EAC Decision on the Interpretation of the Extensions Clause 2013-01 

(Testing and Certifying Innovative Voting Systems) 

Date: 

March 08, 2013 

Question: 

Does the Extensions Clause, within the Conformance Clause, of the 2005 Voluntary Voting System 

Guidelines (VVSG), allow for the testing and certification of voting systems outside the traditional 

DRE, optical scan, and ballot marking device parameters? 

Section of Guidelines: 

2005 VVSG Volume 1 Section 1.6.3.3 

Discussion: 

Section 1.6.3.3 of the 2005 VVSG states: 

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.

(Emphasis added) 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.

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

is further categorized by the location where the system tabulates ballots. However, the Guidelines 

recognize that as industry develops new solutions and technology continues to evolve, the 

distinctions between traditional voting system categories 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 that new types of voting systems 

provide the necessary integrity, security and accessibility and can be properly evaluated in the 

certification process. (VVSG Volume 1, Section 1.5.2 Types of Voting Systems)

Consequently, manufacturers 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 specifically request certification of the voting system with the extensions and shall 

submit a proposed (or draft) test plan that will be refined and finalized by the VSTL and approved 
by the EAC. All other applicable VVSG requirements must be met by the system. Manufacturers 

shall also submit the results of all internal or external testing and, to the extent possible, COTS

component tests conducted by COTS manufacturers of the new system when applying for national 

certification. The Guidelines permit manufacturers 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 

In addition, the manufacturer shall submit a detailed implementation statement as required by 

Section 1.6.4 of the VVSG. The implementation statement documents the requirements that have 

been implemented by the voting system, the optional features and capabilities supported by the 

voting system, and any extensions (i.e., additional functionality beyond what is defined in the 

VVSG) that it implements. (Emphasis added) 

An implementation statement may take the form of a checklist to be completed for each voting 

system submitted for conformity assessment. It is used by VSTLs to identify the conformity 

assessment activities that are applicable. 

a. An implementation statement shall include: 

i. Full product identification of the voting system, including version number or 

timestamp; 

ii. Separate identification of each device that is part of the voting system. Where 

more than one type of COTS device may be used interchangeably, the manufacturer 

shall note this and document all internal interoperability testing conducted on these 

various devices; 

iii. Version of VVSG to which conformity assessment is desired; 

iv. Voting variations supported (see Volume I Section 2.1.7.2); 

v. Device capacities and limits 

vi. List of languages supported; 

vii. List of accessibility capabilities; and 

viii. Signed attestation that the foregoing accurately characterizes the system 

submitted for testing. 

The VSTL shall conduct functional testing of the system and system extensions pursuant to the 

requirements of Volume 2, Sections 3.2.2, 3.2.3 and 3.2.4 of the VVSG.

Finally, the VSTL shall conduct the detailed Functional Configuration Audit (FCA) required by 

Volume 1 Section 9.7.2 and Volume 2 Section 6.7 of the VVSG. The Functional Configuration Audit is 
conducted by the VSTL to verify that the system performs all the functions described in the system 

documentation. The manufacturer 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. 

Conclusion: 

The EAC is committed to testing and certifying voting systems incorporating new and innovative 

solutions emerging in the marketplace. Many of these solutions utilize non-traditional voting 

architecture centered on election specific software, combined with off-the-shelf laptop computers, 

tablets, and even smart phones. The VVSG extensions clause, coupled with requirements from the 

FCA, are the vehicles by which these systems can become federally certified and begin to move into 

the marketplace. The extensions clause allows for additional functionality and/or features not 

required by the VVSG, including new and innovative solutions. The Functional Configuration Audit 

requires that these new and innovative solutions (that are described in the system documentation) 

must perform according to the documentation. Thus, new innovative solutions are allowed by the 

VVSG, but need to be tested (and certified) as per the FCA. 

Effective Date: 

Effective upon final publication.