

V
valid vote: Vote from a ballot or ballot image that is legally acceptable according to state law

validation: Process of evaluating a system or component during or at the end of the

development process to determine whether it satisfies specified requirements

verification: Process of evaluating a system or component to determine whether the

products of a given development phase satisfy the conditions (such as specifications)

imposed at the start of the phase

video ballot: Electronic voter interface which presents ballot information and voting

instructions as video images. See also ballot.

vote for N of M: A ballot choice in which voters are allowed to vote for a specified number

(“N”) of candidates in a multi-seat (“M”) contest

voted ballot: Ballot that contains all of a voter's selections and has been cast

voter verifiable: A voting system feature that provides the voter an opportunity to verify that

his or her ballot selections are being recorded correctly, before the ballot is cast

voter verifiable audit record: Human-readable printed record of all of a voter’s selections

presented to the voter to view and check for accuracy

voting equipment: All devices, including the voting machine, used to display the ballot,

accept voter selections, record voter selections, and tabulate the votes

voting machine: The mechanical, electromechanical and electric components of a voting

system that the voter uses to view the ballot, indicate their selections, verify their selections.

In some instances, the voting machine also casts and tabulates the votes. See voting

equipment.

voting officials: Term used to designate the group of people associated with elections,

including election personnel, poll workers, ballot designers and those responsible for the

installation, operation and maintenance of the voting systems.

voting position: Specific response field on a ballot where the voter indicates the selection of

a candidate or ballot proposition response

voting station: The location within a polling place where voters may record their votes. A

voting station includes the area, location, booth or enclosure where voting takes place as well

as the voting machine. See voting machine.

voting system: The total combination of mechanical, electromechanical or electronic

equipment (including the software, firmware, and documentation required to program,

control, and support the equipment) that is used to define ballots; to cast and count votes; to

report or display election results; and to maintain and produce any audit trail information;

and the practices and associated documentation used to identify system components and

versions of such components; to test the system during its development and maintenance; to

maintain records of system errors and defects; to determine specific system changes to be

made to a system after the initial qualification of the system; and to make available any

materials to the voter (such as notices, instructions, forms or paper ballots).

voting system software: All the executable code and associated configuration files needed

for the proper operation of the voting system. This includes third party software such as

operating systems, drivers, and database management tools. See also dynamic voting system

software, semi-static voting system software, and static voting system software.

voting system testing: Examination and testing of a computerized voting system by using

test methods to determine if the system complies with the requirements in the Voluntary

Voting System Guidelines and with its own specifications.

voting system test laboratory: Test laboratory accredited by the National Voluntary
Laboratory Accreditation Program (NVLAP) to be competent to test voting systems. When

NVLAP has completed its evaluation of a test lab, the Director of NIST will forward a

recommendation to the EAC for the completion of the accreditation process.

W

write-in voting: To make a selection of an individual not listed on the ballot. In some

jurisdictions, voters may do this by using a marking device to physically write their choice on

the ballot or they may use a keypad, touch screen or other electronic means to enter the

name.

A.2 Sources

Definitions in this glossary are either extracted from or based on the following sources:

44 U.S.C. 35 United States Code, Title 44, Chapter 35, Information Security,

Section 3542, Definitions.

ACM SIGCHI ACM's Special Interest Group on Computer-Human Interaction,

http://www.acm.org/sigchi/ (February 2005).

ADA Americans with Disabilities Act of 1990.

ANSI Dictionary American National Dictionary for Information Processing Systems,

American National Standards Committee X3, Information Processing

Systems, 1982.

ANSI 354 American National Standards Institute, International Committee for

Information Technology Standards, Common Industry Format for

Usability Test Reports, ANSI/INCITS 354-2001

ANSI C63.19 American National Standards for Methods of Measurement of

Compatibility between Wireless Communications Devices and

Hearing Aids, 2001.

electionline http://electionline.org/, (March 2005).

FIPS 81 Federal Information Processing Standard 81, DES Modes of

Operations, December, 1980.

FIPS 140-2 Federal Information Processing Standard 140-2, Security

Requirements for Cryptographic Modules, May 2001.

FIPS 199 Federal Information Processing Standard 199, Standards for Security

Categorization of Federal Information and Information Systems,

December 2003.

FIPS 201 Federal Information Processing Standard 201, Personal Identity

Verification for Federal Employees and Contractors, February 2005.

HAVA Help America Vote Act of 2002 - Public Law 107-252.

IEA International Ergonomics Association, http://www.iea.cc/, (February

2005).

IEEE 1583 IEEE P1583/D5.3.2 Draft Standard for the Evaluation of Voting

Equipment, December 6, 2004.

ISO 5725 ISO/IEC 5725:1994 Accuracy (trueness and precision) of measurement methods

and results.

ISO 9241 ISO/IEC 9241:1997 Ergonomic requirements for office work with

visual display terminals (VDT).

ISO 17000 ISO/IEC 17000:2004 Conformity assessment -- Vocabulary and
general principles.

ISO Guide 2-4 ISO/IEC Guide 2:2004 Standardization and related activities - General

vocabulary.

ISO Guide 2-6 ISO/IEC Guide 2:1996 Standardization and related activities - General

vocabulary.

NASS National Association of Secretaries of State Election Reform Key

Terms,

http://www.nass.org/Election%20Reform%20Key%20Terms.pdf

(February 2005).

NIST HB 143 NIST Handbook 143 State Weights and Measures Laboratories

Program Handbook.

NIST HB 150 NIST Handbook 150:2001 NVLAP Procedures and General

Requirements.

NIST HF Rpt. NIST Special Publication 500-256 Improving the Usability and

Accessibility of Voting Systems and Products, May 2004.

NIST SP 800-30 NIST Special Publication 800-30 Risk Management Guide for

Information Technology Systems, July 2002.

NIST SP 800-49 NIST Special Publication 800-49 Federal S/MIME V3 Client Profile,

November 2002.

NIST SP 800-53 NIST Special Publication 800-53 Recommended Security Controls for

Federal Information Systems, Appendix B, Glossary.

NIST SP 800-59 NIST Special Publication 800-59 Guideline for Identifying an

Information System as a National Security System, August 2003.

NIST SP 800-63 NIST Special Publication 800-63 Electronic Authentication Guideline:

Recommendations of the National Institute of Standards and

Technology, June 2004.

OMB A130 OMB Circular A-130, Appendix III.

Section 508 of the

Rehabilitation Act

of 1973, as

amended.

Electronic and Information Technology Accessibility Standards (2002)

Architectural and Transportation Barriers Compliance Board, 36 CRF

Part 1194, http://www.accessboard.gov/sec508/508standards.htm.

Usability Glossary Usability First Usability Glossary,

http://www.usabilityfirst.com/glossary/main.cgi, (February 2005).

VIM The ISO International Vocabulary of Basic and General Terms in

Metrology (VIM), 1994.

VSS 2002 Voting Systems Standards, Volumes I and II. Federal Election

Commission.

Whatis.com http://Whatis.com, IT Encyclopedia

Appendix B: References
Table of Contents

B References....................................................................................................B-3

B.1 Documents Incorporated in the Guidelines.................................... B-3

B.2 Other Documents Used in Developing the Guidelines .................. B-5

B.3 Legislation References ..................................................................... B-6

B.4 Additional References ...................................................................... B-7

Appendix B: References

B.1 Documents Incorporated in the Guidelines

The following publications have been incorporated into the Guidelines. When specific

provisions from these publications have been incorporated, specific references are made in

the body of the Guidelines.

Federal Regulations

Code of Federal Regulations, Title 29, Part 1910, Occupational Safety and Health Act

Code of Federal Regulations, Title 36, Part 1194, Architectural and Transportation Barriers

Compliance Board, Electronic and Information Technology Standards - Final Rule

Code of Federal Regulations, Title 47, Parts 15 and 18, Rules and Regulations of the Federal

Communications Commission

Code of Federal Regulations, Title 47, Part 15, “Radio Frequency Devices”, Subpart J,

“Computing Devices”, Rules and Regulations of the Federal Communications Commission

American National Standards Institute (ANSI)

ANSI C63.4 Methods of Measurement of Radio-Noise Emissions from LowVoltage Electrical and Electronic Equipment in the Range of 9Khz to

40 GHz

ANSI C63.19 American National Standard for Methods of Measurement of

Compatibility between Wireless Communication Devices and Hearing

Aids

ANSI-NCITS Industry Usability Reporting and the Common Industry Format

354-2001

International Electrotechnical Commission (IEC)

IEC 61000-4-2 Electromagnetic Compatibility (EMC) Part 4: Testing and

(1995-01) Measurement Techniques. Section 2 Electrostatic Discharge

Immunity Test (Basic EMC publication).

IEC 61000-4-3 Electromagnetic Compatibility (EMC) Part 4: Testing and

(1996) Measurement Techniques. Section 3 Radiated Radio-Frequency

Electromagnetic Field Immunity Test.

IEC 61000-4-4 Electromagnetic Compatibility (EMC) Part 4: Testing and

(1995-01) Measurement Techniques. Section 4 Electrical Fast Transient/Burst

Immunity Test.

IEC 61000-4-5 Electromagnetic Compatibility (EMC) Part 4: Testing and

(1995-02) Measurement Techniques. Section 5 Surge Immunity Test.

IEC 61000-4-6 Electromagnetic Compatibility (EMC) Part 4: Testing and

(1996-04) Measurement Techniques. Section 6 Immunity to Conducted

Disturbances Induced by Radio-Frequency Fields.
IEC 61000-4-8 Electromagnetic Compatibility (EMC) Part 4: Testing and

(1993-06) Measurement Techniques. Section 8 Power-Frequency Magnetic

Field Immunity Test. (Basic EMC publication).

IEC 61000-4-11 Electromagnetic Compatibility (EMC) Part 4: Testing and

(1994-06) Measurement Techniques. Section 11. Voltage Dips, Short

Interruptions and Voltage Variations Immunity Tests.

IEC 61000-5-7 Electromagnetic compatibility (EMC) Part 5-7: Installation and

Ed. 1.0 b:2001 mitigation guidelines—Degrees of protection provided by enclosures

against electromagnetic disturbances

National Institute of Standards and Technology

FIPS 140-2 Security Requirements for Cryptographic Modules

FIPS 180-2 Secure Hash Standard, August 2002

FIPS 186-2 Digital Signature Standard, February 2000

FIPS 188 Standard Security Label for Information Transfer

FIPS 196 Entity Authentication Using Public Key Cryptography

FIPS 197 Advanced Encryption Standard (AES)

SP 800-63 Electronic Authentication Guideline, Version 1.0.1

Military Standards

MIL-STD-498 Software Development and Documentation Standard, 1989

MIL-STD-810D(2) Environmental Test Methods and Engineering Guidelines, 19 July

B.2 Other Documents Used in Developing the Guidelines

The following publications have been used for guidance in the revision of the Guidelines.

American National Standards Institute (ANSI), International Organization for

Standardization (ISO), International Electro-technical Commission (IEC)

ANSI/ISO/IEC Information Technology Guidelines for the Management of Software

TR 9294.1990 Documentation

ISO/IEC TR Information technology—Guidelines for the management of IT

13335-4:2000 Security—Part 4: Selection of safeguards

ISO/IEC TR Information technology—Guidelines for the management of IT

13335-3:1998 Security—Part 3 Techniques for the management of IT security

ISO/IEC TR Information technology—Guidelines for the management of IT

13335-2:1997 Security—Part 2: Managing and planning IT security

ISO/IEC TR Information technology—Guidelines for the management of IT

13335-1:1996 Security—Part 1: Concepts and models for IT security

ISO 10007:1995 Quality Management Guidelines for Configuration Management

ISO 10005-1995 Quality Managment Guidelines for Quality Plans

ANSI/ISO/ASQC QM and QA standards Part 3: Guidelines for the application of

QS9000-3-1997 ANSI/ISO/ASQC Q9000-1994 to the Development, Supply,

Installation, and Maintenance of Computer Software

Electronic Industries Alliance Standards

MB2, MB5, MB9 Maintainability Bulletins

EIA 157 Quality Bulletin

EIA QB2-QB5 Quality Bulletins
EIA RB9 Failure Mode and Effect Analysis, Revision 71

EIA SEB1—SEB4 Safety Engineering Bulletins

RS-232-C Interface Between Data Terminal Equipment and Data Communications

Equipment Employing Serial Binary Data Interchange

RS-366-A Interface Between Data Terminal Equipment and Automatic Calling

Equipment for Data Communication

RS-404 Standard for Start-Stop Signal Quality Between Data Terminal

Equipment and Non-synchronous Data Communication Equipment

National Institute of Standards and Technology

NISTIR 4909 Software Quality Assurance: Documentation and Reviews

Institute of Electrical and Electronics Engineers

610.12-1990 IEEE Standard Glossary of Software Engineering Terminology

730-1998 IEEE Standard for Software Quality Assurance Plans

828-1998 IEEE Standard for Software Configuration Management Plans

829-1998 IEEE Standard for Software Test Documentation

830-1998 IEEE Recommended Practice for Software Requirements

Specifications

Military Standards

MIL-STD-498 Software Development and Documentation, 27 May 1998

B.3 Legislation References

Help America Vote Act, Pub. L. 107-252, 42 USC Sections 15301-15545

Americans With Disabilities Act of 1990, Pub. L. 101-336, 42 USC Sections 12101-12213

42 USC 1974

Occupational Safety and Health Act, Pub. L. 91-596, 29 USC Sections 651-678, 42 USC

Section 3142-1

Architectural Barriers Act of 1968, Pub. L. 90-480, 42 USC Sections 4151-4157

Voting Rights Act of 1965, Pub. L. 89-110, 42 USC Sections 1973; 1973a-p; 1973aa;

1973aa-1-6; 1973bb; 1973bb-1

B.4 Additional References

The following publications contain information that is useful in understanding and

complying with the Guidelines.

American National Standards Institute (ANSI), International Organization for

Standardization (ISO), International Electro-technical Commission (IEC)

ANSI/ISO/IEC TR Information Technology Guidelines for the Preparation of 10176.1998

Programming Language Standards

ANSI/ISO/IEC Information Technology Guidelines for the Documentation of

6592.2000 Computer Based Application Systems

ANSI/ISO/ASQC Quality management and quality assurance standards Part 3: Q9000-3-

1997 Guidelines for the application of ANSI/IAO/ASQC Q9001-1994 to the

Development, supply, installation and maintenance of computer

software

ANSI/ISO/ASQC Quality Management and Quality Assurance Standards—Guidelines

Q9000-1-1994 for Selection and Use

ANSI/ISO/ASQC Quality Management Guidelines for Configuration Management

Q10007-1995
ANSI X9.31-1998 Digital Signatures Using Reversible Public Key Cryptography for the

Financial Services Industry, 1998

ANSI X9.62-1998 Public Key Cryptography for Financial Services Industry: The Elliptic

Curve Digital Signature Algorithm, 1998

ISO/IEC ITU-T Recommendation X.509 (2000), Information technology - 9594-

8:2001 Open Systems Interconnection - The Directory: Public-key and

attribute certificate frameworks

National Institute of Standards and Technology

FIPS 102 Guideline for Computer Security Certification and Accreditation

FIPS 112 Password Usage (3)

FIPS 113 Computer Data Authentication

Institute of Electrical and Electronics Engineers

488-1987 IEEE Standard Digital Interface for Programmable Instrumentation

796-1983 IEEE Standard Microcomputer System Bus IEEE/ANSI Software

Engineering Standards

750.1-1995 IEEE Guide for Software Quality Assurance Planning

1008-1987 IEEE Standard for Software Unit Testing

1016-1998 IEEE Recommended Practice for Software Design Descriptions

1012-1998 IEEE Guide for Software Verification and Validation Plans

Military Standards

MIL-HDBK-454 Standard General Requirements for Electronic Equipment

MIL-HDBK-470 Maintainability Program for Systems & Equipment

MIL-HDBK-781A Handbook for Reliability Test Methods, Plans, and Environments for

Engineering, Development Qualification, and Production

MIL-STD-882 Systems Safety Program Requirements

MIL-STD-1472 Human Engineering Design Criteria for Military Systems,

Equipment and Facilities

MIL-STD-973 Configuration Management, 30 September 2000

Other References

Designing for the Color-Challenged: A Challenge, by Thomas G. Wolfmaier (March 1999);

http://www.sandia.gov/itg/newsletter/mar99/accessibility_color_challenged.html;

Effective Color Contrast: Designing for People with Partial Sight and Color Deficiencies, by

Aries Arditi, Ph.D; http://www.lighthouse.org/color_contrast.htm

Electronic Markup Language (EML), Version 4.0, (Committee Draft) Organization for the

Advancement of Structured Information Standards (OASIS), January 24, 2005

NIST Special Publication 500-256, Improving the Usability and Accessibility of Voting

Systems and Products, http://vote.nist.gov

RSA Laboratories Technical Note, Public Key Cryptographic Standard (PKCS) #7:

Cryptographic Message Syntax Standard, November 1, 1993

RSA Laboratories Technical Note, Extensions and Revisions to PKCS #7, May 13, 1997

The Americans with Disabilities Act Accessibility Guidelines (ADAAG 2202), Access

Board; http://www.access-board.gov/adaag/html/adaag.htm

Appendix C: Independent Verification Systems
Table of Contents

C Independent Verification Systems .............................................................. C-3

C.1 Independent Verification Systems .................................................. C-3

C.1.1 Improved Accuracy in Independent Verification Audits .............. C-3

C.1.2 Example Independent Verification Systems ................................. C-4

C.1.2.1 The Split Process Architecture for IV Systems ........................ C-5

C.1.2.2 End to End Cryptographic IV Systems..................................... C-5

C.1.2.3 Witness IV Systems.................................................................. C-6

C.1.2.4 Direct IV Systems..................................................................... C-7

C.1.3 Handling Multiple Records Produced by IV Systems................... C-8

C.2 Core Characteristics for Independent Verification Systems ....... C-9

C.3 Split Process Independent Verification Systems .......................... C-10

C.3.1 Capture and Verification Stations ................................................. C-11

C.3.2 Data Formats for Token Objects ................................................... C-11

C.3.3 Storage and Communications of Records .................................... C-12

C.4 Witness IV Systems ......................................................................... C-12

C.5 End to End Cryptographic IV Systems ......................................... C-13

Appendix C: Independent Verification Systems

Appendix C is an informative section that describes Independent Verification systems

followed by characteristics of the types of Independent Verification systems which will be

used as the basis for future requirements. This information is preliminary and will be

evolving with further research.

C.1 Independent Verification Systems

A primary objective for using electronic voting systems is the production of voting records

that are highly precise, highly reliable, and easily counted - in essence, an accurate

representation of ballot selections whose handling requirements are reasonable. To meet this

objective, there are many factors to consider in an electronic voting system design, including:

• the environment provided for voting, including the physical and environmental

factors

• the ease with which voters can use the voting system, i.e., its usability

• the robustness and reliability of the voting equipment

• the capability of the records to be used in audits

Independent Verification (IV) systems have as their primary objective the production of

independent records of voter ballot selections that are capable of being used in audits in

which their correctness can be audited to a very high level of precision. The primary voting

security and integrity issues addressed by IV systems are:

• whether electronic voting systems are accurately recording ballot selections

• whether the ballot record contents can be audited precisely post-election

The threats addressed by IV systems are those that could cause a voting system to

inaccurately record the voter's selections or cause damage to the voting system records.

These threats could occur via any number of means including human error, accident or

fraudulent activity. The threats are addressed mainly by providing, in the voting system
design, the capability for ballot record audits to detect precisely whether specific records are

correct as recorded or damaged, missing, or fraudulent.

C.1.1 Improved Accuracy in Independent Verification Audits

Independent Verification is the top-level categorization for electronic voting systems that

produce multiple records of ballot selections that can be audited to a high level of precision.

For this to happen, the records must be produced and made verifiable by the voter, and then

subsequently handled according to the following protocol:

• At least two records of voter selections are produced and one of the records is then

stored such that it cannot be modified by the voting system, e.g., the voting system

creates a record of voter selections and then copies it to some unalterable media

• The voter must be able to verify that both records are correct, e.g., verify his or her

selections on the voting system’s display and also verify the second record of

selections stored on the unalterable storage media

• The verification processes for the two records must be independent of each other and

(a) at least one of the records must be verified directly by the voter, or (b) it is

acceptable for the voter to indirectly verify both records if they are stored on

independent systems

• The content of the two records can be checked later for consistency through the use of

identifiers that allow the records to be linked

An assumption is made that at least one set of records is usable in an efficient counting

process such as an automated tabulator, and the other set of records is usable in an efficient

process of verifying its agreement with the other set of records used in the counting process.

The sets of records would preferentially be different in form and thus have more resistance to

accidental or deliberate damage.

Given these conditions, the multiple records are said to be distinct and independently

verifiable; that is, both records are not under the control of the same processes. As a result of

this independence, one record can be used to audit or check the accuracy of the other record.

Because the storage of the records is separate, an attacker who can compromise one of the

records still will face a difficult task in compromising the other.

C.1.2 Example Independent Verification Systems

The following sections present overviews of several types of IV systems. Some of these

systems have not been marketed as yet but are included here to help clarify approaches to

independent verification systems. The Independent Verification systems discussed are:

• voting systems with a split process architecture3

• end-to-end voting systems that include cryptographic audit schemes

• witness systems that take a picture of or otherwise capture an indirect verification of

ballot selections

• direct independent verification, including voting systems that produce an optically

scanned ballot or that produce a voter verifiable paper audit trail

3 The split process architecture is otherwise known as the frog protocol, which was first described in the Caltech

– MIT report: Voting: What Is, What Could Be, as part of a modular voting architecture. The frog term, i.e., the

token, was chosen specifically to convey no information about the physical form of the object used to carry vote

information between two separate modules of the voting station. The report is available for download at

http://www.vote.caltech.edu/.
C.1.2.1 The Split Process Architecture for IV Systems

A voting machine with a split process architecture consists of vote capture and verification

stations that are separate, i.e., two physical devices. A voter inserts an object called a token

into the capture station to make ballot selections and then takes the token object to the

verification station to review and store his or her votes. The token object could be paper or

unalterable media. Two records of the vote are created: one on the token object and one by

the verification station. Either could be used in the final count.

For any split process voting system, the interaction between the voter and the split process

operates as follows:

• A voter is given a token object that has been initialized to be blank

• Supporting information is written to the token object including the ballot and

identification information about the election and precinct

• The voter inserts the token object into a capture station such as a DRE, which reads

the ballot information from the token and then displays the ballot to the voter by some

means such as a touch screen. The voter makes his or her ballot selections, which

causes a record of the vote to be recorded on the token object

• The voter takes the token object to a separate verification station, which reads the

recorded votes from the token object, makes an electronic copy, and displays it to the

voter

• The voter verifies that the information is correct and then deposits the token object in

a secure container so it can be archived and used later for recounts or audits against

the electronic records

Two sets of records are produced: the electronic records and the token records. Typically,

the electronic records recorded by the verification station would be counted in the election.

The records should be different in form and be resistant to accidental or deliberate damage to

be useful for audits and recounts.

In theory, the physical separation of vote capture from vote verification may make analysis

of the capture and verification devices easier or less costly. The rationale is that the user

interface software on the capture station is expected to be complex and difficult to verify for

correctness. On the other hand, the verification station’s software is expected to be less

complicated because it need only copy the contents of the token, display it to the voter, and

store the ballot selections. In general, segregating functions by placing them on physically

different systems is a standard computer security practice for making those functions easier

to test for correctness and easier to manage securely.

C.1.2.2 End to End Cryptographic IV Systems

End to end systems use cryptographic techniques to store an encrypted copy of the voter’s

ballot selections. In this way, ballot selections can be audited and demonstrated to have been

included in the election count.

End to end systems in existence today generally operate as follows:

• A voter uses a voting machine such as a DRE to make ballot selections

• The DRE issues a paper receipt to the voter that contains information that permits the

voter to verify that the choices were recorded correctly. The information does not

permit the voter to reveal his or her selections

• The voter may have the option to check that his or her ballot selections were included

in the election count, e.g., by checking a web site of values that (should) match the
information on the voter’s paper receipt

End to end systems are sometimes referred to as receipt-based systems. They may provide

an assurance not only that the correct set of ballot choices was recorded, but that those

selections were included in the election count. Some analyses of auditing and cryptographic

systems assert that very small numbers of self-audits are required to verify the correctness of

an election.

C.1.2.3 Witness IV Systems

A witness system creates the second record of ballot choices by using a separate module to

record or witness the voter’s verification of the first record. The primary feature of a witness

system is that the creation of the record does not require action by the voter. This may result

in quicker voting times or voting systems that are simpler to use than other approaches that

involve multiple, direct verifications by the voter.

An example of a witness system is a DRE with a camera mounted above its screen. The

camera takes pictures and saves them independently of the DRE. It would operate as

follows:

• A voter makes ballot selections at the DRE and then presses a button to record his or

her vote

• The DRE records the ballot selections and uses them in the election count

• At the time the button is pressed, the camera takes a picture of the DRE summary

screen and saves the image. The voter would not be included in the picture.

• This collection of images constitutes a second ballot record that can be used in audits

and recounts

As can be seen by this example, the voter’s interactions are reduced to making ballot

selections at the DRE and pressing a button to make the selections final. If the DRE were to

be compromised such that it secretly recorded the ballot choices incorrectly, the stored

photographic images would reflect what the voter had seen and verified at the DRE summary

screen.

Because the voter may not be able to verify that the creation of the second record was

performed accurately, it is important that the creation process be highly reliable and very

resistant to accidental or deliberate damage. Also, the suitability of the records for manual or

automated auditing is a factor when considering this approach.

C.1.2.4 Direct IV Systems

Direct Independent Verification systems produce a record that the voter may verify directly

with the voter’s senses and which is then preserved for auditing or counting. Some optical

scan voting systems fit this category, as well as DREs with VVPAT capability.

The optical scan voting systems in this category are those in which two records are created: a

paper and an electronic record. This system uses Optical Scan Recognition (OCR) to create

an electronic record from the paper record after the paper record has been directly verified by

the voter. The general operation of this system is:

• A voter uses a marking device such as a DRE to mark a ballot and then presses a

button to print the marked ballot

• The voter directly reviews the printed paper record to ensure its correctness, and if

correct, places the paper record into a scanner. A procedure would be needed to
handle voided ballots.

• The scanner converts the paper record into an electronic format. To reduce errors that

may result from scanning the paper record, the paper records might contain a barcode

representation of the human readable portion of the ballot.

• The paper record is deposited in a secure receptacle

No verification of the scanned paper record is performed in the above approach. One may

assume that the scanning process is highly accurate and can be trusted to create the electronic

record correctly; however it would be preferential for the voter to somehow verify that the

record was, in fact, created correctly.

A DRE with VVPAT capability is similar to that of the optical scan above but consists

typically of a DRE that both creates and records an electronic record, and a printer that

creates a paper record of the voter's selections. Like the optical scan system, it creates two

distinct representations of the voter’s ballot selections: an electronic record and a paper

record.

Typically, a voter would use the voting system as follows:

• A voter makes ballot selections and indicates that his or her selections are complete

• A paper record is printed of the voter’s ballot selections as displayed on the summary

screen. An alternative approach is to print the voter’s ballot selections as they are

made.

• The voter inspects and directly verifies that the paper record matches the displayed

electronic record

• The paper record is deposited in a secure receptacle

Both approaches described here produce paper records that are verified directly by the voter

through visual inspection. Voters with sight impairments would require an accessible device

for verification that can produce an audible representation of the paper record.

C.1.3 Handling Multiple Records Produced by IV Systems

There are several fundamental questions that need to be addressed when designing the

structure and selecting the physical characteristics of IV system records, including:

• how to tell if the records are authentic and not forged

• how to tell if the integrity of the records has remained intact from the time they were

recorded

• the suitability of the records for various types of auditing

• how best to address problems if there are errors in the records

Whenever an electronic voting system produces multiple records of votes, there is some

possibility that one or more of the records may not match. Records can be lost, or

deliberately or accidentally damaged, or stolen, or fabricated. Keeping the two records in

correspondence with each other can be made more or less difficult depending on the

technologies used for the records and the procedures used to handle the records.

It is important to structure the records so that errors and other anomalies can be readily

detected during audits. There are a number of techniques that can be used:

• associating unique identifiers with corresponding records, e.g., an individual paper

record sharing a unique identifier with its corresponding electronic record

• including an identification of the specific voting system that produced the records,

such as a serial number identifier, or by having the voting system digitally sign the


the votes and the identifier of the token object.

Discussion: The voter could reject and thereby void his or her ballot. This is to prevent

the verification station from recording ballot selections that are different

from what was entered at the capture station.

• The capture and verification stations could be purchased from different manufacturers

and could use different operating systems.

Discussion: The greater the independence of the capture and verification stations, the less

likely they could be compromised by the same threats, e.g., software viruses,

or by a single conspiracy.

C.3.2 Data Formats for Token Objects

• The format for data written to the token object is specified and publicly available for

use without licensing fees.

• The verification station verifies the correctness of the data on the token object and

provides an indication of any errors to the voter.

Discussion: The verification station needs to verify that the data written to the token

object was formatted properly according to the format specification and

reject improperly formatted data. It also checks that the votes are consistent

with the voting instructions, e.g., “vote for one, vote for two.”

• The record on the token object is digitally signed using a private key known only to

the vote capture station and whose public key is distributed in an authenticated way to

auditing systems and the verification station.

• The record created by the verification station is digitally signed using a private key

known only to the verification station and whose public key is distributed in an

authenticated way to auditing systems.

• The capture station associates a unique identifier with each record of voter selections

to identify that record and link it to the corresponding record created by the

verification station.

Discussion: The identifier serves the purpose of uniquely identifying the record to identify

duplicates and/or for cross-checking two record types.

• The records from the verification station are randomly shuffled in memory when

exported, so that the order of the records cannot be used to relate the votes to a

specific voter.

• Rejected token objects are stored separately from accepted token objects for later

auditing.

C.3.3 Storage and Communications of Records

• The verification station exports its records of voter choices accompanied by a digital

signature on the entire set of electronic records and their associated digital signatures.

Discussion: This is necessary to determine if records are missing or substituted.

• The token objects are stored and transported in a physically secure way, using chainofcustody mechanisms to ensure their integrity.

• The records from each station are randomly shuffled, so that an attacker learning the

contents of those records at any point in the voting process can learn nothing about

the order of votes cast
.

C.4 Witness IV Systems

Witness IV systems are composed of two physically separate devices: the vote capture

station that captures and stores records of voter selections, and the witness device that

captures voter verifications of the records at the vote capture station. Because there are two

devices, a number of the definitions for split verification systems apply equally well to

witness systems. Because the vote capture station is in essence a DRE, a number of the

definitions for DREs with VVPAT also apply to vote capture stations. A witness system fits

somewhat loosely in the independent verification category because the voter performs only

an indirect verification of ballot choices at the DRE. It is important that the witness device

be tested extensively for accuracy and reliability and that malfunctions of the device be made

immediately obvious to the voter and poll workers.

• A witness device records only a voter's verification at the vote capture station and

stores the record so that it can be used for audit.

• A witness device acts as a passive device that cannot perform any operation with

respect to the voting station other than to capture voter ballot selections as the voter

verifies them.

Discussion: The witness device is synchronized with the voter verification of the ballot

selections.

• A witness device, if attached to the vote capture station, is attached such that it can

capture only the voter’s verification of ballot selections.

Discussion: For example, the witness device could be connected only to the display unit

and not the vote capture station’s memory or disk drive.

• The vote capture station is able to detect whether the witness device is connected or

in operation.

Discussion: If the witness device is not in operation, the vote capture station should cease

recording voter selections.

• The vote capture station and the witness device are connected using a publicly

available, published communications interface, such as RS232 or USB.

• Because voters must trust that the witness device records their verifications

accurately, assessments of its software and functionality are straightforward, readily

performed, and include extensive evaluation and penetration testing above and

beyond what may be performed on voting systems that do not contain witness

devices.

Discussion: Witness device manufacturers will be required to fully document their

systems and conduct stringent testing.

• A voter should be able to inspect the record of his or her verification upon request.

Discussion: It is desirable that a voter have the ability to verify that the witness device is

operating as specified.

• The witness device clearly indicates any malfunction in a way that is obvious to the

voter and poll workers.

• The records captured by the witness device are able to be used in highly accurate

verifications of the voting records of the voting station.

• The records contain unique identifiers that correspond to records stored by the vote

capture station.

• The records are digitally signed by the witness device so that the integrity and
authenticity of its records can be verified.

• A witness device is able to export its records in an open, nonproprietary format such

that the records can be used in automated audits.

• The records are stored in the witness device and exported such that voter privacy is

protected, e.g., by randomizing the order of the records.

C.5 End to End Cryptographic IV Systems

This section contains very preliminary definitions for end to end cryptographic-based IV

systems. They are consistent with the characteristics of IV systems and build on the core

characteristics of IV systems.

End to end voting systems use cryptographic mechanisms as a substitute for some physical,

computer-security, or procedural mechanisms used to secure other types of voting systems.

These cryptographic mechanisms can be used by a voter to verify that ballot selections were

recorded correctly and counted in the election. Some auditing procedures normally

performed by voting officials at the tabulation center can be done by voters or their

designated representatives, using receipts issued by the voting system that work in

conjunction with the cryptographic mechanisms. Typically, multiple individuals, known as

designated trustees, hold key information that is combined to form encryption and decryption

keys; thus, no one person is able to encrypt or decrypt. Several types of cryptographic voting

approaches have been proposed or implemented, with varying properties. There are many

cryptographic techniques (such as secure multiparty computation and homomorphic) that

could be applied in novel ways in future voting systems.

• End to end systems record voters ballot selections at electronic voting machines and

encrypt the records of votes for later counting by designated trustees.

Discussion: The voting station would operate much as a DRE.

• End to end systems produce a receipt that can be used by the voter in a process

defined by voting officials that would enable the voter to verify that the voter's ballot

selections were recorded correctly and counted in the election.

Discussion: The receipt could have a variety of different forms but likely would be

printed on paper for the voter’s ease of handling.

• No one designated trustee is able to decrypt the records; decryption of the records is

performed by a process that involves multiple designated trustees.

• The receipt preserves voter privacy by not containing any information that can be

used to show the voter’s selections.

• The process used to verify that ballot selections were recorded correctly and counted

preserves voter privacy by not revealing any information that can be used to identify

the voter's selections.

• End to end systems store backup records of voter ballot selections that can be used in

contingencies such as damage or loss of its counted records.

Discussion: This is necessary because the handling of the encrypted records requires the

same chain of custody procedures as records produced by other voting

systems and are thus subject to loss or damage. This could be paper for

example.

• The backup records contain unique identifiers that correspond to unique identifiers in

its counted records, and the backup records are digitally signed so that they can be

verified for their authenticity and integrity in audits.
• Cryptographic software in end to end systems is documented thoroughly and subject

to extensive verification testing for correctness. The documentation includes

extensive discussion of how cryptographic keys are to be generated, distributed,

managed, used, certified, and destroyed.

• Vote capture stations used in end to end systems must meet all the security, usability,

and accessibility requirements.

• Reliability, usability, and accessibility requirements for printers in other voting

systems apply as well to receipt printers used in end to end systems.

• Trustee systems are subject to the same evaluations and assessments as other voting

systems.

• Systems for verifying that voter ballot selections were recorded properly and counted

are implemented in a robust secure manner.

Discussion: Many of the cryptographic approaches have a "public append-only bulletin

board" as a component; this is an important part of the system and needs to

be implemented in a robust secure manner.

Appendix D: Technical Guidance for Color,

Contrast, and Text Size

Table of Contents

D Technical Guidance for Color, Contrast, and Text Size .............................. D-3

Appendix D: Technical Guidance for Color,

Contrast, and Text Size

Although estimates vary, it is generally agreed that there are approximately 10 million

visually impaired people in the United States. This estimate includes the 600,000 people

who are legally blind. 8.1 million people were estimated to have a functional limitation in

seeing in 1994, including both those with "non-severe limitation" (e.g., difficulty seeing

words and letters) and those with "severe limitation" (e.g., unable to see words and letters).

Approximately 1.8 million people in the U.S. have severe visual impairments but are not

legally blind.4 Low vision includes dimness of vision, haziness, film over the eye, foggy

vision, extreme near-sightedness or far-sightedness, distortion of vision, color distortion or

blindness, visual field defects, spots before the eyes, tunnel vision, lack of peripheral vision,

abnormal sensitivity to light or glare and night blindness. For the purposes of this discussion

low vision is defined as having a visual acuity greater than 20/70.

People with low vision or color blindness will benefit from high contrast and selection of

color combinations that are appropriate for their needs. Between 7% and 10% of all men

have color vision deficiencies. Certain color combinations in particular cause problems.

Therefore, use of color combinations with good contrast is required.

However, some users are very sensitive to very bright displays and cannot use them for long.

An overly bright background causes a visual “white-out” which makes these users unable to

distinguish individual letters. Contrast ratio between 6:1 and 15:1 is optimal.5.

When color selection is provided the 16-color pallet as used in Microsoft Windows for 16
color displays and recognized by HTML 4.0 provides a sufficient range of both saturated and

non-saturated color options. Use of non-saturated color options is an advantage for some

people. The use of the 16-color palette or a larger color palette is suggested when voter

adjustment of color is provided.

4 See the following sites for further detail:

http://blue.census.gov/hhes/www/disable

http://www.afb.org/info_document_view.asp?documentid=1367

http://www.brailleinstitute.org

5Cushman, W.H. and Rosenberg, D. J., Human Factors in Product Design. New York: Elsevier,

1991.

# Color Name

(Color names are per HTML 4.0)

RGB Value

(Hexadecimal)

1 Black #000000

2 Blue #0000FF

3 Lime #00FF00

4 Red #FF0000

5 Aqua #00FFFF

6 Fuchsia #FF00FF

7 Yellow #FFFF00

8 White #FFFFFF

9 Navy #000080

10 Green #008000

11 Maroon #800000

12 Teal #008080

13 Purple #800080

14 Olive #808000

15 Grey #808080

16 Silver #C0C0C0

Large fonts provide significant help to users with low or impaired vision. A voting system is

required to provide letters of at least 6.3 mm, for capital letters. A capital "X" is often used

to make this measurement. It is not the size per se, but visual angle that is of primary

importance. Visual angle is a measure, in degrees, of the size of the retinal image subtended

by a viewed object. It represents the apparent size of an object based on the relationship

between an object's distance from the viewer and its size (perpendicular to the viewer's line

of sight). An object of constant size will subtend a smaller visual angle as it is moved farther

from the viewer. Visual angle is typically defined in terms of minutes of visual arc. For

people with normal vision, it is recommended that the height of characters in displayed text

or labels be at least 16 minutes of arc (4.6 milliradians), and the preferred character height

should be 22 minutes of arc (6.4 milliradians), which is preferred for reading tasks.

The size required for low vision accessibility is somewhat arbitrary, in that the larger the size
the greater the number of low vision voters who can be accommodated. The

Usability/Accessibility Task Group for IEEE P1583 recommends 30 minutes of arc,

depending upon the presumed viewing distance. A table in the usability section of IEEE

P1583 provides the following recommendations based on three possible viewing distances:

• for a distance of 51cm (20in): 4.43mm (.17in)

• for a distance of 64cm (25in): 5.54mm (.22in)

• for a distance of 76cm (30in): 6.65mm (.26in)

People with tunnel vision can only see a small part of the ballot at one time. For these users

it is helpful to have letters at the lower end of the font size range in order to allow them to see

more letters at the same time. Thus, there is a need to provide font sizes at both ends of the

recommended range.

Use of sans serif fonts is also recommended for computer displays. Sans serif fonts have

proven to be easier to read on computer screens than stylized fonts.

D-6

EAC Commissioners

Chairman Paul DeGregorio

Vice Chairman Ray Martinez III

Commissioner Donetta Davidson

Commissioner Gracia Hillman

EAC Staff

Tom Wilkey, Executive Director

Juliet Thompson, General Counsel

U.S. Election Assistance Commission

1225 New York Avenue, NW

Suite 1100

Washington, DC 20005

866–747–1471 (toll free)

HAVAinfo@eac.gov

www.eac.gov

U.S. Election Assistance Commission