United States Election Assistance Commission

633 3rd St. NW, Suite 200

Washington, DC 20001

www.eac.gov

Voting System Testing and Certification

VVSG Lifecycle Policy

 
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Contents

1. Introduction ..............................................................................................................................3

2. VVSG Version Convention.........................................................................................................3

3. Migration to Revised VVSG Standards......................................................................................4

4. VVSG Review and Update Process............................................................................................5

Appendix A - Glossary........................................................................................................................8

 

 
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1. Introduction

1.1. Introduction: In late 2002, Congress passed the Help America Vote Act of 2002 (HAVA), which 

created the U.S. Election Assistance Commission (EAC) and vested it with the responsibility of 

setting voting system standards and for providing for the testing and certification of voting 

systems. This mandate represented the first time the Federal government provided for the 

voluntary testing, certification, and decertification of voting systems nationwide. In response to 

this HAVA requirement, the EAC has developed the Voting System Testing and Certification 

Program (Program).

1.2. Authority: Section 231(a)(1) of HAVA specifically requires the EAC to “... provide for the 

certification, decertification and re-certification of voting system hardware and software by 

accredited laboratories.” The EAC has the sole authority to grant certification or withdraw 

certification at the federal level, including the authority to grant, maintain, extend, suspend, and 

withdraw the right to retain or use any certificates, marks, or other indicators of certification.

1.3. Scope: This document provides the Voluntary Voting System Guidelines (VVSG) lifecycle policy. 

Participation in the program is voluntary, but if voting system manufacturers decide to 

participate then they and their products will be subject to the VVSG lifecycle policy. This 

document supersedes any previous policy from the EAC concerning VVSG lifecycles.

1.4. Purpose: The intent of this policy is to facilitate migration to revised VVSG standards and

establish consistent periodic review, update, and versioning of future standards.

1.5. Feedback: The EAC will engage registered voting system manufacturers and Voting System Test 

Laboratories (VSTL)s on newly adopted VVSG standards to inform them of the differences 

between VVSG versions, obtain information about practical timelines to prepare for the new 

standard, and to address questions or concerns they may have.

2. VVSG Version Convention 

2.1. Types of Version Changes: This section defines major and minor standard changes to the VVSG. 

After consultation with stakeholders and a proposed VVSG update has been drafted, the EAC 

will determine whether a version change is major or minor.

2.2. Major Version Changes: Major changes to the VVSG will cause the primary number to 

increment by one and the secondary number to reset to zero. For instance, the new version 

number for VVSG 2.0 with major changes would be VVSG 3.0. In general, major version changes

necessitate new hardware, architectural upgrades, or add significant new features that break 

compatibility with the prior major VVSG version.

2.3. Minor Version Changes: Minor changes to the VVSG will cause the secondary number to 

increment by one. For instance, the new version number for VVSG 2.0 with minor changes 

would be VVSG 2.1. In general, minor version changes will not necessitate new hardware or 

other upgrades that maintain compatibility with the same major VVSG version.
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2.4. Voting System Test Laboratory (VSTL) Accreditation: The need for lab accreditation will be

based on consultation between the EAC and National Institute of Standards and Technology 

(NIST) National Voluntary Laboratory Accreditation Program (NVLAP), and metrics such as a 

change in core or non-core competencies, required skills, or any other criteria deemed 

necessary by the EAC that are the result of the VVSG update.

Major VVSG version changes may require VSTL accreditation. Minor VVSG version changes will 

not require VSTL accreditation.

3. Migration to Revised VVSG Standards

3.1. Overview: When a new VVSG iteration is adopted by the EAC’s Commissioners, migration to the 

new standard is a necessary process for the Testing and Certification Program. Manufacturers 

submitting new systems must submit them to the most recently adopted VVSG version that is 

ready to be used for testing. However, systems certified to previous VVSG versions will still be 

able to receive critical updates.

3.2. VVSG Version Migration: Once a new major revision to the VVSG is ready to be used for testing,

with at least one VSTL accredited to test voting systems to the standard, prior major VVSG 

versions will no longer be used by the EAC to certify voting systems. Twelve months after the 

date of the first VSTL accreditation to a new major VVSG version, the EAC will no longer accept 

submissions to test new voting systems to previous major versions, with the exception of 

maintenance modifications as defined in section 3.3 of this policy. Once a VVSG standard is no 

longer used for testing and certification of new and modified systems by the EAC, that standard 

will be assigned legacy status, and manufacturers will be required to submit voting systems to 

the latest VVSG standard. 

This process does not affect the status of any EAC certified voting system. Those systems shall 

maintain their status and jurisdictions may continue to acquire these as EAC certified systems.

Systems may only be decertified upon a vote of the Commissioners and following the process 

detailed in the EAC’s Testing and Certification Program Manual.

3.3. Maintenance Exceptions: To address the subject of fielded voting system maintenance, changes 

to systems certified to a legacy VVSG standard will be accepted within a narrow definition. 

These changes may be requested through application for a system modification or as an 

engineering change order for qualifying requests.

Changes to a system certified to a legacy VVSG standard must be in one or more of the following 

categories:

3.3.1. Security Update: Software patches or hardware mitigations to address known security 

vulnerabilities and exploits. Software patches may include code authored by voting 

system manufacturers.

3.3.2. Bug Fix: EAC-approved fixes to correct anomalies previously reported to the EAC. 

Examples include critical functional discrepancies or issues that are part of an EAC 

certified system. Enhancements are not considered a fix.
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3.3.3. COTS Replacement: Replacement of commercial-off-the-shelf equipment that has 

reached end-of-life. Any significant changes to specifications or functionality in the 

replacement are discouraged and must be evaluated and approved by the Testing and 

Certification Program Director and a VSTL.

3.3.4. Jurisdictional Rule Change: Changes that are legally required in a jurisdiction already 

fielding the system due to a change in statute, rule, directive, or other publication that 

places requirements on a jurisdiction. This type of change must be confirmed by a chief 

election official, electoral board, or certification body where this system is state certified 

or fielded.

3.3.5. Updating and Adding New Components to be Evaluated Against the Current VVSG 

Standard: Changes to one or more components outside of 3.3.1 through 3.3.4 may be 

permitted provided the proposed changes meet the most current VVSG version. This 

may include changes to components necessary to integrate new software, firmware, and 

hardware into the system. In this instance, the overall system certification granted would 

be to the VVSG version of the system that is being modified.

Voting systems that feature changes that are outside these categories will only be accepted for 

testing and certification to the most current VVSG version. When a manufacturer applies for a 

modification to a voting system that is certified to a legacy VVSG standard, they must clearly 

state under which category they are applying and must supply supporting documentation for 

this claim.

EAC staff will make the determination on acceptance of modifications to maintain systems 

certified to legacy VVSG standards and will communicate the decision to the manufacturer and 

appropriate voting system test laboratory. This decision will be posted on the EAC website. 

Decisions will be made within five business days of receiving all necessary supporting 

documentation. Manufacturers are encouraged to contact the EAC in advance of applying for 

voting system testing for a modification to get a non-binding opinion on whether a modification 

would be considered in any of the categories enumerated in section 3.3.1 of this policy. Nonbinding decisions will be provided to the manufacturer in writing within five business days.

4. VVSG Review and Update Process

4.1. Overview: More frequent iteration of standards is the result of a continuous improvement 

process that closely matches modern agile software and hardware development cycles. All

updates to the VVSG will adhere to the established practice of public review and comment, 

agency review and comment, and consideration by the Commissioners, as described in HAVA.

4.2. Timeline: There will be a 12-month cycle for each review for revisions to the VVSG. It is 

understood the time taken to complete the review and update process will vary due to several 

factors, including but not limited to, the number of changes proposed, number of comments 

received from stakeholders, complexity of changes, and time taken to develop requirements. 
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4.3. Scope: Updates to the standards during this cycle may incorporate items such as Requests for 

Interpretation, Notices of Clarification, errata, and other administrative changes. Additionally, 

requirements may be added or adjusted to support more voting system functions or other 

updates to accommodate new technologies or standards. Stakeholders are encouraged to 

submit proposed changes as part of the VVSG review process.

4.4. VVSG Review: The EAC Testing and Certification Program will engage with the Technical 

Guidelines Development Committee (TGDC), the Standards Board, and the Board of Advisors 

annually to identify and propose changes to the VVSG including adding requirements, modifying 

existing guidelines and requirements, and rolling in Requests for Interpretation, Notices of 

Clarification, or other clarifying information from the program. An annual 90-day period of 

public comment will allow all stakeholders to submit comments to the EAC. Public comments 

will be posted on the EAC website.

The EAC Testing and Certification Program Director will provide an annual report to the 

Executive Director at the end of the fiscal year detailing recommendations for updates to the 

VVSG that have been collected throughout the prior fiscal year from various stakeholders. This 

report will be shared with the Technical Guidelines Development Committee (TGDC), the 

Standards Board, and the Board of Advisors. Feedback from this process will inform the decision 

to make updates to the VVSG. This annual cycle will continue, without regard to whether the 

Executive Director makes the decision to pursue a new version of the VVSG, initiating the steps 

detailed in section 4.5.

4.5. VVSG Update Process: When the Executive Director determines that a new version of the VVSG

should be published based on feedback from section 4.4, the process detailed in section 222 of 

HAVA will be followed. The EAC expects that key stakeholders will be involved throughout this 

update process.

4.5.1. The EAC will work with NIST and the TGDC to address relevant proposed changes

gathered from section 4.4 and draft revisions to the sections of the VVSG affected by the 

proposed changes.

4.5.2. The Executive Director will submit the draft revised VVSG to the EAC’s Board of Advisors 

and the Executive Board of the Standards Board for review and comment. The draft 

revised VVSG will also be posted for public comment.

4.5.3. The EAC will collaborate with NIST to review and address all comments. Comments will 

be posted to the EAC website once addressed. Concurrently, the Testing and Certification 

Program Director will draft updates to relevant sections of the program manuals and 

other program documentation, if necessary. Program manuals for the new standards will 

be posted for public comment.

4.5.4. The Testing and Certification Program Director will submit the updated VVSG and 

program documentation to the Executive Director. The Executive Director will forward all 

revised VVSG documentation to the Commissioners and will publish redline versions on 

the EAC website.
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4.5.5. The Commissioners may meet with stakeholders and shall hold a public hearing prior to 

voting on the revised VVSG. This vote may not take place less than 90 days from the date 

the Executive Director submits the draft revised VVSG to the Board of Advisors and 

Standards Board Executive Board as described in section 4.5.2.

The Commissioners will vote on whether to adopt the updated VVSG. For the purposes

of this policy, “adopted” means that the Commission has accepted this copy of the VVSG 

as the final version and further edits, additions, or deletions outside of minor errata 

published to the EAC website cannot be made without incrementing the version.

4.6. Commissioner Quorum: In the event the EAC is without a quorum of Commissioners and 

adoption of a new VVSG standard is not possible, section 4.4 will be executed on an annual 

basis, and sections 4.5.1 through 4.5.3 will be executed, as necessary. Recommendations 

provided to the EAC for standard updates or changes will continue to be collected, evaluated, 

and drafted in accordance with the process in HAVA. The EAC can hold public meetings without 

quorum, however, adoption of updated standards cannot be accomplished without quorum. 

Once a quorum of Commissioners is reestablished, the process will proceed through sections 

4.5.4, 4.5.5, and 4.5.6, as applicable, including all changes recommended previously up to 

section 4.5.3 in the process.
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Appendix A - Glossary

Accreditation

Formal recognition that a laboratory is competent to carry out specific tests or calibrations.

Commercial Off-the-Shelf (COTS)

Software, firmware, device, or component that is used in the United States by many different people or 

organizations for many different applications other than certified voting systems and that is 

incorporated into the voting system with no manufacturer- or application-specific modification.

Component

An identifiable and discrete part of the larger voting system essential to the operation of the voting 

system, and an immediate subset of the system to which it belongs.

Decertification

Revocation of national or state certification of a voting system or any of its components.

Election Assistance Commission (EAC)

The Election Assistance Commission, created by the Help America Vote Act (HAVA) to assist the states 

regarding HAVA compliance and to distribute HAVA funds to the states. The EAC is also charged with 

creating voting system guidelines and operating the Federal Government's first voting system 

certification program. The EAC is also responsible for maintaining the National Voter Registration form, 

conducting research, and administering a national clearinghouse on elections that includes shared 

practices, information for voters, and other resources to improve elections.

Engineering Change Order

A change to a certified voting system’s hardware, software, technical data package, or data, the nature 

of which does not materially alter the system’s reliability, functionality, capability, or operation as 

detailed in the EAC’s Testing and Certification Program Manual.

Fielded Voting System

An EAC certified voting system purchased or leased by a State or local government.

Help America Vote Act (HAVA)

Act passed by the U.S. Congress in 2002 to make sweeping reforms to the nation's voting process. HAVA 

addresses improvements to voting systems and voter access that were identified following the 2000 

election. 

Legacy

A status that denotes when a version of the VVSG standard has been superseded by an updated VVSG 

version.
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Manufacturer

The entity with ownership and control over a voting system submitted for certification.

National Institute of Standards and Technology (NIST)

Federal organization tasked with assisting in the development of voting system standards. NIST develops 

and maintains standards for a wide array of technologies. NIST scientists assist the EAC in developing 

testable standards for voting systems.

Program Director

The individual responsible for administering and managing the EAC’s Testing and Certification Program.

Standard

A document that provides requirements, specifications, guidelines, or characteristics that can be used 

consistently to ensure that materials, products, processes, and services are fit for their purpose.

Voting System

The total combination of mechanical, electromechanical, and electronic equipment (including the 

software, firmware, and documentation required to program, control, and support the equipment) used 

to define ballots; cast and count votes; report or display election results; connect the voting system to 

the voter registration system; and maintain and produce any audit trail information. 

Voting System Test Laboratory (VSTL)

Independent testing laboratories accredited by the EAC to test voting systems to EAC-approved voting 

system standards. Each VSTL must be accredited by NVLAP) and recommended by the NIST before it 

may receive an EAC accreditation. NVLAP provides third party accreditation to testing and calibration 

laboratories. NVLAP is in full conformance with the standards of the International Organization for 

Standardization (ISO) and the International Electrotechnical Commission (IEC), including ISO/IEC Guide 

17025 and 17011. 

Voluntary Voting System Guidelines (VVSG)

A set of specifications and requirements against which voting systems can be tested to determine if the 

systems meet required standards. Under HAVA, the EAC is responsible for developing, maintaining, and 

approving these standards.