1

Voluntary Voting 

System Guidelines

VVSG 2.0

Recommendations for Requirements for the 

Voluntary Voting System Guidelines 2.0

February 29, 202010, 2021

Prepared for the Election Assistance Commission

At the direction of the

Technical Guidelines Development Committee
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Requirements for VVSG 2.0 February 29, 202010, 2021

Acknowledgements

Chair of the TGDC:

Dr. Walter G. Copan

Director of the National Institute of Standards and Technology (NIST) 

Gaithersburg, MD

Representing the EAC Standards Board: 

Robert Giles

Director

New Jersey Division of Elections

Trenton, NJ

Paul Lux

Supervisor of Elections

Okaloosa County

Crestview, FL

Representing the EAC Board of Advisors: 

Neal Kelley 

Registrar of Voters

Orange County

Orange County, CA

Linda Lamone

Administrator of Elections

Maryland State Board of 

ElectionElections

Annapolis, MD

Representing the Architectural and Transportation Barrier, and Compliance Board (Access 

Board): 

Marc Guthrie

Public Board Member

Newark, OH

Sachin Pavithran

Public Board Member

Logan, UT

Representing the American National Standards Institute (ANSI): 

Mary Saunders

Vice President, Government Relations & Public Policy

American National Standards Institute

Washington, DC

Representing the Institute of Electrical and Electronics Engineers: 

Dan Wallach

Professor, Electrical & Engineering Computer Science

Rice University

Houston, TX

Representing the National Association of State Election Directors (NASED):

Lori Augino

Washington State Director of Elections

Washington Secretary of State 

Olympia, WA

Judd Choate

State Elections Director

Colorado Secretary of State

Denver, CO
3

Individuals with technical and scientific expertise relating to voting systems and equipment:

McDermot Coutts

Chief Architect/Director of Technical 

Development

Unisyn Voting Solutions

Vista, CA

Diane Golden

Program Coordinator

Association of Assistive Technology Act 

Programs

Accessibility Expert

Grain Valley, MO

Geoff Hale

Computer Security Expert

Washington, DC

David Wagner

Professor, Electrical & Engineering 

Computer Science

University of California-Berkeley

Berkeley, CA
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Requirements for VVSG 2.0 February 29, 202010, 2021

Public Working Groups discussed and developed guidance to inform the development of 

requirements for the VVSG.

• The Election Process Working Groups: Pre-Election, Election, and Post-Election Process 

Working Groups performed a great deal of up-front work to collect locale-specific 

election process information and, from that, to create coherent process models.

• The Interoperability Working Group handled voting system interoperability including 

common data format (CDF) modeling and schema development.

• The Human Factors Working Group handled human factors-related issues including 

accessibility and usability.

• The Cybersecurity Working Group handled voting system cybersecurity-related issues 

include various aspect of security control and auditing capabilities.

• The Testing Working Group handled voting system testing-related issues including what 

portions of the new VVSG need to be tested and how to test them.
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Requirements for VVSG 2.0 February 29, 202010, 2021

Executive Summary

The United States Congress passed the Help America Vote Act of 2002 (HAVA) [HAVA02] to 

modernize the administration of federal elections and to establish the U.S. Election Assistance 

Commission (EAC) to provide guidance to the states in their efforts to comply with the HAVA 

administrative requirements. Section 202 of HAVA 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 Version 2.0 Requirements (referred to herein as the Guidelines or 

VVSG 2.0), is the fifth iteration of national level voting system standards. The Federal Election 

Commission published the first two sets of federal standards in 1990 [VSS1990] and 2002.

[VSS2000]. The EAC then adopted Version 1.0 of the VVSG (VVSG 1.0) [VVSG2005] on December 

13, 2005. In an effort to update and improve Version 1.0 of the VVSG, on March 31, 2015, the 

EAC commissioners unanimously approved VVSG 1.1. [VVSG2015]. 

The VVSG 2.0 is a departure from past versions in that a set of principles and associated 

guidelines were first developed to describe how, at a high-level, voting systems should be 

designed, developed, and how they should operate. The VVSG 2.0 requirements were then 

derived from those principles and guidelines. The VVSG 2.0 requirements fitsfit within a 

framework of documents under the EAC Voting System Certification Program that include:

• VVSG 2.0 Principles and Guidelines

• VVSG 2.0 Requirements

• VVSG 2.0 Testing and Certification Program Manual 

The Guidelines were designed to meet the challenges ahead, to replace decade’s old voting 

machines, to improve the voter experience, and provide necessary safeguards to protect the 

integrity of the vote.voting process. All sections of the prior VVSG versions have been reviewed, 

rethoughtre-evaluated, and updated to meet modern expectations about, which address how 

voters should interact with the voting system and how voting systems should be designed and 

developed. The VVSG 2.0 requirements represent the latest in both industry and technology 

best practices, requiring significant updates in many aspects of voting systems. 

The Guidelines allow for an improved and consistent voter experience, enabling all voters to 

vote privately and independently, ensuring votes are marked, verified and cast as intended, and 

that the final count represents the true will of the voters. Federal accessibility standards, 

Section 508, Information and Communication Technology (ICT) Final Standards and Guidelines

[USAB18], and Web Content Accessibility Guidelines (WCAG) [W3C10] are referenced and 

highlighted. Voter interface requirements have been updated to incorporate recent usability 
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Requirements for VVSG 2.0 February 29, 202010, 2021

research and interactions that result from modern devices and now fully support accessibility 

throughout the voting process. 

The cybersecurity of voting systems has never been more important. Indeed, attacks from 

nation state actors on our elections infrastructure in 2016 led to a critical infrastructure 

designation. To limit the attack surface on voting systems, the Guidelines require that any 

election system, such as an e-pollbook or election reporting system, be air-gapped from the 

voting system. To ensure the integrity of the votevoting process, methods have been 

implemented to detect errors through the combined use of an evidence trail and regular audits, 

including risk-limiting audits (RLAs), compliance audits, and ballot-level audits, are now 

supported.. There is a dedicated section on ballot secrecy, preventing voter information from 

being carried through to the voting system, and two-factor authentication is now mandated for 

critical voting operations. Cryptographic protection of data and new system integrity 

requirements ensure that security protections developed by industry over the past decade are 

built into the voting system. These include risk assessment and supply chain risk management, 

secure configurations and system hardening, exploit mitigation, sandboxing and runtime 

integrity. 

The VVSG 2.0 requires the voting system to include the capability to useof using common data 

formats defined by the National Institute of Standards and Technology (NIST) and public 

working groups. The common data formats were created to make election data more 

transparent and interoperable. These formats can be used in addition to any native formats 

used by the manufacturer. Defensive coding practices, reliability and electrical requirements 

were reviewed, updated, and streamlined. Finally, guidance relevant to testing and certification 

has been moved to the EAC’s testing and certification manual. 

This document was produced by the EAC’s Technical Guidelines Development Committee 

(TGDC) working in conjunction with the National Institute of Standards and Technology 

(NIST)NIST to aid in developing guidelines for voting equipment and technologies for making 

accessible, accurate and secure elections possible.

EAC staff must annually review the VVSG for proposed revisions. Determinations must be sent 

to the EAC’s Executive Director (or a person operating in that capacity) to begin the review 

process required by HAVA (review by the TGDC, Board of Advisors, Standards Board, and public 

comment review) to ensure timely adoption of revisions. Under the direction of the Executive 

Director, EAC staff in consultation with NIST staff may make minor technical changes to the 

requirements in a timely manner. This process may include, but is not limited to, the 

development of an appeals process for such minor technical changes. EAC staff is responsible 

for updating the test assertions and issuing requests for interpretation or notices of 

clarification, as needed, to ensure efficiency in the process.
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Table of Contents

Acknowledgements............................................................................................................. 2

Executive Summary............................................................................................................. 5

Introduction ........................................................................................................................ 9

How the VVSG is to be Used ............................................................................................... 9

Scope................................................................................................................................. 10

Implications for Networking and Remote Ballot Marking .......................................... 12

External Network Connections......................................................................................... 12

Remote Ballot Marking ..................................................................................................... 13

Internal Wireless Networks .............................................................................................. 13

Major changes from VVSG 1.1 to VVSG 2.0 ............................................................... 14

VVSG document structure ........................................................................................ 17

Conformance Information ................................................................................................ 17

Organization and Structure of VVSG 2.0 Requirements............................................. 18

Navigating through Requirements............................................................................ 19

Technical standards and terms used in the requirements.......................................... 19

Conformance Language ............................................................................................ 19

Implementation Statement ...................................................................................... 20

Extensions to the VVSG 2.0....................................................................................... 20

The VVSG 2.0 - Principles and Guidelines......................................................................... 21

Principle 1 High Quality Design......................................................................................... 26

Principle 2 High Quality Implementation ......................................................................... 92

Principle 3 Transparent................................................................................................... 130

Principle 4 Interoperable ................................................................................................ 158

Principle 5 Equivalent and Consistent Voter Access ...................................................... 165

Principle 6 Voter Privacy................................................................................................. 175

Principle 7 Marked, Verified, and Cast as Intended ....................................................... 181

Principle 8 Robust, Safe, Usable, and Accessible............................................................ 221

Principle 9 Auditable....................................................................................................... 233

Principle 10 Ballot Secrecy.............................................................................................. 258

Principle 11 Access Control............................................................................................. 268
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Principle 12 Physical Security.......................................................................................... 285

Principle 13 Data Protection........................................................................................... 293

Principle 14 System Integrity .......................................................................................... 304

Principle 15 Detection and Monitoring .......................................................................... 324

Appendix A Glossary of Terms........................................................................................ 339

Appendix B Requirements Listing................................................................................... 398

Appendix C References................................................................................................... 417
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Introduction

This document, the Voluntary Voting System Guidelines 2.0 Requirements (VVSG 2.0), is the 

third version of national level voting system standards. Adherence to the Guidelines is governed 

by state and territory-specific laws and procedures.

VVSG 2.0 is a recommendation from the Technical Guidelines Development Committee (TGDC) 

to the Election Assistance Commission (EAC) for a voting system standard written to address 

the next generation of voting equipment.

This version offers a new approach to the organization of the guidelines. It is a complete rewrite of the VVSG 1.1Voluntary Voting System Guidelines 1.1 (VVSG 1.1) [VVSG2015] and 

contains new and expanded material in many areas, including reliability, usability, accessibility, 

and security.

The requirements of the VVSG 2.0 are more precise, more detailed, and written to be clearer to 

voting system manufacturers and test laboratorieslabs. The language throughout is written to 

be readable and usable by other audiences as well, including election officials, legislators, 

voting system procurement officials, various voting interest organizations and researchers, and 

the public at large.

The VVSG 2.0 requirements were derived from the VVSG 2.0 Principles and Guidelines, which 

contain 15 major principles and 63 associated guidelines that cover voting system design, 

development, and operations.

How the VVSG is to be Used

This document will be used primarily by voting system manufacturers and voting system test 

laboratories as a baseline set of requirements for voting systems to which states will add their 

state-specific requirements as necessary. This audience includes:

• Manufacturers, who will use the requirements when they design and build new voting 

systems as information about how voting systems should perform or be used in certain 

types of elections and voting environments. 

• Test laboratorieslabs who will refer to this document when they develop test plans for 

the analysis and testing of voting systems as part of the national certification process and 

state certification testing to verifying whether the voting systems have satisfied the VVSG 

2.0 requirements.

This document, therefore, serves as an important, foundational tool that defines a baseline set 

or requirements necessary for ensuring that the voting systems used in U.S. elections will be 

secure, reliable, and easy for all voters to use accurately.
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Scope

The scope of the VVSG 2.0 is limited to equipment acquired by states and certified by the EAC. 

The VVSG 2.0 covers pre-voting, voting, and post-voting operations consistent with the 

definition of a voting system in the Help America Vote Act (HAVA) Section 301, [HAVA02],

which 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; cast and count 

votes; report or display election results; and maintain and produce any audit trail information. 

The voting system as defined in the VVSG 2.0 is:

Equipment (including hardware, firmware, and software), materials, and documentation used to 

enact the following functions of an election:

1. define elections and ballot styles, 

2. configure voting equipment, 

3. identify and validate voting equipment configurations, 

4. perform logic and accuracy tests, 

5. activate ballots for voters, 

6. record votes cast by voters, 

7. count votes, 

8. label ballots needing special treatment, 

9. generate reports,

10. export election data including election results,

11. archive election data, and

12. produce records in support of audits.

As part of the voting system scope, HAVA Section 301 [HAVA02] mandates five additional 

functional requirements to assist voters. Although these requirements may be implemented in 

a different manner for different types of voting systems, all voting systems must provide these 

capabilities, which are reflected in the VVSG 2.0 requirements:

1. Permit the voter to verify (in a private and independent manner) their choicechoices

before thetheir ballot is cast and counted.

2. Provide the voter with the opportunity (in a private and independent manner) to change 

their choicechoices or correct any error before thetheir ballot is cast and counted.

3. Notify the voter if they have 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 thetheir ballot before it is cast and counted.

4. Be accessible for individuals with disabilities in a manner that provides the same 

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

otherall voters.
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5. Provide alternative language accessibility pursuant to Section 203 of the Voting Rights 

Act. [VRA65].

Section 301(a)(3)(B) [HAVA02] also states that there should be “... at least one direct recording 

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

each polling place”. However, the Americans with Disabilities Act of 1990 [ADA10] requires that 

voters with disabilities be provided with auxiliary aids that allow them to participate equally in 

the voting process without discrimination. This is consistent with Section 301 of HAVA cited 

above that requires a voting system to be accessible for individuals in a manner that provides 

the same opportunity for access and participation (including privacy and independence). If a 

majority of voters areutilize hand-markingmarked paper ballots, a sufficient number of 

accessible voting stations (including alternative language ballot features) must be available in 

each polling place to ensure their consistent availability in case of malfunctions. A sufficient 

number of machine-marked ballots must also be produced by those voting stations to ensure 

non-discrimination and ballot secrecy, particularly when the ballots produced by the accessible 

voting system differ in size, shape, and/or content from the hand-marked ballots and are thus

readily identifiable. Procedures and training for poll workers on the operation of the accessible 

voting stations are also necessary to support this usage.

There is substantial experience1 showing that having one accessible voting machine per polling 

place used only for voters with disabilities has worked poorly for voters with disabilities and 

may not be sufficient to provide equal access as required by law. For instance, data collected in 

recent elections highlight how difficult it is to ensure that a sufficient number of voters use the 

accessible voting machinemachines to preserve the secrecy of machine-marked ballots and that 

poll workers are able to operate the machines successfully. To support best practices, states 

should consider legislation and additional resources to ensure balanced access to accessible 

voting machines wherever voting technology is deployed and used for elections. 

The VVSG 2.0 definition of a voting system does not expand the HAVA definition but focuses it 

on election processes. The VVSG 2.0 principles, guidelines, and requirements apply to the 

election process functions and, by extension, to the voting devices that implement these 

functions.

The scope of most VVSG 2.0 requirements appliesapply to the entire voting system as opposed 

to specific devices, thus permitting the manufacturer more freedom to implement the 

requirements as they choose. However, when the scope of a requirement is limited to a specific 

function, that information is included in the text of the requirement, for clarity. For example:

• “A voting system’s electronic display must be capable of...”

1 For more details, see:

 a) “Disability, Voter Turnout, and Voting Difficulties in the 2012 Elections” (Rutgers)

https://smlr.rutgers.edu/sites/default/files/images/Disability%20and%20voting%20survey%20report%20for%202012%20elections.pdf;

 b) “Experience of Voters with Disabilities in the 2012 Election Cycle” (National Council on Disability) 

https://ncd.gov/rawmedia_repository/8%2028%20HAVA%20Formatted%20KJ%20V5%20508.pdf; and 

 c) “The Blind Voter Experience: A Comparison of the 2008 and 2012 Elections” (National Federation of the Blind)

https://nfb.org/images/nfb/documents/word/2012_blind_voter_survey_report.docx.
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• “Scanners and ballot marking devices must include...”

• “The cryptographic E2E protocol used in the voting system must...”

Implications for Networking and Remote Ballot Marking

Traditionally, ballots have been cast at polling places or through mail-in absentee ballots. There 

has been a growing trend to provide flexibility for voters to vote early and in-person at vote 

centers or at home using remote ballot marking applications. These innovative methods of 

voting provide additional paths to voting independently and privately for voters including those 

with disabilities. Likewise, advances in technology have led to efficiencies in election 

administration, including increasing the use of e-pollbooks for easy check-in and electronic 

election results reporting for timely aggregation of unofficial election results. 

These additional election systems require network access to synchronize voter records, access 

remote ballot marking applications, and transmit unofficial election results. The measures taken 

to securing these systems isfalls outside the scope of VVSG 2.0. However, the benefits and risks 

associated with the use of these technologies was carefully considered when developing the 

Guidelines, whereas the associated and requirements were created developed to ensure that 

the voting system is isolated from these additional election systems. 

This section clarifies the boundary between the external election systems and the voting 

system as well as the use of wireless technologies within polling places or vote centers. 

External Network Connections 

VVSG 2.0 does not permit devices or components using external network connections to be 

part of the voting system. There are significant security concerns introduced when networked 

devices are then connected to the voting system. This connectivity provides an access path to 

the voting system through the Internet and thus an attack can be orchestrated from anywhere 

in the world (e.g., nation state attacks). The external network connection leaves the voting 

system vulnerable to attacks, regardless of whether the connection is only for a limited period 

or if it is continuously connected. TheThese types of attacks include the following: 

• The loss of confidentiality and integrity of the voting system and election data through 

malware injection or eavesdropping.

• The loss of availability to access data or perform election process (e.g., ransomware 

attack)).

The VVSG 2.0 requirements address the concerns of external network connections (see 14.2-E –

External network restrictions and 15.4-B – Secure network configuration documentation). 

Externally -networked devices or components, such as those used for e-pollbooks or 

transmission of election results, must be physically isolated from the voting system. This 
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physical isolation can be described as an airgapair gap between any systems that have an 

external network connection.

Remote Ballot Marking

Remote ballot marking is defined as an election system for voters to mark their ballots outside 

of a voting center or polling place. These systems are a tool to be used to enable as a tool which

enables “no excuse” absentee voting. They allowThis allows a voter to receive a blank ballot to 

mark electronically, print, and then cast by returning the printed ballot to the electionsan

election office. A voter may electronically fill out their ballot with a state-provided web 

application. Remote ballot marking applications provide another path to voting independently 

and privately for voters including those with disabilities. 

The VVSG 2.0 requirements apply to devices used to mark ballots inside a polling place or vote 

center. They do not apply to remote ballot marking devices and applications. The VVSG 2.0 

requirements affect only those voting system devices that constitute a voting system and that 

are submitted for testing and certification. For remote ballot marking, the voter uses a web 

application, their own personal device, and an external network (i.e., the Internet). 

It should be noted that remote ballot marking applications need to comply with accessibility 

laws such as the Americans with Disabilities Act. of 1990 [ADA10]. VVSG 2.0 requirements that 

address the accessibility and usability for the electronic interface of a remote ballot marking 

software application can serve as an informative resource for developers of these systems. For 

example, 8.2-A — Federal standards for accessibility, identifies the WCAG Level AA checkpoints 

in the Section 508 [USAB18] – Standards as a requirement for voting system electronic 

interfaces.

Internal Wireless Networks

Internal wireless networks wirelessly communicate or transfer information between two or 

more devices. Examples include use of wireless (Bluetooth) mice and keyboards or (Wi-Fi) 

printers. There are also growing trends towards using wireless technology for assistive devices 

such as headsets or hearing aids. 

Wireless technology within the voting system introduces security concerns in that wireless 

networks can provide an entry point to the voting system for attackers. The security 

configurations for devices used in wireless technologies are not all equally secure, with some 

configured to provide more strength than others. 

The VVSG 2.0 requires that a voting system be incapable of broadcasting a wireless network 

(see 14.2-DC – Wireless communication restrictions and 15.4-C – Documentation for disabled 
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wireless). Instead, a voting system could use wired technology, e.g., Ethernet cables, to connect 

devices such as printers. 

Wireless personal assistive technologies are still possible, however. A voter may use their 

Bluetooth headset by using an adapter connected to the voting system’s 3.5mm5 mm standard 

headphone jack, which creates a Bluetooth wireless connection between the adaptor and the 

headset. This effectively limits the attack surface to that of the headphone jack’s analog 

communications without limiting the use of the voter’s personal assistive technology. 

Major changes from VVSG 1.1 to VVSG 2.0

There are many new or updated requirements, strengthening the security, interoperability, 

and usability and accessibility of voting systems.

Principle 1 - High Quality Design 

• Functional equipment requirements are organized as phases of running an election:

o Election and Ballot Definition

o Pre-election Setup and logic and accuracy (L&A) testing

o Opening Polls, Casting Ballots

o Closing Polls, Results Reporting

o Tabulation, Audit

o Storage

• Requirements dovetail with cybersecurity in areas including:

o Pre-election setup

o Audits of barcodes versus readable content for ballot marking devices (BMDs)

o Audits of scanned ballot images versus paper ballots

o Audits of Cast Vote Record (CVR) creation

o Content of various reports

o Ability to match a ballot with its corresponding CVR

• Guidance relevant to testing and certification has been moved to the EAC testing and 

certification manuals.

Principle 2 - High Quality Implementation

• Adds requirement to document and report on user-centered design process by 

developer to ensure system is designed for a wide range of representative voters, 

including those with and without disabilities, and election workers (P 2.2)
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Principle 3 – Transparent

• Addresses transparency from the point of view of documentation that is necessary and 

sufficient to understand and perform all operations

Principle 4 - Interoperable 

• Ensures that devices are capable of importing and exporting data in common data 

formats

• Requires manufacturers to provide complete specification of how the format is 

implemented

• Requires that encoded data uses publicly available, no-cost method

• Uses common methods (for example, a USB) for all hardware interfaces

• Permits commercial-off-the-shelf (COTS) devices as long as relevant requirements are 

still satisfied

Principle 5 - Equivalent and Consistent Voter Access 

• Applies to all modes of interaction and presentation throughout the voting session, fully 

supporting accessibility 

Principle 6 - Voter Privacy 

• Distinguishes voter privacy from ballot secrecy and ensures privacy for marking, 

verifying, and casting the ballot

Principle 7 - Marked, Verified, and Cast as Intended 

• Updates voter interface requirements such as font, text size, audio, interaction control 

and navigation, scrolling, and ballot selections review

• Describes requirements that are voting system specific, but derived from federal 

accessibility law

Principle 8 - Robust, Safe, Usable, and Accessible 

• References Federal accessibility standards, Section 508 Information and Communication 

Technology (ICT) Final Standards and Guidelines [USAB18] and Web Content Accessibility 

Guidelines 2.0 (WCAG 2.0) [W3C10]

• Updates requirements for reporting developer usability testing with voters and election 

workers 
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Principle 9 - Auditable 

• Focuses on machine support for post-election audits

• Makes software independence mandatory

• Supports paper-based and end-to-end (E2E) verifiable systems

• Supports all types of audits, including risk-limiting audits (RLAs), compliance audits, and 

ballot-level audits

Principle 10 - Ballot Secrecy 

• Includes a dedicated ballot secrecy section 

• Prevents association of a voter identity to ballot selections

Principle 11 - Access Control 

• Prevents the ability to disable logging

• Bases access control on voting stage (pre-voting, activated, suspended, post-voting)

• Does not require role-based access control (RBAC)

• Requires multi-factor authentication for critical operations: 

o Software updates to the certified voting system

o Aggregating and tabulating

o Enabling network functions

o Changing device states, including opening and closing the polls

o Deleting the audit trail

o Modifying authentication mechanisms

Principle 12 - Physical Security 

• Requires using only those exposed physical ports that are essential to voting operations

• Ensures that physical ports are able to be logically disabled

• Requires that all new connections and disconnections be logged

Principle 13 - Data Protection 

• Clarifies that there are no hardware security requirements (for example, TPM (trusted 

platform module))

• Requires Federal Information Processing Standard (FIPS) 140-2 [NIST01] validated 

cryptographic modules (except for end-to-end cryptographic functions)

• Requires cryptographic protection of various election artifacts

• Requires digitally signed tabulation reportscast vote records and ballot images

• Ensures transmitted data is encrypted with end-to-end authentication
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Principle 14 - System Integrity 

• Requires risk assessment and supply chain risk management strategy

• Removes non-essential services

• Secures configurations and system hardening

• Exploit mitigation (for example, address space layout randomization (ASLR) data 

execution prevention (DEP) and free of known vulnerabilities

• Requires cryptographic boot validation

• Requires authenticated updates

• Ensure sandboxing and runtime integrity

Principle 15 - Detection and Monitoring 

• Ensures moderately updated list of log types

• Requires firewalls and Intrusion Detection System for networked systems

• Detection systems must be updateable

• Requires digital signatures or whitelistingallowlisting for voting systems

• Requires malware detection focusing on backend PCs

VVSG document structure

This document contains the following sections:

• Principles and Guidelines: High level system design goals

• Requirements: Detailed technical requirements that support the principles and 

guidelines 

• Appendix A - Glossary of Terms: Terminology used in requirements and informative 

language

• Appendix B - List of all Requirements: A summary listing of the titles of all requirements

• Appendix C - References: References to external sources used in the writing of the 

requirements

Conformance Information

This section provides information and requirements about how manufacturers can use the 

features ofmaterial in this document to assess whether a voting system conforms to the VVSG 

Principles and Guidelines. Conformance here means only that the requirements of the VVSG 

have been met; it does not imply certification according to the EAC’s Voting System 

Certification Program.
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Organization and Structure of VVSG 2.0 Requirements

The VVSG 2.0 requirements are organized and numbered according to the principles and 

guidelines they are most applicable to. They have the following fields:

• Number and title of each requirement

• Text of each requirement

• Optional informative discussion field

• Optional informative fieldsfield for source and applicability of the requirement

As an example, Requirement 8.1-B contains all four fields:

8.1-B – Flashing

If the voting system emits lights in flashes, there must be no more than three flashes in 

any one-second period.

Discussion

This requirement has been updated to meet WCAG 2.0 [W3C10] and Section 508 [USAB18]

software design issue standards.

External references: WCAG 2.0/Section 508

Prior VVSG sources: VVSG 1.1 - 3.2.5.a.i

Applies to: Electronic interfaces

Requirements are indicated by the presence of a unique number in the left margin, followed by 

a descriptive title. 

The Discussion field may aid in understanding the requirement but does not itself constitute a 

requirement.

The optional informative fields show the source of the requirement related requirements and to 

which functions or devices of the voting system it applies:

• External references: specifications or laws that are sources for the requirement. 

Prior

• “Related requirements:” VVSG sources: previous VVSG requirements thatelsewhere in 

the document related to the current requirement is updating. .

• “Applies to::” indicates the type of voting system function or device to which the 

requirement applies. This field is used only if the applicability of a requirement is not 

already clear in the requirement text.
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Requirements for VVSG 2.0 February 29, 202010, 2021

Navigating through Requirements

You can navigate through the requirements:

From the list of principles and guidelines. in the Table of Contents. Links in this list gonavigate

to the requirements that support each principle or guideline.

From the list of all requirements in Appendix B.: Requirements Listing. This list lets you 

quickly identify requirements in each section. Each title is also linked to the requirement text. 

for navigation throughout the document. 

In addition, features of the Adobe Acrobat Reader can be useful. More information can be 

found in Adobe’s help site under Navigating PDF Pages. 

Technical standards and terms used in the requirements

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

reference.through the use of references. These are referred to by title in the body of the 

document. The full citations for these publications are provided in Appendix C: References. This 

appendix also includes other references that may be useful for understanding the information. 

References in requirements and informative text are linked to Appendix C.

The requirements 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 whichwhat is commonly used by the 

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

systems. Requirements that use words with special meanings are linked to their definitions in 

Appendix A,: Glossary of Terms.

Conformance Language

The text of a requirement is referred to as normative, meaning that the text constitutes the 

requirement and must be satisfied when implementing and testing the voting device or system. 

Text in this document that is not part of a requirement is referred to as informative, meaning 

that it is for informational purposes only and does not contain requirements. 

The following keywords are used to convey conformance requirements: 

“Must” indicates a mandatory requirement. Synonymous with "is required to."

“Must not” also indicates a mandatory requirement, but the requirement is to not do 

something.
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Requirements for VVSG 2.0 February 29, 202010, 2021

“May” indicates an optional, permissible action and often suggests one possible way of 

conforming to a more general requirement.

What is neither required nor prohibited by the language of the requirements is permitted.

Informative parts of this document include discussion, examples, extended explanations, and 

other matters that are necessary to understand the VVSG Principles and Guidelines and how to 

conform to them. Informative text may serve to clarify requirements, but it is not otherwise 

applicable to achieving conformance. Unless otherwise specified, a list of examples should not 

be interpreted as excluding other possibilities that were not listed.

Implementation Statement

A voting system conforms to the VVSG Principles and Guidelines if all stated requirements that 

apply to that voting system and all of its devices are fulfilled. 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 (that is, additional 

functionality) that it implements.

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

voting system submitted for conformity assessment. It is used by test labs to identify the 

conformity assessment activities that are applicable.

The implementation statement must include: 

• Full product identification of the voting system, including version number or timestamp

• Separate identification of each device that is part of the voting system

• Device capacities and limits

• List of languages supported

• List of accessibility capabilities

• List of voting variations supported

• Devices that support the core functions and how they do it

• List of requirements implemented

• Any extensions also included in the voting system

• Signed document that the information provided accurately characterizes the system 

submitted for testing

Extensions to the VVSG 2.0

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

not defined in the requirements. Extensions are permitted to accommodate the needs of states 

that may impose additional requirements and to accommodate changes in technology, 

extensions are permitted.. However, an extension is not allowed to contradict or relax 

requirements that would otherwise apply to the system and its devices.
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Requirements for VVSG 2.0 February 29, 202010, 2021

The VVSG 2.0 - Principles and Guidelines

The VVSG 2.0 consists of 15 principles and 53 guidelines. Together these principles and 

guidelines cover voting system design, development, and operations.

Principle 1: HIGH QUALITY DESIGN 

The voting system is designed to accurately, completely, and robustly carry out election 

processes. 

1.1 - The voting system is designed using commonly -accepted election process 

specifications. 

1.2 - The voting system is designed to function correctly under real-world operating 

conditions. 

1.3 - Voting system design supports evaluation methods enabling testers to clearly 

distinguish systems that correctly implement specified properties from those that do 

not. 

Principle 2: HIGH QUALITY IMPLEMENTATION 

The voting system is implemented using high quality best practices. 

2.1 - The voting system and its software are implemented using trustworthy materials 

and best practices in software development.

2.2 - The voting system is implemented using best practice user-centered design 

methods that consider a wide range of representative voters, including those with and 

without disabilities, and election workers.

2.3 - Voting system logic is clear, meaningful, and well-structured. 

2.4 - Voting system structure is modular, scalable, and robust. 

2.5 –- The voting system supports system processes and data with integrity. 

2.6 - The voting system handles errors robustly and gracefully recovers from failure. 

2.7 - The voting system performs reliably in anticipated physical environments.

Principle 3: TRANSPARENT 

The voting system and voting processes are designed to provide transparency. 
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Requirements for VVSG 2.0 February 29, 202010, 2021

3.1 - The documentation describing the voting system design, operation, accessibility 

features, security measures, and other aspects of the voting system can be read and 

understood. 

3.2 - The processes and transactions, both physical and digital, associated with the 

voting system are readily available for inspection. 

3.3 - The public can understand and verify the operations of the voting system 

throughout the entirety of the election. 

Principle 4: INTEROPERABLE 

The voting system is designed to support interoperability in its interfaces to external 

systems, its interfaces to internal components, its data, and its peripherals. 

4.1 - Voting system data that is imported, exported, or otherwise reported, is in an 

interoperable format. 

4.2 - Standard, publicly -available formats for other types of data are used, where 

available. 

4.3 - Widely-used hardware interfaces and communications protocols are used. 

4.4 - Commercial-off-the-shelf (COTS) devices can be used if they meet applicable VVSG 

requirements. 

Principle 5: EQUIVALENT AND CONSISTENT VOTER ACCESS 

All voters can access and use the voting system regardless of their abilities.

5.1 - Voters have a consistent experience throughout the voting process within any 

method of voting.

5.2 - Voters receive equivalent information and options in all modes of voting. 

Principle 6: VOTER PRIVACY 

Voters can mark, verify, and cast their ballot privately and independently. 

6.1 - The voting process preserves the privacy of the voter's interaction with the ballot, 

modes of voting, and vote selections. 

6.2 - Voters can mark, verify, and cast their ballot or other associated cast vote record, 

without assistance from others. 
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Requirements for VVSG 2.0 February 29, 202010, 2021

Principle 7: MARKED, VERIFIED, AND CAST AS INTENDED 

Ballots and vote selections are presented in a perceivable, operable, and understandable 

way and can be marked, verified, and cast by all voters. 

7.1 - The default voting system settings present a ballot usable for the widest range of 

voters, and voters can adjust settings and preferences to meet their needs. 

7.2 - Voters and election workers can use all controls accurately, and voters have direct 

control of all ballot changes and selections. 

7.3 - Voters can understand all information as it is presented, including instructions, 

messages from the system, and error messages. 

Principle 8: ROBUST, SAFE, USABLE, AND ACCESSIBLE 

The voting system and voting processes provide a robust, safe, usable, and accessible 

experience. 

8.1 - The voting system’s hardware, software, and accessories are robust and do not 

expose users to harmful conditions. 

8.2 - The voting system meets currently accepted federal standards for accessibility. 

8.3 - The voting system is evaluated for usability with a wide range of representative 

voters, including those with and without disabilities.

8.4 - The voting system is evaluated for usability with election workers.

Principle 9: AUDITABLE 

The voting system is auditable and enables evidence-based elections. 

9.1 - An error or fault in the voting system software or hardware cannot cause an 

undetectable change in election results. 

9.2 - The voting system produces readily available records that provide the ability to 

check whether the election outcome is correct and, to the extent possible, identify the 

root cause of any irregularities. 

9.3 - Voting system records are resilient in the presence of intentional forms of 

tampering and accidental errors. 

9.4 - The voting system supports efficient audits.

Principle 10: BALLOT SECRECY 

The voting system protects the secrecy of voters’ ballot selections. 
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Requirements for VVSG 2.0 February 29, 202010, 2021

10.1 - Ballot secrecy is maintained throughout the voting process. 

10.2 - The voting system does not contain nor produce records, notifications, 

information about the voter or other election artifacts that can be used to associate the 

voter’s identity with the voter’s intent, choices, or selections. 

Principle 11: ACCESS CONTROL 

The voting system authenticates administrators, users, devices, and services before granting 

access to sensitive functions. 

11.1 - The voting system enables logging, monitoring, reviewing, and modifying of 

access privileges, accounts, activities, and authorizations. 

11.2 - The voting system limits the access of users, roles, and processes to the specific 

functions and data to which each entity holds authorized access.

11.3 - The voting system supports strong, configurable authentication mechanisms to 

verify the identities of authorized users and includes multi-factor authentication 

mechanisms for critical operations. 

11.4 - The voting system’s default access control policies enforce the principles of least 

privilege and separation of duties. 

11.5 - Logical access to voting system assets are revoked when no longer required. 

Principle 12: PHYSICAL SECURITY 

The voting system prevents or detects attempts to tamper with voting system hardware. 

12.1 - The voting system supports mechanisms to detect unauthorized physical access. 

12.2 - The voting system only exposes physical ports and access points that are essential 

to voting operations. 

Principle 13: DATA PROTECTION 

The voting system protects data from unauthorized access, modification, or deletion. 

13.1 –The voting system prevents unauthorized access to or manipulation of 

configuration data, cast vote records, transmitted data, or audit records. 

13.2 - The source and integrity of electronic tabulation reports are verifiable. 

13.3 - All cryptographic algorithms are public, well-vetted, and standardized. 

13.4 - The voting system protects the integrity, authenticity, and confidentiality of 

sensitive data transmitted over all networks. 
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Principle 14: SYSTEM INTEGRITY 

The voting system performs its intended function in an unimpaired manner, free from 

unauthorized manipulation of the system, whether intentional or accidental. 

14.1 - The voting system uses multiple layers of controls to provide resiliency against 

security failures or vulnerabilities. 

14.2 - The voting system is designed to limit its attack surface by avoiding unnecessary 

code, data paths, connectivity, and physical ports, and by using other technical controls. 

14.3 - The voting system maintains and verifies the integrity of software, firmware, and 

other critical components. 

14.4 - Voting system software updates are authorized by an administrator prior to 

installation. 

Principle 15: DETECTION AND MONITORING 

The voting system provides mechanisms to detect anomalous or malicious behavior. 

15.1 - Voting system equipment records important activities through event logging 

mechanisms, which are stored in a format suitable for automated processing. 

15.2 - The voting system generates, stores, and reports all error messages as they occur. 

15.3 - The voting system is designed to protect against malware. 

15.4 - A voting system with networking capabilities employs appropriate, well-vetted 

modern defenses against network-based attacks, commensurate with current best 

practice. 
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Principle 1

High Quality Design

HIGH QUALITY DESIGN 

The voting system is designed to accurately, completely, and robustly 

carry out election processes. 

1.1 - The voting system is designed using commonly -accepted election 

process specifications. 

1.2 - The voting system is designed to function correctly under realworld operating conditions. 

1.3 - Voting system design supports evaluation methods enabling 

testers to clearly distinguish systems that correctly implement specified 

properties from those that do not. 
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Requirements for VVSG 2.0 February 29, 202010, 2021

Principle 1

HIGH QUALITY DESIGN

The voting system is designed to accurately, completely, and robustly 

carry out election processes.

The requirements for Principle 1 and its guidelines include functional requirements for election 

definition and preparation through all voting processes concluding with closing of the polls, 

tabulating, and reporting. The requirements deal with how voting systems are designed to 

operate during election processes, including limits for stress and volume. Other principles 

provide more detailed requirements in other areas including accessibility, security, and 

usability.

The requirements for Guideline 1.1 are arranged into sections by election process with 

requirements containing the basic core requirements for conducting an election: 

1 – Election definition which deals with the capabilities of the voting system to define an 

election, that is, manage items such as election districts, contests, candidates, and to define 

ballots for the election that may be specific to various combinations or splits of precincts. 

Support for the specifications described in the Election Results Common Data Format 

Specification (NIST SP 1500-100 common data format (CDF)) [NIST16] is required for imports 

and exports.

2 – Equipment setupPre-election testing which deals with capabilities of the voting system to 

configure and verify correctness of devices before opening the polls. Logic and accuracy (L&A) 

testing is covered here, as well as new requirements to check that cast vote records (CVR) are 

created properly and that any encoded data such as barcodes is accurately recorded.

3 - Opening the polls which deals with capabilities of the voting system to ensure that the 

voting system is properly configured so that polls can be opened.

4 - Ballot activationCasting which deals with functions neededthe capabilities of the voting 

system to enable a voter to activate theand cast a ballot for a voter. If ballot activation occurs 

on an electronic pollbook, one cannot test and verify whether these requirements are satisfied 

unless the entire pollbook is also tested.

5 - Casting which deals with the capabilities of the voting system to enable a voter to cast a 

ballot. Additionally, the requirements deal with capabilities needed for common vote 

variations, ballot measures, and write-ins.

6

5 - Recording voter choices which deals with casting ballots and how equipment will handle 

ballots as they are cast, including the processes involved in recording votes in cast vote records. 

ItThis mandates recording the selected contest options, and other information needed for 

linking the CVR with the device that is creating the CVRs and for auditing.
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7

6 – Ballot handling for scannersvote-capture devices which deals with functions that scanners 

will provide, including separating ballots for various reasons, for example, because of write-ins 

on manually-marked paper ballots and handling mis-fed ballots. It deals with the behavior of 

batch-fed scanners and voter-facing scanners when scanning ballots that need manual handling 

or inspection, such as for write-ins or unreadable ballots.

8 – Closing the polls

7 – Exiting or suspending voting which deals with exiting the voting mode (closing the polls), 

that is, stopping voting and preventing further voting. This applies to those systems located at a 

remote location such as the polling place or vote centers. 

9

8 – Tabulation which deals with how tabulation processes will handle voting methodsvariations, 

including those methods used most commonly across the United States. 

10

9 - Reporting results which deals with the need for the voting system to have the capability to 

createof creating all required precinct post-election reports. This includes recording ballots such 

as absentee ballots and Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA) 

ballots.

The requirements for Guideline 1.2 cover how a voting system is designed to function correctly 

under real-world operating conditions. They address: 

• Reliability – the failure rate benchmark for reliability, the need to protect against a

single point of failure, and the need for systems to withstand the failure of input and 

storage devices.

• Accuracy – the need to satisfy integrity constraints for accuracy, to achieve the required 

end-to-end accuracy benchmark, and the ability to reliably detect marks on the ballot.

• Mid-feedMisfeed rate – which treats all misfeeds, such as multiple feeds, jams, and 

ballot rejections collectively as “misfeeds” and the need to meet the misfeed rate 

benchmark.

• Stress – the ability to respond gracefully to all stresses of the system’s limits.

• Election volume –the ability to handle a realistic volume of activities in normal use 

throughout an entire election process.

The requirements for Guideline 1.3 cover how voting system design supports evaluation 

methods that enable testers to distinguish a system that correctly implementimplements

specified properties from those that do not. They include:

• IdentifiabilityReporting of manufacturer-performed tests – so testers can clearly 

identify the fullhave a baseline set of basicinformation significant for the specification, 

performance, and compound elementsreporting of theeach test.

• Coverage of manufacturer-performed tests– so that all requirements applicable to a 

submitted system are also covered by submitted tests.

• System configuration processes– so testers can understand how particular 

configurations of process and technology are formed to produce a final working system.
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Requirements for VVSG 2.0 February 29, 202010, 2021

• Observable configurations – so testers can detect plausible observational tools and 

techniques to observe signs of the system configurations.

• Identifiable resolution limits – so testers can determine how well the observational 

tools and techniques can detect and distinguish each type of element in a system 

configuration.

• Observational noise and consequences – so testers can determine what sources of 

noise will arise from observing a system configuration and be able to map observable 

signs of those configurations.

• Performance criteria – so testers can state criteria the enable them to unambiguously 

decide whether an observed configuration exhibits intended properties.

• Evaluation methods – so testers can derive, construct and execute plausible evaluation 

methods that can:

o Observe system configurations using observation tools and techniques

o Decide whether a configuration has satisfied the performance criteria.

o Report the findings.
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Requirements for VVSG 2.0 February 29, 202010, 2021

1.1 – The voting system is designed using commonly-accepted election 

process specifications.

1.1.1 – Election definition

1.1.1-A – Election definition

An election definitionThe voting system must provide the capability to import, define, 

maintain, and export the information necessary to define ballots and hold an election, 

including accurate information on for:

1. election districts,

2. contests, and ballot measures,

2.3. candidates, and

3.4. ballot style information, along with the number of allowable votes for each 

contest and related rules for voting and tabulating the results.

Discussion

This requirement and its sub-requirements deal with the processes involved in states that election 

definition, including and ballot definition and layout. Itcapabilities must be included within the voting 

system. Ballot style information includes capability to:

• import election definition data that can be stored in external databases, and 

• export the same data. 

It includes the most commonly used voting methods in the United States, including for write-ins, 

ballot questions, straight party voting, N-of-M contests, cumulative voting contests, proportional 

voting contests, and ranked choice voting contests.

1.1.1-B – Election definition details

The election definition function must be capable of importing, defining, and maintaining:

1. contests and their associatedthose labels and instructions

1. candidate names and their associated labels

2. ballot measures and their associated text

,Discussion
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Requirements for VVSG 2.0 February 29, 202010, 2021

Labels means any headers, footers, orand other text information typically found on ballots and that 

appears on the ballot along with the contest or candidate’s name. 

External reference: NIST 1500-100 CDF

Related requirements 1.1.1-Z – Data inputs and outputs

1.1.1-C – Define political geographies

An election definition must clearly describe the political geographies where the list of 

contests varies between subdivisions. The political geographies include:

1. election districts, including Congressional, state government, and local government that 

may overlap each other

county, city, town and townshipacross jurisdictions and precincts, splits, and combinations of 

precincts. Requirements in Principle 4: Interoperable deal with using common data formats for 

importing and exporting election definition information. 

2. user-defined geographies

Discussion

User-defined geographies could include non-election districts such as mosquito abatement districts.

1.1.1-DB – Serve multiple or split precincts and election districts

An election definitionThe voting system must describe election districts and precincts in such 

a way that a given polling place may serve:

1. two or more election districts; and/or

2. combinations of precincts and split precincts.

Discussion

This requirement addresses the capability of precinct devices to be flexible in accommodatingto 

accommodate multiple ballot styles depending on the political geography being served by a polling 

place.

1.1.1-E –C – Multiple identifiers

An election definitionThe voting system must enable election officials (EOs) to associate 

multipleat least three identifiers that can be cross-referenced with each other for 

administrative subdivisions, election districts, contests, and candidates, including for. This 

also includes:

1. locally -defined identifiers;
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Requirements for VVSG 2.0 February 29, 202010, 2021

2. state-wide-defined identifiers; and

3. Open Civic Data Identifiers ([OCD-IDs)ID].

Discussion

Discussion

This requirement is based on the need to support cross-referencing of statewide identifier schemes

or schemes, such as Open Civic Data Identifiers [OCD-IDsID] with those used on a more local level. 

1.1.1-FD – Definition of parties and contests

An election definitionThe voting system must allow for:

1. the definition of political parties and indicate the affiliation or endorsements of each 

contest option;

2. information on both party-specific and non-party-specific contests, with the 

capability to include both contests on the same ballot; and

3. contests that include ballot positions with write-in opportunities.

1.1.1-GE – Voting methodsvariations

An election definition must enable election officialsThe voting system must provide the 

capability to define and identify contests, contest options, candidates, and ballot questions 

using all voting methodsvariations indicated in the manufacturer-provided implementation 

statement.

Discussion

1. For N-of-M contests, an election definition must be capable of defining contests 

where the voter is allowed to choose up to a specified number of contest options 

from a list of options.

2. For ballot questions, an election definition must include the ability to create ballot 

questions where the voter is allowed to vote yes or no on a question.

3. For ballot questions, an election definition must include the ability to create ballot 

questions where the voter is allowed to vote on one or more from a list of possible 

choices on a question.

4. For the cumulative voting method, an election definition must include the ability to 

create ballot questions where the voter is allowed to allocate up to a specified 

number of votes over a list of contest options, possibly giving more than one vote to 

a given option.
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Requirements for VVSG 2.0 February 29, 202010, 2021

5. For the proportional voting method, an election definition must include the ability to 

create ballot questions where the candidate gets the number of votes equal to those 

allowed divided by number of selections. 

6. For the ranked choice voting method, an election definition must include the ability 

to create ballot questions where the voter is allowed to rank contest options in order 

of preference, as first choice, second choice, etc.

7. For the cross-party endorsement voting method, an election definition must include 

the ability to create ballot questions about the necessary straight party contest and 

record the endorsements made by each party in the election definition. This supports 

gathering and recording votes for the slate of contest options endorsed by a given 

political party when a given contest option is endorsed by two or more different 

political parties. 

1.1.1-H – Election definition accuracy

An election definition must record the election contests, contest options, issues, and political 

and administrative subdivisions exactly as defined by EOs.

1.See requirements in sections 1.1.4 – Casting and 1.1.8 – Tabulation for voting variations most 

commonly used in the U.S.

1.1-I – Voting options accuracy

An election definition must record the options for casting and recording votes exactly as 

defined by EOs. 

.1.1.1-J-F – Confirm recording of election definition

An election definitionThe voting system must check and confirm that its data is correctly 

recorded to a persistent storage system.

Discussion

Discussion

"Persistent storage" includes storage systems such as nonvolatilenon-volatile memory, hard disks, 

and optical disks. 
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Requirements for VVSG 2.0 February 29, 202010, 2021

1.1.1.1.1-K-G – Election definition distribution

An election definitionThe voting system must provide for generatingcreation of master and 

distributed copies of election definitionsdefinition information as needed to configure each 

voting device in the voting system.

1.1.1-L – Define ballot stylesH – Jurisdiction-dependent content

An election definitionThe voting system must enable EOselection officials to defineupdate 

jurisdiction-dependent text, line art, logos, and images to ballot styles.

1.1.1-M – Auto-format

An election definition must be capable of automatically formatting ballots according to 

jurisdictional requirements for office and contest options qualified to be placed on the ballot 

for each political subdivision and election district.

1.1.1-NI – Include contests 

An election definitionThe voting system must provide for the inclusion of all contests in a 

given ballot style of all contests, in which the voter would beis entitled to vote.

1.1.1-OJ – Exclude contests

An election definitionThe voting system must provide for the exclusion of any contest from a 

given ballot style of any contest , in which the voter would beis prohibited from voting 

because of place of residence or other administrative criteria.

Discussion

Discussion

In systems supporting primary elections, this requirement would include the exclusion of partyspecific contests thatfor which voters in a particular political party are not eligible to vote in.

1.1.1-P – Nonpartisan formatting

An election definition must support the uniform allocation of space and fonts used for each 

office, contest option, and contest so the voter does not perceive that one contest option is 

preferred over any other.
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Requirements for VVSG 2.0 February 29, 202010, 2021

1.1.1-Q – Jurisdiction-dependent content

An election definition must enable EOs to add jurisdiction-dependent text, line art, logos, 

and images to ballot styles.

1.1.1-RK – Primary elections, associate contests with parties

When implementing primary elections, an election definitionThe voting system must support 

the association of different contests with different political parties when administering

primary elections.

1.1.1-SL – Ballot rotation, Election definition

When implementing ballot rotation, an election definitionThe voting system must support 

producingthe production of rotated ballots or activating ballot rotation functions in votecapture devices by including relevant metadata in distributed election definitions and ballot 

styles.

Related requirement: 1.1.5-I – Ballot rotation for contest options

1.1.1-T-M – Ballot configuration in combined or split precincts

When implementing combined or split precincts, an election definitionThe voting system

must include the ability to createcapability of creating distinct ballot configurations for 

voters from two or more election districts that are served by a given polling place or vote 

center.

1.1.1-U – No advertising

The ballot presented to the voter must not display or link to any advertising or commercial 

logos of any kind, whether public service, commercial, or political.

1.1.1-V – Ballot style distribution

An election definition must include the option to generate master and distributed copies of 

ballot styles as needed to configure each voting device in the system.

1.1.1-WN – Ballot style identification

An election definition must The voting system must include the capability to generate codes 

or marks as needed to uniquely identify the ballot style associated with any ballot.

Discussion
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Requirements for VVSG 2.0 February 29, 202010, 2021

In paper-based systems, identifying marks would appear on the actual ballots. Ballot marking devices 

(BMDs) would make internal use of unique identifiers for ballot styles but would not necessarily 

present these where the voter would see them. In both cases, the identifying mark also could be 

recorded in the cast vote record.

1.1.1-X – Retaining, modifying, reusing definitions

An 2 – Pre-election definition must support retaining, modifying, and reusing 

general districting or precinct definitions and ballot formatting parameters 

within the same election and from one election to the next. testing

1.1.1-Y – Ballot style protection

An election definition must prevent unauthorized modification of any ballot styles.

Discussion

See security requirements for information on techniques to prevent unauthorized modifications. 

1.1.1-Z – Data inputs and outputs

An election definition must support NIST 1500-100 CDF specifications for election 

programming data inputs and outputs, including for:

1. import of election programming data

2. export of election programming data

3. reports of election programming data to ensure the data is inspected and verified

Discussion

Item 1 concerns import of pre-election data such as for identification of political geography, contest, 

candidate, ballot data, and other pre-election information used to setup an election and produce 

ballots. Items 2 and 3 refer to exporting and reporting the pre-election data from the election 

definition device so that it can be checked for accuracy or exchanged as needed.

External reference: NIST 1500-100 CDF

Related requirements 1.1.1-B – Election definition details
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Requirements for VVSG 2.0 February 29, 202010, 2021

1.1.2 – Equipment setup

1.1.2-A – Equipment setup

The voting system must provide the capability to verify that: 

1. all voting devices are properly prepared for an election using real world scenarios and 

collect data that verify equipment readiness

2. all system equipment is correctly installed and interfaced 

3. hardware and software function correctly

Discussion

This requirement and its sub-requirements deal with equipment setup prior to the election. They 

deal primarily with logic and accuracy testing (L&A), whose purpose is to detect malfunctioning and 

misconfigured devices before polls are opened. Election personnel conduct equipment and system 

readiness tests before an election to:

• ensure that the voting system functions properly, 

• confirm that system equipment has been properly integrated, and 

• obtain equipment status and readiness reports. 

The intent is that the voting system and devices be configured so real-world configuration scenarios 

will be supported and testable.

1.1.2-B – Built-in self-test and diagnostics

The voting system must include built-in measurement, self-testing, and diagnostic software 

and hardware for monitoring and reporting the system's status and degree of operability.

1.1.2-C – Verify proper preparationB – Installation of software and ballot 

styles

An election definition must allow for EOs to test that ballot styles and programs have been 

properly prepared.

1.1.2-D – Verify proper installation of ballot styles

The voting system must include the capability to automatically verify that the software and 

ballot styles have been properly selected and installed in the equipment and can 

immediately notify an EOto provide notification of any errors that occur while selecting or 

installing software and ballot styles.
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Requirements for VVSG 2.0 February 29, 202010, 2021

Discussion

At a minimum, notification means an error message, and a log entry, and a "failed" result on this 

portion of the L&A test. Examples of detectable errors include use of software or data intended for a 

different type of device or operational failures in transferring the software or data.

1.1.2-E – Verify compatibility between software and ballot styles

1.1.2-C – Use of test ballots

The voting system must includeprovide the ability to automatically verify that software 

correctly matches the ballot styles that it is intended to process and immediately notify an 

EO of any errors.

capabilityDiscussion

At a minimum, notification means an error message, a log entry, and a "failed" result on this portion 

of the L&A test.

1.1.2-F – Test ballots

The voting system must allow for EOs to submit test ballots for use in verifying the integrity 

of the system.

1.1.2-G – TestD – Testing all ballot positions

ScannersVote-capture devices must allow for testing that uses all potential ballot positions in 

the election as active positions.

1.1.2-H – Test Cast Vote RecordsE – Testing cast vote record creation

The voting system must include the ability to verify that cast vote records (CVRs) are created 

and tabulated correctly by permitting EOselection officials to compare the created CVRs with 

the test ballots. 

Discussion

This requires providing a capability such as an export of CVRs and a tabulated summary that can be 

compared manually against their test ballot counterparts. 

1.1.2-I – TestF – Testing codes and imagesimage creation

The voting system must include the abilitycapability to verify that any encoded 

versionversions or images of voter selections on a ballot and any other encoded information 
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on a ballot are created correctly. by permitting election officials to compare the encodings 

and images with the test ballots.

Discussion

DiscussionThe purpose of this requirement is to ensure that an encoded versiongive election officials

the capability, prior to opening the polls, to audit encoded versions of voter selections. This process

may include the review of created ballots and encoded information on each ballot to ensure that the 

images correctly match the ballot, thus validating accuracy in ballot creation. and that the ballot was 

created accurately. will include such as provided by a ballot marking device (BMD) using QR codes 

and gain assurance that the QR codes and any encoded data represented by the QR codes contains 

the voter’s selections exactly as made. It will also ensure that Likewise, to audit any image of the 

ballot made by a scanner to gain assurance that the image correctly matches the ballot. BMDs may 

encode other items as appropriate in codes, for example, ballot style IDAnd, to audit any encoded 

information on the ballot to gain assurance it is being created correctly.

Related requirement: 1.1.2-JC – Use of test ballots

1.1.2-G – Testing equipment calibration

Scanners must support the use of test ballots to testtesting the calibration of the paper-todigital conversion (such as the calibration of optical sensors, the density threshold, and the 

logical reduction of scanned images to binary values, as applicable).

1.1.2-K – Ballot marker readiness

Ballot marking must allow for a way to verify that the ballot marking mechanism is properly 

prepared and ready to use.

1.1.2-L – L&A testing,H – No side-effects from pre-election testing

Logic and accuracy Pre-election testing functions must introduce no lasting effects on in 

regard to the operation of the voting system during the election other than:

1. audit log entries;

2. status changes to note that the tests have been run with a successful or failed result;

3. separate storage of test results;

1. changes in the protective counter or life-cycle counter (if the device has one)

4. changes in counters that record ballots cast; and

4.5. normal wear and tear.

Discussion
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Requirements for VVSG 2.0 February 29, 202010, 2021

Discussion

Subsequent requirements preclude the device from actually serving in the election unless these tests 

are successful. Apart from that safeguard, It should be impossible (by design) for the L&Apre-election

testing to have any influence on the operation of the device(s) during the election or on the results 

that are reported for the election. Most notably, election results can never include any test votes that 

were counted during L&A testingpre-election testing. If a test election is run on the voting system as 

a means of providing pre-election testing, an election official should be able to remove all artifacts of 

the test election except as noted in items 1 through 5 of this requirement.

1.1.2-M –I – Equipment status and readiness reports

The voting system must provide the capability to produce status and equipment readiness 

reports. that show the readiness of the equipment, including: 

Discussion

These reports typically are generated during pre-voting logic and accuracy testing.

1. 1.1.2-N – Pre-whether calibration is needed;

2. consumable supplies such as toner or paper are sufficient for use;

3. batteries are fully charged; and

4. the status of other election-sensitive aspects of the equipment.

1.1.2-J – Ballot style readiness reports

The voting system must provide the capability to produce a reportpre-election reports that 

includesinclude:

1. the allowable number of votes in each contest;

1. The counting logic (for example, N-of-M, cumulative, or ranked choice) that is used 

for each contest

2. the tabulation method for each contest; 

2.3. the inclusion or exclusion of contestscontests as the result of precinct splits; and

2. Any other characteristics that may be peculiar to the jurisdiction, the election, or the 

precincts

3. Manual data maintained by election personnel

3.4. samples of all final ballot stylesballot styles.

4. Ballot preparation edit listings
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Discussion

The purpose of this requirement is for sanity checks of the election configuration. Previous 

requirements mandate support for the NIST 1500-100 CDF specification.

External reference: NIST 1500-100 CDF specification

1.1.2-O – K – Precinct-based voting devices readiness reports for each polling 

place

Precinct-based voting devices must have the capability of generating readiness reports must 

include at least the following information for each polling place:that include:

1. the election's identification data;

2. the identification of the precinct and polling place; and

1. The identification of all voting devices deployed in the precinct

3. the identification of all ballot stylesballot styles used in that precinct.

1.1.2-L – All vote-capture devices readiness reports

Vote-capture devices must have to capability to generate a report that includes the 

following:

1. the election's identification data;

2. the identification of the precinct and polling place, if applicable;

3. the identification of the device;

4. the identification of all ballot styles loaded;

5. the contents of each active contest option register at all storage locations;

1.6. confirmation that no hardware or software failures were detected during setup and 

testing, or a record of those that occurred; and

2. Confirmation that all vote-capture devices are ready for the opening of polls, or 

identification of those that are not

1.1.2-P – Readiness reports, precinct tabulation

Readiness reports must include the following information for each voter-facing scanner or 

other precinct reporting device:

1. The election's identification data
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2. The identification of the precinct and polling place

3. The identification of the voter-facing scanner

4. The contents of each active contest option register at all storage locations

5. Confirmation that no hardware or software failures were detected during setup and 

testing, or a record of those that occurred

2.7. any other information needed to confirm the readiness of the equipment and to 

accommodate administrative reporting requirements.

1.1.2-Q – Readiness reports, central tabulation

Readiness reports must include the following information for each batch-fed scanner or 

other central reporting device: 

1. The election's identification data

2. The identification of the tabulator

3. The identification of all ballot styles used in the system extent

4. The contents of each active contest option register at all storage locations

5. Confirmation that no hardware or software failures were detected during setup and 

testing, or a record of those that occurred

6. Any other information needed to confirm the readiness of the equipment and to 

accommodate administrative reporting requirements

1.1.2-R – Readiness reports, public network test ballots

Systems that send ballots over a public network must provide a report of test ballots that 

includes:

1. the number of test ballots sent

2. when each test ballot was sent

3. the identity of the machine from which each test ballot was sent

4. the specific votes contained in the test ballots
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1.1.3 – Opening the polls

1.1.3-A – Opening the polls 

The voting system must provide functions to enter and exit a mode in which voting is 

permitted. 

Discussion

Discussion

This and following requirements cover the process of enabling voting to occur by placing the voting 

system in a voting mode. More information about the activated stage is defined in Table 11-1.

1.1.3-B – Verify L&A performedNon-zero totals

The voting system must provide internal test or diagnostic capabilities to verify that the 

applicable tests specified in the equipment setup requirements have been successfully 

completed.

Discussion

When an L&A test is conducted, that test will indicate whether any aspects of the test were 

successful or failed. 

1.1.3-C – Prevent opening the polls

The voting system must not enter the voting mode unless and until the readiness test has 

been performed successfully and anyall steps necessary to isolate test data from election 

data have been performed successfully.

Discussion

If a device has not been tested, has failed its L&A test, or the test data have not been isolated (that is, 

test votes could end up being included in election results), then the device is not ready for use in the 

election.

1.1.3-D – Non-zero totals

Tabulation must not enter the voting mode unless and until the L& A test has been 

performed successfully, any steps necessary to isolate test data from election data have 

been performed successfully, and all vote counters have been zeroed. An attempt to open 

polls with non-zero totalscounters:

1. must be recorded in the audit log, and
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2. an EOelection worker must be clearly notified of the event.

Discussion

Jurisdictions that allow early voting before the traditional election day should notedocument that a 

distinction is made between the opening and closureclosing of the polls, which. This can occur only 

once per election, and the suspension and resumptioncontinuance of voting between days of early 

voting. The open-polls operation, which requires zeroed counters, is performed only when early 

voting commences; the resumptioncontinuation of voting that was suspended overnight does not 

require that counters be zeroed again.

1.1.3-E – Scanners and ballot marking devices - verify activation

Scanners and ballot marking devices must include a means of verifying that they have been 

correctly activated and are functioning properly.

1.1.3-F – Scanners and ballot marking devices - enter voting mode

Scanners and ballot marking devices must provide designated functions for entering voting 

mode. They must include:

1. access control to prevent the inadvertent or unauthorized activation of the pollopening function.

2. a means of enforcing the execution of poll-opening steps in the proper sequence if 

more than one step is required.

a means of verifying that the system has been correctly activated.

1.1.4 - Ballot ActivationCasting

This section deals with functions needed to activate the ballot for a voter. If ballot activation 

occurs on an electronic pollbook, one cannot test and verify whether these requirements are 

satisfied unless the entire pollbook is also tested.

This section describes the requirements of the ballot issued to the voter and the types of 

contests that appear on the ballot. This includes characteristics that the voter must be aware 

of in order to accurately reflect the intent of their choices and the requirements of the voting 

system when the ballot is cast. 

1.1.4-A – Ballot activationVoting and casting the ballot

The voting system must support ballot activation.
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1.1.4-B – One cast ballot per session

provide a ballot to each voter containing contests and contest choices using all voting 

variations that are indicated in the voting system must enable election workers either to 

initiate or to provide the voter with the credentials sufficient to initiate a voting session in 

which the voter may cast or print at most one ballotimplementation statement.

Discussion

A voting session on a BMD may end with the printing of the voter’s contest selections, that is, 

scanning contest selections need not be considered part of the voting session.

1.1.4-C – Contemporaneous record

The voting system must create contemporaneous records of the credentials issued to a 

voter. The record, once made, will not be able to be modified by the voting system.

Discussion

The voting system creates a record at the time when credentials are issued to voters so that the 

records collected can be compared to the number of ballots voted. This may be done if the activation 

device prints a record or by using a paper pollbook.

1.1.4-DB – Control ballot configuration

The voting system must enable election workers to control the ballot configurations made 

available to the voter, whether presented in printed form or electronic display, so that each 

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

The voting system must:

The voting system must, where applicable:

1. activate all portions of the ballot the voter is entitled to vote on.;

2. disable all portions of the ballot the voter is not entitled to vote on.; and 

3. enable the selection of the ballot configuration that is appropriate to the party 

affiliation declared by the voter in a primary election.

Discussion

This requirement does not apply to pre-printed paper ballots. For on-demand ballot printing 

systems, item 3 requires that the proper ballot style be selected for the voter and the appropriate 

ballot be printed for the voter’s use. For an electronic display, or ballot marking device, items 1-3 

would be required, where poll workers may control the ballot configuration by using an activation 

device and, issuing a token, or following other jurisdictional procedures to select the appropriate 

ballot style. 
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1.1.4-C – Precinct splits, Casting

Each ballot that is issued to a voter must include contests that are associated with a district 

that the voter’s residential address falls within. 

Discussion

If a precinct is not entirely contained in the district associated with the precinct, multiple ballot styles 

must be available to ensure that each voter in the precinct receives a ballot that only contains 

contests for which they are eligible to vote.

1.1.4-D – Ballot rotation, Casting

The order of contest options listed on each ballot must be in the order prescribed. The voting 

system must be able to correctly associate a voter’s choice with the associated contest 

choice independent of where it appears on a specific voter’s ballot.

Discussion

credentials. In paper-Many states require contest choice position order to be rotated on different 

ballots to prevent bias for or against a choice based on position listed.

1.1.4-E – Partisan closed primary ballot

The voting system must provide a type of ballot, used in a partisan primary election. to the 

voter that only contains contests associated with a specific party to which the voter is 

registered in addition to any nonpartisan contests that the voter is eligible to make choices. 

Discussion

systems, This type of ballot is used in states that run closed primary elections (voter is issued a ballot 

based on party of registration), partially closed primary elections (voter can receive a party-specific 

ballot that is different from their registration or an unaffiliated voter can choose a party ballot) and 

partially open primaries have sometimes been handledprimary elections (voters do not register by 

printingparty and choose a singleparty-specific ballot stylefor the election). 

1.1.4-F – Partisan open primary ballot

The voting system must provide a type of ballot, used in a partisan primary election, to the 

voter that merges thecontains partisan contests from all parties, instructing the voter to vote 

only in the contests applicable to a single party, and rejecting or discarding votes that violate 

this instruction. To use that approach on a paper-based BMD would violate this requirement.

and any nonpartisan contests in which the voter is eligible to make choices. Only choices 

associated with one party will be permitted.

Discussion
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1.1.5 - Casting

1.1.5-A – Voting methods when casting

This type of ballot is used in states that run open primary elections, where voters do not register by 

party but choose the party for which they wish to vote. 

1.1.4-G – Indicate party affiliations and endorsements 

The voting system must record provide a type of ballot associated with:

1. a partisan primary election that identifies the party associated with each listed 

primary election contest (all individuallisted contest options for each contest using all 

voting methods indicated for them in the implementation statement.are affiliated 

with the listed party); and

2. a partisan general election that identifies the affiliated/endorsing party of each 

contest choice.

1.1.4-H – Write-in contest options

The voting system must be capable of enabling and recording the voter's write-in of desired 

candidate names. 

Discussion

A write-in is a contest option on the ballot that permits the voter to identify a candidate of choice 

that is not already listed as a contest option and is captured when the ballot is cast. State rules 

determine when a write-in candidate option may be placed as a contest option on the ballot and 

what qualifies as a valid write-in selection that may be counted.

1.1.4-I – Write-in reconciliation

Discussion

This requirement and its sub-requirements deal with general support for casting ballots using the 

most common voting methods used in the United States. (Voting methods are otherwise known as 

voting variations.) When a ballot is cast, the voting system will create an electronic record of the 

voter’s selections, that is, a cast vote record. The cast vote record need not include those contest 

options not selected by the voter; their absence in the cast vote record indicates their non-selection.
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1.1.5-B – N-of-M voting

For the N-of-M voting method, The voting system must be capable of gathering and 

recording votes in contests where the voter is allowed to choose up to a specified number of 

contests from a list of contest options.

1.1.5-C – Yes/no measures and multiple-choice measures

For ballot measures, the voting system must be capable of gathering and recording votes in 

contests where the voter is allowed to:

1. vote yes or no on a measure

2. vote for selections from a list of choices

1.1.5-D – Indicate party affiliations and endorsements

The voting system must be capable of indicating the affiliation or endorsements of each 

contest option.

1.1.5-E – Closed primaries

For closed primaries, the voting system must be capable of gathering and recording votes 

within a voting process that:

1. assigns different ballot styles depending on the registered political party affiliation of 

the voter

2. supports both party-specific and non-party-specific contests

1.1.5-F – Open primaries

For open primaries, the voting system must be capable of gathering and recording votes 

within a voting process that assigns different ballot styles depending on the political party 

chosen by the voter at the time of voting and supports both party-specific and non-partyspecific contests.

Discussion

In paper-based systems, open primaries have sometimes been handled by printing a single ballot 

style that merges the contests from all parties, instructing the voter to vote only in the contests 

applicable to a single party, and rejecting or discarding votes that violate this instruction. 
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1.1.5-G – Write-ins

The voting system must record the voter's write-in of candidates whose names do not 

appear on the ballot and record as many write-in votes as the voter is allowed. 

1.1.5-H – Write-in reconciliation

The voting system must be capable of gathering and recordingwrite-in votes within a voting 

process that allows for reconciliation of aliases and double votes resulting from write-ins..

Discussion

Reconciliation of aliases means allowing EOselection officials to declare two different spellings of a 

candidate's name to be equivalent (or not), as could happen from write-ins.). Reconciliation of 

double votes means handling the case where, in an N-of-M contest, a voter has attempted to cast 

multiple votes for the same candidate using the write-in mechanism.

1.1.5-I – Ballot rotation for4-J – N-of-M contest options, Casting

For ballot rotationthe N-of-M contest, the voting system must be capable of gathering and 

recording votes in a contest where the voter may choose up to a specified number of choices 

from a list of contest options. These selections are independent of selections in any other 

contest. 

Discussion

when the ordering ofA baseline N-of-M contest is one where a voter is allowed N contest choices 

from a list of M choices and where votes are tallied independently of any other contest options in 

ballot positions within each contest is variable in such a manner that does not show bias to any 

contest optionon the ballot. N includes 1 (vote for 1 contest or typically a measure) or any larger 

number. If N is larger than M, all choices listed will be selected. It can be used for approval voting by 

setting N equal to M. It can also be used for limited voting by setting N to be less than the number of 

seats being elected. 

Discussion

The intent is to ensure that the manner in which the rotation algorithm works does not show bias 

towards any candidate, that is, all contest options appear equally in rotated positions to the extent 

possible. 

1.1.5-J4-K – Straight-party voting, Casting 

For straight-party voting, the voting system must be able to provide a contest in which a 

voter may select political party contest choices that result in the selection of all partisan 

contests on their ballot. In this instance, a selection of a political party choice automatically 
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selects all contest choices associated with that party. The voting system must be capable of 

gathering and recording votes for a specialboth this contest and all partisan contests 

associated with it. 

Discussion

Straight-party voting is a voting variation used in whicha general election. It provides the voter with 

the ability to select all candidates affiliated with a desired party in all partisan contests on the ballot 

by selecting one contest option. When a party is selected, the system must not prevent the selection 

of a political party implies votes for the contest individual candidate options endorsed by that party 

in all may negate the original straight-party contests on the ballot.choice, nor must it require that 

voters utilize the straight-party voting option. Rules for determining the candidate choices resulting 

from the combination of direct option selections and straight-party option selections are determined 

by the rules in states that use straight-party voting. 

1.1.5-K – Cross-party endorsement

1.1.4-L – Cumulative voting contest, Casting

For cross-party endorsementa cumulative voting contest, the voting system must be capable 

of gathering and recording straight-party votes when a given contest option is endorsed by 

twoin a contest where the voter may allocate no more than the allowed number of votes to 

one or more different political partiescontest selections in whole vote increments.

Discussion

1.1.5-L – Precinct splits

When a cumulative voting contest is on a ballot, the system must allow the voter to assign all allowed 

votes to any desired contest selection or to any set of contest selections in whole vote increments. 

The total of all selection assignments must not exceed the total votes allowed. (See 1.1.4-Q -

Proportional voting contest (equal-and-even cumulative voting contest), Casting for an alternate 

method of assigning multiple votes to a candidate.)

1.1.4-M – Ranked choice voting contest, Casting 

For a ranked choice voting (RCV) contest, the voting system must be capable of gathering 

and recording votes in a polling place where there are distinct ballot styles for voters from 

two or more political geographies.contest where the voter must be able to rank contest 

selections in order of preference, as first choice, second choice, etc. 

Discussion
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1.1.5-M – Cumulative voting

The ballot presentation of a RCV contest is independent of the number of seats being elected. 

Depending on jurisdictional rules, the number of choice options provided may vary from a minimum 

of 3 to the number of contest choices on the ballot. Contest outcome determination requires cast 

vote records (CVR) to be processed post-election.

1.1.4-N – Party preference contest

For cumulative votinga party preference contest, the voting system must be capable of 

gathering and recording votes in contests where the voter is allowed to allocate up to a 

specified number of votes over a list of contest options, possibly giving more than one vote 

to a given contest option. for a contest containing a list of political party choices. In this 

instance, the voting system uses a valid selection of a party in the contest, which limits

gathering and recording of votes in all partisan contests on the ballot to those associated 

with the selected party.

Discussion

1.1.5-N – Ranked choice voting

A party preference contest only appears on an open primary ballot when required by state rules. Its 

purpose is to allow the voter to select the party they intend to vote contests for and prevent the 

voter from spoiling the partisan section of the ballot by, for example, marking contests in a different 

party’s section of the ballot. 

1.1.4-O – Top-2 primary contest (blanket primary contest)

For ranked choice votinga top-2 primary contest, the voting system must be capable of 

gathering and recording votes in contests where the voter is allowed to rank contest options 

in a contest in order of preference, as first choice, second choice, etc.

1.1.5-O – Recallableassigning candidates of all relevant parties to a single seat contest which 

is also assigned to all partisan ballots.

See Section 10.2.1 for requirements to identify recallable ballots. 

Discussion

Discussion

Recallable ballots that are scanned and for which a CVRs have been created, cannot be recalled 

without being able to remove a ballot’s corresponding CVR. Thus, there is a need to know the voter, 

the voter’s ballot, and the corresponding CVR. This presents a potential voter privacy issue. See 

Section 10.2.1 for requirements that deal with this issue.
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In some states, this method is required to be used to fill designated partisan offices. The contest, 

also called a blanket primary contest, appears on all party-specific primary ballots. All candidates are 

listed as contest options including their party affiliation. The 2 candidates who receive the most votes 

will be on the general election ballot independent of their party affiliation. 

1.1.54-P – Review-required ballotsPresidential delegate contest, Casting

For a presidential delegate contest, the voting system must be capable of gathering and 

recording votes within a voting process that requires certain ballots to be flagged or 

separated for reviewfor only those delegates that are affiliated with the voter’s choice in the 

presidential preference contest.

Discussion 

Presidential delegate voting is a voting variation that only is used in a presidential primary election on 

a party-specific primary ballot where delegates to the convention are selected by the voter when the 

method is selected by a state’s political party. With this method, only contest option selections in 

delegate contests that are pledged to the voter’s presidential candidate selection will be recorded. If 

the voter does not make a selection in the presidential preference contest, selections for presidential 

delegates will not be recorded.

1.1.4-Q – Proportional voting contest (equal-and-even cumulative voting 

contest), Casting

For a proportional voting contest, the voting system must be capable of gathering and 

recording votes for a contest which allow multiple votes to be assigned to a candidate. This is 

accomplished by prorating the number of allowed votes proportionally to the number of 

validly selected candidates.

Discussion

Discussion

Also known as equal-and-even cumulative voting, this contest is an alternative to a cumulative voting 

contest in allowing multiple votes to be assigned to selected candidates. Votes are assigned based 

on the votes allowed and the number of valid selections made by dividing the number of votes 

allowed by the number of options chosen. Marking fewer selections than the number of votes 

allowed may result in fractional votes being assigned to a contest option. 
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1.1.4-R – Group voting contest, Casting

For a group voting contest, the voting system must be capable of designating a group select 

contest choice that automatically selects, gathers and records all contest choices associated 

with the group. More than one contest group select contest choice must be provided if the 

contest contains more than one group of candidates.

Discussion 

A group voting contest is used to enable the voter to select a large number of allowed candidate 

options associated with a single group, party or ideology with a single option selection. There may be 

multiple groups of contest choices each associated with a single selection. The system treats a group 

selection as if all candidates in the group are selected when determining the number of selections 

made. This voting variation is currently only used in the State of Massachusetts to select Ward and 

Town party committee persons and only appears on the ballot in the presidential preference primary. 

1.1.4-S – Top-2 IRV contest (supplementary or contingent vote contest)

For a top-2 instant runoff voting (IRV) contest, the voting system must be capable of 

gathering and recording votes in a contest where the voter must be able to rank contest 

options in order of preference as their first choice, second choice, etc. 

Discussion

In some systems and jurisdictions, all ballots containing write-in votes require flagging or separation 

for review. Support for this indicates that the system can flag or separate ballots in this manner and 

include the results of the review in the reported totals. Other reasons for which ballots are flagged or 

separated are jurisdiction-dependent. 

The top-2 IRV contest, also known as a supplementary or contingent vote contest, is an IRV type 

contest and provides the voter the ability to identify the contest options in order of preference in the 

same fashion as a standard IRV contest. Although voted the same as an IRV contest and requiring 

cast vote records to be processed post-election to determine outcome, only the top-2 candidates 

with the most votes are eligible to win. 

 

1.1.5

1.1.6 – Recording voter choices

1.1.65-A – Casting and recording

All systemsThe voting system must support casting a ballot and, recording each vote 

precisely as indicated by the voter, subject to the rules of the election jurisdiction, and 

creating a cast vote record that can be tabulated and audited.
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1.1.65-B – Secure ballot boxes

Voting systems that include paper ballots must include secure receptacles for holding cast 

ballots.

1.1.6-C – Prevent counter overflow

When the voting system can no longer accept another ballot without the potential of 

overflowing a vote counter or otherwise compromising the integrity of the counts, it must 

notify the user or operator and cease to accept new ballots.

Discussion

Assuming that the counter size is large enough that the value will never be reached is not an 

adequate safeguard. Systems are required to detect and prevent an impending overflow condition. 

This requirement is in response to past issues in which devices would use up available memory but 

give no warning and continue to permit voters to cast ballots.

1.1.6-D – Ballot orientation

Ballot marking devices that useThe voting system, when using pre-printed ballots, must 

either:

1. correctly mark pre-printed ballots regardless whether they are loaded upside down, 

right side up, forward, or reversed; or

2. detect and reject pre-printed ballots that are oriented incorrectly.

1.1.6-E – Records consistent with feedback to voter

All CVRs and logs must be consistent with the feedback they give to the voter.

1.1.5-CDiscussion

This does not mean that every message displayed to the voter during an interactive session will be 

included in every CVR or log. It means that the records and the interactive messages will not be in 

conflict with one another. For example, it is not permissible to show a vote for candidate X on the 

display, and then record a vote for candidate Y.

1.1.6-F – Record contest selection information

The voting system must record contest selection information in the CVR that includes:

1. all contest selections made by the voter for all supported vote variations; and
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2. positions on the ballot associated with each contest selection made by the voter, 

including when multiple selections are permitted, if applicable.

Discussion

For item 2, some contests such as for RCV may place candidate choices on the same line of the ballot, 

therefore the positions of the candidates may need to be recorded.

1.1.6-G5-D – Record write-in information

The voting system must record write-in information in the CVR that includes:

1. identification of write-in selections made by the voter;

2. the text of the write-in, when using a BMD or other device that marks the ballot for 

the voter;

1. an image or other indication of the voter’s write-in markings

3. an indication whether the write-in has been adjudicated; and constitutes a 

tabulatable vote

4. the total number of write-ins in the CVR.

1.1.6-H5-E – Record election and contest information

The voting system must record additional contest information in the CVR that includes:

1. identification of all contests in which a voter has made a contest selection;

1. identification of the contest vote method including number of votes allowed in the 

contest and the maximum number of valid contest selections

2. identification of all overvoted and undervoted contests;

3. the number of write-ins recorded for the contest; and

4. identification of the party for partisan ballots or partisan contests.

Discussion

Discussion

For identification of the party, a ballot in a partisan primary election may in some cases contain 

contests for different parties. Thus, an indication as to whetherpartisanship of the contest is 

partisancontests is required.
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1.1.6-I5-F – Record ballot selection override information

ScannersThe voting system, if tabulatingrecording voter selections differently than as 

marked due to election or contest rules in effect, must record information in the CVR that 

includes:

1. identification of the original ballot selections made by the voter;

2. identification of the changed voter selections; and

3. identification of the reasons for the changes.

Discussion

When marking a ballot by hand, a voter may vote in contests in which the voter is not allowed to 

make contest selections. For example, a voter may elect to vote straight-party, but then make 

contest selections in contests anywaywhich differ from the political party contest choices. Election or 

contest rules may cause a scanner to invalidate the contest markings or require other actions. 

1.1.6-J – Record detected mark information

Scanners must record, for each mark detected on the ballot, information in the CVR that 

includes:

1. indications of marginal marks that are made by the voter or that are due to 

imperfections on the ballot

2. mark quality information for each detected mark

1.1.5-GDiscussion

This applies to contest selections recognized as valid as well as to marginal marks or other detected 

facets of contest selection positions that are detected by the scanner. For example, a crease in the 

ballot may be detected by the scanner as a marginal mark. The measurement of mark quality may be 

specific to manufacturer and model of scanner.

1.1.6-K – Record audit information

The voting system must be capable of recording audit-related information in the CVR or 

collection of CVRs as they are created, that includes:

1. identification of the specific creating device such as a serial number;

2. identification of the geographical location of the device;

3. identification of the ballot style corresponding to the CVR;

4. identification of the corresponding voted ballot;
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5. for multi-sheet ballots, identification of the individual sheet corresponding to the 

CVR, along with the identification of the ballot style;

6. identification of the batch containing the corresponding voted ballot, when 

applicable; and

7. sequence of the corresponding voted ballot in the batch, when applicable.

Discussion

Item 2 can be any identification scheme that is preferential in the jurisdiction, e.g., polling place 

name, address, geographical coordinates, etc.

Item 4 can be satisfied by printing a unique ID on the ballot as it is scanned and including that ID in 

the corresponding CVR. 

Item 5 ensures that every sheet of a multi-sheet ballot contains the sheet number as well as the 

ballot style ID. This way, a ballot style ID could be defined to include all sheets, or each sheet could be 

defined with a unique ballot style. 

Items 6 and 7 are necessary when ballot batching is in effect. 

1.1.5-H – Store and link corresponding image

The voting system must be capable of storing an image of a paper ballot and linking this 

image to the specific associated CVR.

Discussion

The image could be linked to the CVR by, for example, creating a filename for the image that is the 

same as the identifier from item 4 in Requirement 1.1.5-G – Record audit information.

1.1.67 – Ballot handling for paper ballot scannersvote-capture devices

1.1.76-A – Ballot handling functions for scanners

Scanners must provide features for handling ballots when they are scanned individually using 

voter-facing scanners or scanned in batches using batch-fed scanners.

1.1.7-B – Detect and prevent ballot style mismatches

AllThe voting systemssystem must detect ballot style mismatches and prevent votes from 

being tabulated or reported incorrectly due to a mismatch.

Discussion
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For example, if the ballot stylesballot styles loaded on a scanner disagree with the ballot stylesballot 

styles that were used by vote-capture devices,vote-capture devices, the system will raise an alarm 

and prevent the incorrect ballot stylesballot styles from being used during tabulation. Otherwise, 

votes could be ascribedcredited to the wrong contest options.contest options.

Such a mismatch should have been detected and prevented induring L&A testing but if it was not, it 

needs to be detected and prevented before tabulation begins.

1.1.7-C6-B – Detect and reject ballots that are oriented incorrectly

Scanners must do one of the following:

The voting system must either:

1. correctly count ballots regardless of whether they are fed upside down, right side up, 

forward, or reversed; or

2. detect and reject ballots that are oriented incorrectly.

1.1.7-D6-C – Ballot separation when batch feeding

Batch-fed scanners, in response to unreadable ballots, write-ins, and other designated 

conditions, batch-fed scanners must do one of the following:

1. out stack the ballot (that is, divert to a stack separate from the ballots that were 

normally processed));

2. stop the ballot reader and display a message prompting the EOelection official to 

remove the ballot;

3. mark the ballot with an identifying mark to facilitate its later identification; and/or

4. if the ballot image uniquely identifies its corresponding ballot, use electronic 

adjudication to segregate the ballot.

Discussion

Item 4 allows the ballot image to be segregated if, for example, an identifier is printed on the ballot 

as it is scanned, so that the image of the ballot also contains this identifier. Without a unique 

identifier or other marking, the ballot image itself does not facilitate finding the corresponding paper 

ballot.
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1.1.6-D – Overvotes, undervotes, blank ballots 

Voter-facing scanners must provide a function that can be activated by election officials to 

stop the scanning process and display a message which will enable the removal and 

correction of the ballot in response to the following ballot conditions:

1. ballots containing overvotes in a designated contest;

2. ballots containing undervotes in a designated contest; 

3. ballots containing contests that were not voted; and

4. blank ballots.

Related requirements: 7.3-H – Overvotes

7.3-I – Undervotes

1.1.6-E – Write-ins, Ballot handling for vote-capture devices

Voter-facing scanners, when scanning a ballot containing a write-in vote, must either:

1. segregate the ballot in a manner that facilitate its later identification; or

2. if the ballot image uniquely identifies its corresponding ballot, use electronic 

adjudication to segregate the ballot.

Discussion

The requirement to separate ballots containing write-in votes is not applicable into systems in which 

a BMD encodes write-in votes in a machine-readable form. In this instance, and a scanner generates 

individual tallies for all written-in candidates automatically. Separation of ballots containing write-in

votes is only necessary in systems that require the allocation of write-in votes to specific candidates 

to be performed manually.

1.1.7-E – Overvotes, undervotes, blank ballots 

Voter-facing scanners must provide a capability that can be activated by EOs to stop the 

scanning and display a message to the EO to remove and correct the ballot in response to 

the following ballot conditions:

1. ballots containing overvotes in a designated contest

2. ballots containing undervotes in a designated contest

3. ballots containing contests that were not voted

4. blank ballots
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1.1.76-F – Write-ins

1. When scanning a ballot containing a write-in vote, voter-facing scanners must 

segregate the ballot in a manner that facilitate its later identification.

Discussion

The requirement to separate ballots containing write-in votes is not applicable in systems in which a 

BMD encodes write-in votes in machine-readable form and a scanner generates individual tallies for 

all written-in candidates automatically. Separation of ballots containing write-in votes is only 

necessary in systems that require the allocation of write-in votes to specific candidates to be 

performed manually. 

1.1.7-G – Ability to clear misfeedmis-fed ballots

If multiple feed or misfeedmisfeeding (jamming) occurs, a batch-fed scannerscanners must: 

1. halt in a manner that permitspermit the operator to remove the ballots causing the 

error and reinsert them in the input hopper (if unread) or insert them in the ballot 

box (if read)); and

2. indicate whether or notprevent duplicate scanning of the ballots causing the error 

has been read.

Discussion 

The second bulletNumber 2 deals with whether a CVR hasCVRs have been created for the ballots that

were jammed; EOs needs to know whether to re-feed the ballot.

1.1.7-H6-G – Scan to manufacturer specifications

Scanners must detect marks made on paper ballots according to non-proprietary, published 

manufacturer specifications.

The voting system must have the capability to provide a report of the mark detection 

thresholds that have been used to program the scanner so that the information is available 

upon request.

Discussion

Manufacturers will publish their specifications for detecting marks, and these specifications will be 

publicly available. Because voters may make any number of mistakes when marking a ballot, canners 

need to interpret the marks according to these published specifications as well as possible. 

Requirements in the Casting section require the manufacturer to include, in the CVR, an indication of 

mark quality for each detected mark. 
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1.1.7-I – Ignore unmarked contest option positions

Scanners must ignore (that is, not record as votes) unmarked contest option positions.

Discussion

"Unmarked" in this requirement means containing no marks of any kind other than those designed to 

be present as part of the ballot style. This includes extraneous perforations, smudges, folds, and 

blemishes in the ballot stock. 

1.1.7-J – Accurately detect perfect marks

Scanners must detect marks that conform to manufacturer specifications.

1.1.7-KManufacturers must not make their specifications proprietary; auditors must be able to 

understand what and what does not constitute a valid voter mark on a particular scanner. 

1.1.6-H – Accurately detect imperfect marks

ScannersThe voting system must detect a 1 mm thick line that:

1. is made with a #2 pencil that crosses the entirety of the contest option position on its 

long axis,;

2. is centered on the contest option position; and

3. is as dark as can practically be made with a #2 pencil.

Discussion

Different optical scanning technologies will register imperfect marks in different ways. Variables 

include:

• the size, shape, orientation, and darkness of the mark;

• the size, shape, orientation, and darkness of the mark;

• the location of the mark within the voting target;

• the wavelength of light used by the scanner;

• the size and shape of the scanner's aperture;

• the color of the ink;

• the sensed background-white and maximum-dark levels; and, 

• the calibration of the scanner.
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The mark specified in this requirement is intended to be less than 100 % perfect, but reliably 

detectable, that is, not so marginal as to bring the uncontrolled variables to the forefront.. In plain 

language: scanning technologies may vary, but as a minimum requirement, all of them should be 

capable of reliably reading this mark.

1.1.7-L – Ignore extraneous marks outside contest option position 

Scanners must not record as votes any marks, perforations, smudges, or folds appearing 

outside the boundaries of contest option positions.

1.1.7-M6-I – Ignore extraneous marks inside voting targets

Scanners must not record as votesThe voting system must include a capability to recognize

any imperfections in the ballot stock, folds, and similar insignificant marks appearing inside 

the voting targets and not record them as votes.

Discussion

Insignificant marks appearing inside of the voting targets cancould be detected as votes., thus the

capability to recognize the ballot folds or imperfections must be included as a part of the voting 

system. It may not be possible to completely eliminate this problem should be minimized.

1.1.7-N – Ignore hesitationin all cases depending on scanner thresholds for detecting marks.

Scanners must not record hesitation marks and similar insignificant marks as votes.

Discussion

It may be possible to reliably detect reasonable marks and reliably ignore hesitation and other 

insignificant marks if the scanner is calibrated to a specific marking utensil or, when an image is made 

of the ballot, analysis of the image. 

Related requirements: 1.1.6-G – Scan to manufacturer specifications

1.1.7-O6-J – Marginal marks, nowithout bias

The detection of marginal marks from manually-marked paper ballots must not show a bias.

The detection of marginal marks from manually marked paper ballots must not show a bias.

Discussion

Bias errors are not permissible in any system. An example of bias would be if marginal marksmarginal 

marks in the first ballot position were detected differently than marginal marks in the second ballot 

position.

Field Code Changed
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1.1.7-P6-K – Repeatability

The determination of a vote on a manually marked paper ballot must be repeatable, such 

that it never changes from a vote to a non-vote or from non-vote to a vote.

Discussion

The detection of marginal marks from manually-marked paper ballots must be repeatable.

Discussion

It is difficult to have confidence in the equipment if consecutive readings of the same ballots on the 

same equipment yield dramatically different results. However,Since it is technically impossible to 

achieve repeatable readingreadings of ballots containing marks that fall precisely on the 

sensingscanning threshold. , changing between a non-vote and a marginally machine-readable mark 

is allowed. Similarly, changing from a valid vote and a marginally machine-readable mark is allowed.

1.1.8 – Closing the Polls

1.1.7 – Exiting or suspending voting

1.1.87-A – Closing the pollsExiting or suspending election mode

The voting system must provide designated functions for exiting or suspending an election 

mode and stoppingin which voting is permitted.

Discussion

Discussion

When voting is conducted across multiple days, for example, forduring early voting, these 

requirements are still applicable even though the election itself may not be over,; this is with the 

exception of requirement 1.1.87-E – Prevent reopening pollsre-entering election mode, which deals 

with preventing , on election day, re-opening of the polls once they have been closed on election day.

1.1.87-B – No voting when polls are closedvoting is stopped

The voting system must prevent the further enabling, activation, marking, or casting of 

ballots by any device once the polls have closedvoting has stopped.

Discussion

This requirement is applicable to voter-facing scanners, batch-fed scanners and any other device that

enables the activation or tabulation of the voting process. However, Discussiona BMD cannot 
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prevent a voter from marking a paper ballot with a writing utensil after polls have closed. This needs 

to be prevented through proceduresjurisdictional procedure.

1.1.87-C – Poll closingVoting stop integrity check

The voting system must provide an internal test that verifies that the prescribed closing 

procedure hasor suspension procedures have been followed and that the device status is 

normal.

1.1.87-D – Report on poll closingvoting stop process

The voting system must provide a means to produce a diagnostic test record that verifies the 

sequence of events and indicates, which indicate that the poll closing processvoting mode

has been activateddeactivated or suspended.

1.1.87-E – Prevent reopening pollsre-entering election mode

The voting system must prevent reopeningnot be capable of the pollsre-entering an election 

mode, in which voting is permitted, once the poll closing hasprocedures have been 

completed for an election without an explicit override authorized by an administrator.

Discussion

Discussion

ForWhen early voting is conducted across multiple days, this requirement does not prevent 

reopening of the polls on the following day. This requirement is only applicable on the final day of 

election

Related requirements: 11.3.1.-B – Multi-factor authentication for critical 

operations

1.91.8 – Tabulation

1.1.91.8-A – Voting methods when tabulating

Tabulation 

The voting system must support the tabulation function for all voting methodsvariations

indicated in the implementation statement.implantation statement. This function includes:
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1.1.9-B – N-of-M voting

For N-of-M voting, tabulation must be capable of tabulating votes, overvotes, and 

undervotes in contests where the voter is allowed to choose up to a specified number of 

contest options from a list of contest options.

1.1.9-C – Yes/no measure and multiple-choice measure

For yes/no measures and multiple-choice measures, tabulation must be capable of 

tabulating votes, overvotes, and undervotes in contests where the voter is allowed to:

1. vote yes or no on a measure

2. choose from a list of multiple choices on a measure

1.1.9-D – Recallable ballots

For recallable ballots, tabulation must be capable of tabulating votes, overvotes, and 

undervotes in contests where the decision whether to count a particular ballot is deferred 

until after election day.

1.1.9-E – Accept or reject recallable ballots individually

Tabulation must support the independent acceptance and rejection of individual recallable

ballot.

Discussion

1. extracting the valid votes from each ballot cast according to the defined rules;

2. creating and storing a CVR that contains the disposition of each contest selection as 

well as the disposition of each contest choice that is eligible to be cast; and

3. accumulation and aggregation of contest results and ballot statistics.

Discussion

This is meant to rule out the mode of failure in which the IDs assigned to provisional ballots fail to be 

unique, rendering the system incapable of accepting one without also accepting the others with the 

same ID.

1.1.9-F – Accept or reject recallable ballots by category

Tabulation must support the acceptance and rejection of recallable ballots by category.

1.1.9-G –Results accumulation and aggregation takes place at multiple levels within the voting 

system. Each tabulation unit must perform this function and must have the ability to transmit the 
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CVRs and results to the election management system (EMS) for jurisdiction wide accumulation and 

aggregation.

1.1.8-B – Partisan primary elections 

ForIn partisan primary elections, tabulationthe voting system must be capable of 

keepingreporting separate totals for each political party for the number of ballots read and 

the number of ballots counted for each political party. This is independent of whether the 

primary type is closed or open.

Discussion

Discussion

In paper-based systems, open primaries have sometimes been handled by printing a single ballot 

style that merges the contests from all parties and instructing the voter to vote only in the contests

applicable to a single party. This approach requires additional logic in the tabulator to support 

rejecting or discarding votes that violate these special instructions, while the approach of assigning 

different ballot configurations to different parties does not. Support for the merged ballot approach 

is not required for a tabulator.

This requirement to separate by party applies only to the number of read ballots and counted ballots. 

It does not apply to contest option vote totals.

1.1.9-H – Write-ins

For write-ins,From a tabulation perspective, there are two types of partisan primary election ballots. 

A closed primary ballot is one in which a ballot is limited to contests associated with one political 

party and any nonpartisan contests. An open primary ballot is one which contains contests from all 

parties on the same ballot, but the voter may only select contest choices applicable to a single party. 

1.1.8-B.1 – Tabulation of a closed primary ballot

The voting system must support the tabulation of ballots that are specific to a party or are

nonpartisan and must be able to report combined totals for nonpartisan contests no matter 

what party ballot the contest appears on.

1.1.8-B.2 – Tabulation of an open primary ballot

When tabulating ballots from an open primary, the voting system must limit tabulation of 

votes to contests of one political party.

Discussion
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In an open primary, a voter may select partisan contest choices that are associated with more than 

one political party. Therefore, tabulation of a ballot during an open primary will void the partisan 

content of the ballot and only contest selections in nonpartisan contests are tabulated. The ballot is 

treated like a nonpartisan ballot. 

1.1.8-B.3 – Open primary ballot with party preference contest

If the ballot contains a party preference contest and a party preference contest choice is 

selected, the voting system must only tabulate partisan contest option selections from 

contests that are of the same party as is selected in the party preference contest. 

Discussion

A party preference contest provides the voter with the ability to select their intended party and avoid 

cross-party selections voiding the partisan selection of the ballot. If a party preference contest option 

is not selected, partisan contests on the ballot are tabulated as if the party preference contest was 

not present. 

Related requirements: 1.1.4-N – Party preference contest

1.1.8-C – Write-ins, Tabulation

The voting system must be capable of 

1. tabulating votes for write-inwrite-in candidates, with separate totals for each contest

choice, and

1.2. tabulating valid individual write-in candidate totals in each contest.

Discussion 

Tabulation of candidate names that are manually written in on a hand voted paper ballot can only be 

tabulated as an aggregate total in each contest. Each name must be adjudicated from graphical 

images of the contest write-in area or from the ballot itself to determine the name of the candidate. 

When names are typed on an electronic voting unit such as a BMD, although the entered names 

must be recorded, only aggregate contest write-in totals are tabulated. Each individual write-in 

name must be adjudicated for validity before they can be aggregated. In most states, a write-in 

candidate must be registered to be valid. State rules also determine acceptable variations in the 

written name for the candidate to be credited with the vote. State rules also determine treatment of 

a written-in name of a candidate already listed on the ballot.

1.1.8-D – Ballot rotation, Tabulation

When the order of contest choices within a contest varies by ballot style, the voting system

must tabulate votes for each contest selection independent of a contest selections location 

in the contest on the ballot.
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Discussion 

This means that ballot rotation will not impact the correctness of the count.

1.1.8-E – Straight-party voting, Tabulation

When tabulating a partisan general election ballot, which includes a validly selected straightparty contest option in a straight-party contest, the voting system must select each 

candidate contest choice that is endorsed by the selected party in every contest on the ballot 

unless the contest is specifically exempted. 

Discussion1.1.9-I – Support write-in reconciliation

For write-ins, tabulation must be capable of tabulating votes within a voting process that 

allows for reconciliation of aliases and double votes.

There are currently two different tabulation rule sets for handling a ballot with both a straight-party 

selection and a selection in a contest of a candidate not endorsed by the selected party, known as 

party crossover. In one, any selection of a contest choice in a partisan contest eliminates any 

straight-party selection in that contest. In the other, straight-party option selections in a contest are 

eliminated if the number of candidates selected exceeds the allowed number, whether directly 

selected by the voter or automatically selected by the straight-party. Other rules are possible as well. 

Note that some states explicitly indicate that certain contests will not be affected by a straight-party 

selection.

1.1.8-F – Cross-party endorsement with straight-party voting

For straight-party tabulation, if a listed candidate option is endorsed by more than one 

political party, the voting system must be capable of tabulating votes for that candidate 

independent of which party option is validly selected. 

1.1.8-G – Precinct splits, Tabulation

When multiple ballot styles are associated with a specific precinct, the voting system must 

be capable of keeping separate totals for the number of ballots read and counted for each 

ballot style or split. Tabulation must not be affected by variation of contest selection

locations from one ballot style to another.
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1.1.8-H – N-of-M contest, Tabulation

For N-of-M voting, the voting system must be capable of tabulating votes, overvotes, and 

undervotes in contests where the voter is permitted to select up to a specified number of 

contest choices.

Discussion

Reconciliation of aliases means allowing EOs to declare two different spellings of a candidate's name 

to be equivalent (or not). Reconciliation of double votes means handling the case where, in an N-ofM contest, a voter has attempted to cast multiple votes for the same candidate using the write-in

mechanism. 

1.1.9-J – Ballot rotation

Tabulation must be capable of tabulating votes when the ordering of contest options in 

ballot positions within each contest is variable.

An N-of-M contest is one where a voter is allowed N contest selections from a list of M choices and 

where votes are tallied independent of any other contest choices. N includes 1 vote (1 vote for 1 

contest or typically a measure) or any larger number. Contest choices include those where the 

contest choices are candidates for a specific office or measures/referenda where there are usually 

only two contest choices (Yes/No, For/Against) but may also be a list of choices (Tax rate A, Tax rate 

B, Tax rate C). An N-of-M contest is used for approval voting by setting N to be equal to M. This type 

of contest is used for limited voting by setting N to be less than the number of seats being elected. 

An N-of-M contest is also is used for top-2 primary contests (blanket primary contests), where N is 

always 1 but the 2 candidates with the most votes will be on the general election ballot. 

Discussion

This simply means that ballot rotation will not impact the correctness of the count. 

1.1.9-K – Straight party voting

Tabulation must be capable of tabulating straight party votes.

1.1.9-L – Tabulating straight party votes

A straight party vote must be counted as a vote in favor of all contest options endorsed by 

the chosen party in each straight-party-voting contest in which the voter does not cast an 

explicit vote.

Discussion
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This requirement intentionally says nothing about what happens when there is both a straight party 

endorsed contest option and an explicit vote in a given contest (a straight party override). 

Jurisdictions may handle this in various ways, including to void the ballot or contest.

1.1.9-M – Cross-party endorsement

For cross-party endorsement, tabulation must be capable of tabulating straight-party votes 

when a given contest option is endorsed by two or more different political parties.

1.1.9-N – Precinct splits

Tabulation must be capable of tabulating votes for precinct splits or combinations of 

precincts.

1.1.9-O8-I – Cumulative voting contest, Tabulation

For cumulative voting, tabulationthe voting system must be capable of tabulating votes, 

overvotes, and undervotes in contests where the voter is allowed tocontests where the voter 

may allocate up to a specified number of votes over a list of contest options howeverchoices 

in any manner they choose,. This may result in possibly giving more than one vote to a given 

contest option.contest selection.

1.1.9-P8-J – Ranked choice voting contest, Tabulation

For ranked choice voting, tabulation must be capable of determining the results of a ranked 

choice contest for each round of tabulation.

Discussion

For ranked choice voting (RCV), the voting system must 

1. capture the voter’s ranking of each contest selection and store it in the CVR 

associated with the ballot style;

2. aggregate 1st choice totals of each contest selection; and

3. process the collection of CVRs round-by-round according to the method specified in 

the implementation statement.

Discussion 

Ranked choice voting (RCV) tabulation methods are different for single seat and multi-seat contests. 

Jurisdictional rules vary even when using the same basic method. A voting unit or precinct tabulating 

unit cannot perform RCV tabulation. RCV tabulation requires the concurrent availability of all CVRs 

associated with an RCV contest and is a post-voting accumulation/aggregation process. Some 
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jurisdictional rules may only require use of the RCV tabulation process if aggregated first choice 

selections do not produce the total needed to exceed the threshold of votes required to win. Other 

jurisdictional rules do not use tabulated and aggregated 1st choice selections and require the RCV 

tabulation process to be used for all winners. Single winner RCV is also known as IRV (Instant Runoff 

Voting). STV (Single Transferable Vote) is a method used for multi-winner RCV. Another multiwinner process (Sequential At-Large IRV) uses successive IRV passes, one pass to determine each 

winner.

1.1.8-K – Group voting contest, Tabulation

When tabulating group voting contest choices, the voting system must automatically select 

each contest choice that is affiliated with the selected group as if the voter manually 

selected each of those candidate choices. Any selection of a contest choice outside of the 

group will constitute as an overvote if the number of candidates in the group selected is 

equal to the votes allowed.

Discussion

There may be multiple candidate groups in a contest. The ballot normally places contest options for 

all candidates in a group sequentially, with the group contest option first. If a contest is not fully 

voted by utilizing the group voting contest option, a voter can select additional contest options 

outside of the group, as long as the total does not exceed the votes allowed.

1.1.8-L – Presidential delegate contest, Tabulation

When tabulating a presidential delegate contest, the voting system must prevent votes for 

any delegate in the contest that is not representing the president candidate chosen by the 

voter’s contest option selection in the presidential contest. 

Discussion

Most states that directly elect presidential delegates do not have a tabulation associated with the 

presidential candidate selection. However, as of 2020, Alabama has included this association on both 

the democratic and republican ballots, while Rhode Island has the association on the democratic 

ballot. When used, if there is no presidential candidate selection or the presidential candidate and 

no affiliated delegate in the contest, no vote will be counted for any delegate contest option 

selection.

1.1.8-M – Recall contest pair

When tabulating a recall/replace contest pair, the voting system must only tabulate the 

replace contest (controlled contest) if there is a vote selection in the recall contest 

(controlling contest).
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Discussion

The recall contest in the contest pair is typically a question used to determine whether an elected 

official should be recalled and the replace contest allows selection of the desired replacement. If the 

question is not voted, the replacement contest is not processed. However, the contest pair has been 

used for other purposes such as annexations and determination of tax rates.

1.1.8-N – Proportional voting contest (equal-and-even cumulative voting 

contest), Tabulation

Votes selections in a proportional voting contest (also known as an equal-and-even 

cumulative voting contest) must be tabulated for the selected contest option or options by 

dividing the allowed votes by the number of contest option selections; this may occur as long 

as the number of selections do not exceed the number of allowed votes. 

Discussion

This requirement is minimal. Since ranked choice voting is not currently in wide use, it is not clear 

what, other than the final result, will be computed. 

This may produce a fractional number of votes tabulated for a candidate. However, it is not possible 

to tabulate undervotes in this contest.

1.1.109 – Reporting results

1.1.109-A – Post-election reports

The voting system must have the capability to create precinct post-election reports that

contain cast ballot counts and vote counts for contests on the ballot types served by 

precincts or splits of precincts.

1.1.109-B – Report categories of cast ballots

The voting system must have the capability to report the number of ballots cast in total and 

broken down by ballot style. This is in addition to the associated units of political geography 

for the following categories of ballots cast:

1. All read ballots and all counted ballots,

2. For multi-page ballots, the number of different pages read, and number counted,

3. Read ballots and counted ballots that require review,
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4. Absentee read and counted ballots, and

5. Blank ballots (ballots containing no votes).

Discussion

Associated units of political geography may also include state, county, city, town or township, ward, 

and districts.

1.1.9-C – Report categories of votes 

The voting system must have the capability to report the following categories of votes:

1. in-person voting,

2. absentee voting,

3. write-ins,

4. accepted reviewed ballots, and

5. rejected reviewed ballots.

1.1.9-D – Reporting device consolidationcombined or split precincts

The voting system must be capable of generating reports that consolidate vote data from 

selected precincts.

Discussion

Jurisdictions in which more than one precinct may vote at the same location on either the same 

ballot style or a different ballot style may desire reports that consolidate data from the voting 

location by precinct.

1.1.9-E – Report counted ballots by contest

The voting system must have the capability to report the number of counted ballots for each 

relevant N-of-M or cumulative voting contest.

Discussion

The count by contest could be inferred from the other counts that are broken down by ballot 

configuration, but providing this figure explicitly will make it easier to account for every vote. N-of-M

in this requirement includes the most common type of contest, 1-of-M.
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1.1.9-F – Report votes for each contest option

The voting system must have the capability to report the vote totals for each contest option

in each relevant N-of-M or cumulative voting contest.

Discussion

N-of-M in this requirement includes the most common type of contest, 1-of-M.

1.1.9-G – Report overvotes for each contest

The voting system must have the capability to report the number of overvotes for each 

relevant N-of-M or cumulative voting contest.

1.1.9-H – Report undervotes for each contest

The voting system must have the capability to report the number of undervotes for each 

relevant N-of-M or cumulative voting contest.

Discussion

Counting ballots containing undervotes instead of votes lost to undervoting is insufficient.

1.1.9-I – Ranked choice voting, report results

The voting system must have the capability to report the contest choice vote totals for each 

ranked choice contest and for each round of tabulation.

Discussion

This requirement is minimal. Since ranked choice voting is not currently in wide use, it is not clear 

what needs to be reported, how bogus orderings are reported, or how it would be done in multiple 

reporting contexts. 

1.1.9-J – Precinct reporting devices, reporting device consolidation

When more than one vote-capture device or voter-facing scannervote-capture device is 

used, it must be possible in a polling place, the voting system must have the capability to 

consolidate the data contained intabulated by each unit into a single report for the polling 

place. If the consolidation of polling place data is done locally, the precinct reporting device

needs to perform this consolidation in no more than 5 minutes per scanner.

Discussion

Discussion
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This requirement essentially requires precinct-based vote-capture devices to be able to consolidate 

voting data for the purposes of issuing one consolidated report.

1.1.10-C – Reporting is non-destructive

The voting system must prevent data, including data in transportable memory, from being 

altered or destroyed by report generation.

Discussion

Appending an audit record reflecting the fact that a report has been generated is not considered an 

alteration.

1.1.10-D – Ballot and vote counts

The voting system must be capable of generating human-readable reports of the vote and 

ballot count, including the capability for: 

1. alphanumeric headers

2. election, office, and issue text

3. alphanumeric entries generated as part of the audit record

1.1.9-KDiscussion

This requirement and its sub-requirements specify a minimum set of information that a voting 

system will report. They do not prohibit any voting system from reporting additional information that 

may be required by jurisdictions or otherwise found to be useful.

1.1.10-E – Report all votes cast

All systems must be able to produce an accurate, human-readable report of all votes cast.

Discussion

Binary document formats and text containing markup tags are not considered human-readable. The 

system may generate such documents, but it must also provide the functionality to render those 

documents in human-readable form (for example, by including the necessary reader application).

1.1.10-F – Account for all cast ballots and all valid votes

All systems must produce vote data reports that account for all cast ballots and all valid 

votes.
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1.1.10-G Discrepancies detectable

Any discrepancy that is detectable by the system must be flagged in the system by an 

annotation or error message in the affected report or a separate discrepancy report.

Discussion

If this requirement is applicable, then the system has failed to satisfy Requirement 1.1.10-G and is 

therefore non-conforming. Nevertheless, in practice it is essential that discrepancies be flagged by 

the system as much as possible so that they are not overlooked by election judges. The system 

cannot detect discrepancies if no single voting device is ever in possession of a sufficient set of data.

1.1.10-H – Reporting combined precincts

The voting system must be capable of generating reports that consolidate vote data from 

selected precincts.

Discussion

Jurisdictions in which more than one precinct may vote at the same location on either the same 

ballot style or a different ballot style may desire reports that consolidate the voting location.

1.1.10-I – Precinct reporting devices, no tallies before polls close 

The voting system must prevent the printing of vote data reports and extracting vote tally 

data beforewhile the polls closeare open.

Discussion

Providing ballot counts does not violate this requirement. The prohibition is against providing vote 

totals. Ballot counts are required for ballot accounting, but early extraction of vote totals is an 

enabler of election fraud. for ballot contests. 

1.1.10-J9-L – Report categories of castread ballots by party

AllThe voting systemssystem must reporthave the number of ballots both in total and broken 

down by ballot style and by selected units of political geography including county, city, town 

or township, ward, precinct, and precinct split, for the following categories of cast ballots:

1. All read ballots and all counted ballots

2. For multi-page ballots, the number of different pages read, and number counted

3. Recallable read ballots and counted ballots

4. UOCAVA read ballots and counted ballots

5. Absentee read and counted ballots
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6. Blank ballots (ballots containing no votes)

capability of Discussion

There is no sub-requirement for separate reporting of provisional cast ballots because the system is 

unlikely to know whether a ballot is provisional until it is successfully read. Some jurisdictions find the 

number of blank ballots to be useful. Blank ballots sometimes represent a protest vote.

1.1.10-K – Report read ballots by party

Systems must report separate totals for each party in primary electionsprimary elections

when reporting categories of read and counted cast ballots.

1.1.10-L – Report counted ballots by contest

All systems must report the number of counted ballots for each relevant N-of-M or 

cumulative voting contest.

Discussion

The count by contest could be inferred from the other counts that are broken down by ballot 

configuration, but providing this figure explicitly will make it easier to account for every vote. N-of-M

in this requirement includes the most common type of contest, 1-of-M.

1.1.10-M – Report votes for each contest option

All systems must report the vote totals for each contest option in each relevant N-of-M or 

cumulative voting contest.

Discussion

N-of-M in this requirement includes the most common type of contest, 1-of-M.

1.1.10-N – Report overvotes for each contest

Systems must report the number of overvotes for each relevant N-of-M or cumulative voting

contest.

Discussion

This count refers to votes lost to overvoting, not of ballots containing overvotes. This means that a 

ballot that overvotes an N-of-M contest would contribute N to the count of overvotes for that 

contest.
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1.1.10-O – Reporting overvotes, ad hoc queries

All systems must be capable of producing a consolidated report of the combination of 

overvotes for any contest that is selected by an authorized official (for example, the number 

of overvotes in a given contest combining candidate A and candidate B, or combining 

candidate A and candidate C).

1.1.10-P – Report undervotes for each contest

All systems must report the number of undervotes for each relevant N-of-M or cumulative 

voting contest.

Discussion

Counting ballots containing undervotes instead of votes lost to undervoting is insufficient.

1.1.10-Q – Ranked choice voting, report results

Systems implementing ranked choice voting must report the contest option vote totals for 

each ranked choice contest for each round of tabulation.

Discussion

This requirement is minimal. Since ranked choice voting is not currently in wide use, it is not clear 

what needs to be reported, how bogus orderings are reported, or how it would be done in multiple 

reporting contexts. 

1.1.10-R – Include all categories of votes 

Systems must report all following categories of votes in the consolidated reports:

1. In-person voting

2. Absentee voting

3. Write-ins

4. Accepted recallable ballots

5. Accepted reviewed ballots

1.1.10-S – Post-election reports in common data format

The voting system must include support for the NIST 1500-100 CDF specification for postelection reports.

External reference: NIST 1500-100 CDF
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1.1.10-T – CVR export and import in common data format

The voting system must include support for the NIST 1500-102 CDF specification for cast vote 

records for exporting a collection of CVRs from the device that created the CVRs and for 

importing a collection of CVRs into devices that process CVRs1.1.9-M.

Discussion

This requirement concerns export of CVRs from devices such as scanners or code and bar-code 

reading devices and import of the CVRs into adjudication devices, tabulators, and audit devices.

External reference: NIST 1500-102 CDF

1.1.10-U – Reports are time stamped

All reports must include the date and time of the report's generation, including hours, 

minutes, and seconds. Timestamps in reports need to comply with ISO 8601, provide all four 

digits of the year, and include the time zone.

External reference: ISO 8601
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1.2 – The voting system is designed to function correctly under realworld operating conditions.

Requirements in this section deal with voting system accuracy and reliability.

1.2-A – Assessment of accuracy

The voting system’s accuracy must be assessed by using a combination of evidence items 

gathered during the entire course of testing, including:

1. A measurement of how accurately voter marks are recognized as valid or not valid 

according to manufacturer specifications.

2. A measurement of how accurately voter marks are tabulated and reported as results.

3. An assessment of whether the remaining VVSG requirements are satisfied.

Discussion

A voting system cannot be determined as accurate without some uncertainty; thus, a judgement 

must be made based on evidence. In this case, a volume test is used under real-world conditions, and 

evidence collected throughout the test campaign as to whether the voting system satisfies all other 

relevant VVSG requirements.

Prior VVSG source: New requirement

The data collected during the testing of this requirement contributes substantially to the evaluations 

of reliability, accuracy, and misfeed rate. 

1.2-B – Reliably detectable marks

The voting system must detect marks on the ballot consistent with system mark 

specifications and differentiate between voter-made marks constituting votes versus votermade marginal marks or other marks on the ballot.

Discussion

The specification may have parameters for different configuration values. It should also state the 

degree of uncertainty. 

1.2-C – Minimum ballot positions

A minimum of 10,000,000 ballot positions must be read by the voting system and tabulated 

accurately.

Discussion
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The value of 10,000,000 ballot positions is taken from VVSG 1.0, [VVSG2005], however it is used here 

as the minimum number of ballot positions to test without error. If a larger number of ballot 

positions is used, there still can be no error.

Prior VVSG source: VVSG-1.0 - 4.1.1

1.2-C – Ballot position distribution

1.2-D – Handle maximum volume

The ballot positionsvoting system must be spread across devicesable to handle the maximum

volume of activities in conditions approximating normal use in an entire election process

according to a typical volume per device in a typical electionmanufacturer specifications.

Discussion

ThisDiscussion

The test lab determines the typical volume per device and then spreads the number of ballot 

positions to be tested accordingly across the devices, for example, 10% to the ballot marking device 

(BMD), 40% to the voter facing scanner, etc.

Prior VVSG source: New requirement

1.2-D – Mark quality

For devices that read and interpret human-made marks on ballots, the mark quality of the 

marks must be spread across the manufacturer’s published specifications for valid marks and 

invalid marks according to expected distributions in typical elections.

Discussion

The goal of this requirement should be verified through operational testing if the limit is to model 

real-worldpractically testable. 

1.2-E – Respond gracefully to stress of system limits

Certain conditions. The test lab would prepare, using the manufacturer’s specifications for valid 

marks, a set of test ballots in which mark quality will vary as it would in typical elections. In the case 

of marks that are borderline valid tend to overload the system’s capacity to process, store, or invalid, 

a scanner may flag the marks as requiring adjudication.

Prior VVSG source: New requirement
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1.2-E – Assessment of reliability

The voting system’s reliability must be assessed using a combination of evidence items 

gathered during the entire course of testing, including:

1. continuous operation of the voting system under typical environmental conditions.

2. Continuous operation ofreport data. These conditions include attempts to process 

more than the expected number of precincts, and to process more than the expected 

volume or ballot tabulation rate. Therefore, the voting system under varied 

environmentalmust be able to respond to the above conditions across defined 

ranges.

3. An assessment of the manufacturer’s statement of the reliability of that overload the 

system’s capacity, by ensuring that the voting system by applying best practices for 

reliability engineering practices and standard reliability analysis methods (e.g., failure 

modes and effects analysis (FMEA)). 

Discussion

As with accuracy, reliability cannot be positively ascertained; a judgment of reliability has to 

be determined from evidence. In this case, a volume test is used to determine the reliability 

ofdoes not fail or halt suddenly. The voting system operations, as well as data from the test 

campaign regarding relevant VVSG requirements. In bullet 3, a manufacturer needs must 

give adequate warning if it is to show that reliability has been built into the voting system 

using a reliability analysis such as in FMEA. Consequently, the test lab has to assess the 

manufacturer’s statement of reliability and weigh the performance of the voting system 

against that assessmentfail or halt for any reason.

Discussion

This requirement should be verified through operational testing if the limit is practically testable. 

Prior VVSG source: VVSG-1.0 – 4.3.5

VVSG-1.1 – 4.1.1

1.2-F – Continuous operation – typical environmental conditions

The voting system must operate for a continuous period of at least 163 hours during which 

ballots are cast and ballot positions are read and tabulated without error. Table 1 shows the 

volume of ballots that must be cast during this period for vote-capture devices. The duration 

of the testing is as follows:

1. When testing a single device, e.g., a single BMD, the period of testing must be no 

less than 163 hours.
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2. When testing two or more of the same device, e.g., two identical BMDs, the period 

of testing must be no less than 81 hours.

Discussion

This requirement is, in essence, a volume test in which the voting system is expected to operate 

continuously for 7 days without error. A form of this requirement is in VVSG 1.0; VVSG 1.1 omitted it 

entirely. The continuous operation may occur under typical expected temperatures and humidity 

such as may be found in a standard test lab environment. For hybrid devices such as a BMD 

combined with a tabulator, two devices should be tested for the 163-hour duration, e.g., one tested 

as a tabulator, one tested as a BMD. For mixed mode devices such as an accessible BMD used for all 

voters, the modes should be alternated during the testing.

Prior VVSG source: VVSG-1.0 - 4.1.2-A.2

DEVICE VOLUME/HOUR

CENTRAL SCANNER Manufacturer’s stated maximum volume/4

VOTER FACING SCANNER 100

BMD INCLUDING 

ACCESSIBLE VERSION

Ballots cast for at least 15 minutes per hour

Table 1 – Volume per hour for vote-capture devices

1.2-G – Continuous operation – varied environmental conditions

The voting system must operate for a continuous period of at least 24 hours during which 

ballots are cast and ballot positions are read and tabulated without error and in which 

temperature and humidity are varied.

1. The temperature must range from 41 °F to 104 °F (5 °C to 40 °C).

2. The relative humidity must range from 5 % to 85 %, noncondensing.

Discussion

In VVSG 1.0, the tests for humidity and temperature are included as requirements. For the VVSG 2.0, 

the same material will be specified as part of an EAC-governed test assertion and not included here.

Prior VVSG source: VVSG-1.0 - 4.1.2

1.2-H – Failure Modes and Effect Analysis (FEMA)

The manufacturer must ensure the reliability of the voting system by applying best practices 

for reliability engineering practices and standard reliability analysis methods, for example, 

failure modes and effects analysis (FMEA).
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Discussion

Manufacturers are now required to apply best practices to assure reliability in addition to the volume 

test-related requirements. If using FMEA for the manufacturer’s reliability analysis, each specific, 

individual, identified failure mode would be assigned a probability, and the system probability of 

failure would then be derived mathematically. Since the underlying probabilities are likely to depend 

on the volume that a device is expected to handle in the course of the election, minimum values for 

the assumed volume per device per election. Other credible forms of reliability analysis could be 

used, provided they are widely used and accepted in the reliability measurement field.

Prior VVSG source: VVSG-1.1-Vol2 – 5.6.6.2

1.2-I – No single point of failure

All systemsThe voting system must protect against a single point of failure that would 

prevent further voting at the polling place.

Discussion

Prior VVSG source: VVSG 2007 - 6.3.1-B

1.2-J – Protect againstThe intent of this requirement is to prevent, at the 

polling place, a situation in which failure of input and storagea component 

would prevent voting. This can be addressed in various ways, including being 

able to swap in/out devices

All systems must withstand, without loss of data, the failure of any data input or storage device. .

Prior VVSG source: VVSG 2007 - 6.3.1-C

1.2-K – Reliably detectable marks

For an optical scanner, the system must detect marks for detectable and marginal marks 

consistent with system mark specifications.

Discussion

1.2-GThe specification may have parameters for different configuration values. It should also state 

the degree of uncertainty. 

Prior VVSG source: VVSG 2007 - 4.1.2-A.2

1.2-L – Misfeed rate benchmark

The voting system misfeed rate must not exceed 0.002 (1 / 500).

Discussion
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Multiple feeds, misfeeds (jams), and rejections of ballots that meet all manufacturer specifications 

are all treated collectively as "misfeeds" for benchmarking purposes; that is, only a single count is 

maintained. 

Prior VVSG source: VVSG 2007 - 6.33

1.2-M – Respond gracefully to stress of system limits

The system must be able to respond gracefully to attempts to process more than the 

expected number of ballots per precinct, more than the expected number of precincts, 

higher than expected volume or ballot tabulation rate, or any similar conditions that tend to 

overload the system's capacity to process, store, and report data.

1.2-H – Protect against failure of input and storage devices

The voting system must withstand, without loss of data, the failure of any data input or 

storage device.

Discussion

The intent of this requirement is to prevent votes from being permanently lost due to the failure of a 

storage device that contains votes. For example, if a scanner fails, the voting system must have the 

ability to swap in a replacement data input device without the losing cast vote records that were 

previously recorded by the failed scanner.

1.2-I – FCC Part 15 Class A and B conformance

Voting devices must comply with the requirements of the Rules and Regulations of the 

Federal Communications Commission, Part 15, Class B [FCC19a].

1. Voting devices located in polling places must minimally comply with Class B

requirements.

2. Voting devices located in non-polling place settings such as back offices must 

minimally comply with Class A requirements. 

1.2-J – Power supply from energy service provider

Voting devices located in polling places must be powered by a 120 V, single phase power 

supply derived from typical energy service providers. 

Discussion

It is assumed that the AC power necessary to operate the voting system will be derived from the 

existing power distribution system of the facility housing the polling place. This single-phase power 
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may be a leg of a 120/240 V single phase system, or a leg of a 120/208 V three-phase system, at a 

frequency of 60 Hz.

1.2-K – Power port connection to the facility power supply

Voting devices located in polling places must comply with Class B emission limits affecting 

the power supply connection to the energy service provider.

Discussion

The normal operation of an electronic system can produce disturbances that will travel upstream and 

affect the power supply system of the polling place, creating a potential deviation from the expected 

electromagnetic compatibility of the system. The issue is whether these actual disturbances (after 

possible mitigation means incorporated in the equipment) reach a significant level to exceed 

stipulated limits.

Discussion

In particular, This requirement should be verified through operational testing if the limit is practically 

testable. 

Prior VVSG source: VVSG 2007 - 5.2.3-C

1.2-N – Handle realistic volume

The system must be able to handle a realistic volume of activities in 

conditions approximating normal use in an entire election process,L – Leakage

from election definition through reporting and auditing final 

results. grounding port

Voting devices located in polling places must comply with limits of leakage currents 

effectively established by the trip threshold of all listed Ground Fault Current Interrupters 

(GFCI), if any, installed in the branch circuit supplying the voting system.

Discussion

Excessive leakage current is objectionable for two reasons:

• For a branch circuit or wall receptacle that could be provided with a GFCI (depending upon the 

wiring practice applied at the particular polling place), leakage current above the GFCI built-in 

trip point would cause the GFCI to trip and therefore disable the operation of the system.

• Should the power cord lose the connection to the equipment grounding conductor of the 

receptacle, a personnel hazard would occur. (Note the prohibition of “cheater” adapters in the 

discussion of general requirements for the polling place.)
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Discussion

Data collected during this test contribute substantially to the evaluations of reliability, accuracy, and 

misfeed rate. 

Prior VVSG source: VVSG 2007 - 5.2.3-D
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1.3 – Voting system design supports evaluation methods enabling 

testers to clearly distinguish systems that correctly implement 

specified properties from those that do not.

1.3-A – IdentifiabilityReporting of basic and compound system 

componentsmanufacturer-performed tests

TheEach test provided documentation and equipment must ensure that a tester is able to 

clearly and unambiguously identify the full set of the basic (not made of any components) 

and compound (made up of other components) elements of the system.

Discussion

This is a basic condition necessary for a tester to be able to properly distinguish whether or not a 

system has correctly implemented specified properties or not. 

It may be fulfilled by satisfying the documentation-specific guidelines of principle 3, and by providing 

information in the a manufacturer-submitted report of internal testing performed (technical 

data package (TDP) that will support this kind of understanding.)) must, at least, include the 

following information:

1. requirement(s) under test;

2. items under test to exercise a given requirement;

3. pass-fail criteria necessary to determine whether or not a requirement has passed 

the test of conformity to the requirement;

4. evidence (observations, data) expected to provide justification for satisfying or failing 

a given pass-fail condition;

5. test procedures necessary to provide, observe, record, analyze, and interpret this 

evidence relative to pass-fail criteria;

6. where applicable, descriptions of the causes of variation, ambiguity, noise, or 

observed errors in observed and recorded evidence during tested procedures;

7. where applicable, descriptions of any necessary techniques, procedures, or processes 

applied to normalize or clean data prior to subjecting it to data analysis and 

interpretation relative to pass-fail criteria;

8. report of actual tests performed and their results; and

9. description and justification if a given test cannot be fully performed or exercised due 

to internal resource constraints, including description of alternative means of 

verification.

Discussion
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This is a documentation requirement. Its intent is to ensure a baseline set of information provided in 

manufacturer-submitted report of manufacturer-performed internal testing submitted as part of the 

TDP. Manufacturers may likely have additional information, formatting, etc., as part of their 

particular testing practices, that they will include as is consistent with their internal testing bestpractices.

1.3-B – Coverage of manufacturer-performed tests

Each requirement identified in a manufacturer-submitted implementation statement or 

conformance statement must describe one-or-more tests in their test-plan describing how it 

was tested.

Discussion

Prior VVSG source: New Requirement

1.3-B – Comprehensible processes that form system configurations

The provided documentation and equipment must ensure that a tester is able to clearly 

understand how particular configurations of process and technology are formed by 

combining their basic (and component) elements to produce the whole, final working system 

(whether in software, hardware, telecom, process, data, or other implemented aspect).

Discussion

This is a basic condition necessary for a tester to be able to properly distinguish whether or not a 

system has correctly implemented specified properties or not. 

It may be fulfilled by satisfying the documentation-specific guidelines of principle 3, and by providing 

information in the Technical Data Package (TDP) that will support this kind of understanding.

Prior VVSG source: New Requirement

1.3-C – Observable configurations via plausible observation methods

The provided documentation and equipment must ensure that a tester is able to identify and 

select plausible observational tools, techniques, or strategies that can be used to observe 

signs of the system configurations.

Discussion

This requirement is a basic condition necessary for a tester to be able to properly distinguish whether 

or not a system has correctly implemented specified properties or not. 

It may be fulfilled by satisfying the documentation-specific guidelines of principle 3, and by providing 

information in the Technical Data Package (TDP) that will support this kind of understanding. 
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Prior VVSG source: New Requirement

1.3-D – Identifiable resolution limits for observation methods 

From the provided documentation and equipment, for the observational tools, techniques, 

or strategies, a tester must be able to determine how well they can actually detect and 

distinguish each type of element and interconnection of elements in a system configuration.

Discussion

Every observational or measurement method has a limit to their resolution. Resolution is the 

threshold beyond which one cannot determine any more differences between two different things. 

This concept is sometimes known as the just noticeable difference of an observational method. This is 

like moving two things so close together that a given observer, eventually, cannot see powerfully 

enough to distinguish distances (differences) too small to detect with that technique. By identifying 

these limits, each evaluation method explicitly defines its power to distinguish certain observable 

configurations and characteristics from others.

This is a basic condition necessary for a tester to properly distinguish whether or not a system has 

correctly implemented specified properties or not. 

It may be fulfilled by satisfying the documentation-specific guidelines of principle 3, and by providing 

information in the TDP that will support this kind of understanding. 

Prior VVSG source: New Requirement

1.3-E – Description of observational noise and consequences for 

observational methods

From the provided documentation and equipment, for the observational tools, techniques, 

or strategies, a tester must be able to:

• determine what sources of noise will likely arise from observing a given system 

configuration completely by some observational method;

• map observable signs of system configurations (through that noise) to actual 

attributes of system configurations.

Discussion

It is often the case, when observing a system during testing, that one cannot always directly see what 

they are attempting to observe. Instead, one often sees indirectly observable signs of facts that 

would most likely be true if one could observe the system or component directly. Thus, much of the 

task of testing is to be sure that one can strongly relate the secondary facts of directly observable 

signs to those aspects of a system that may not be directly observable at all. In this way, a tester 
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Requirements for VVSG 2.0 February 29, 202010, 2021

always acknowledges the degree to which they can directly access signs of what they are actually 

evaluating.

In addition, very often the methods used for observing those signs may introduce some noise or error 

into the process for observing configurations. As a result, if not accounted for, such factors can 

significantly affect the degree to which one can understand and rely upon the relationship of the 

observed results to the configuration they strive to observe.

This is a basic condition necessary for a tester to properly distinguish whether or not a system has 

correctly implemented specified properties or not. 

It may be fulfilled by satisfying the documentation-specific guidelines of principle 3, and by providing 

information in the TDP that will support this kind of understanding.

Prior VVSG source: New Requirement

1.3-F – Explicitly-stated performance criteria

The provided documentation and equipment must ensure that a tester is able to state or use 

criteria that enable them to unambiguously decide whether or not an observed 

configuration exhibits intended properties.

all requirements identified in the respective implementation and conformanceDiscussion

Before one can begin to evaluate the performance of a given system task (that is, a given systemimplemented election function or process), one must be able to formulate some statements of facts 

that must be true of the original system configuration when there are observable signs of system 

configurations and their behaviors. 

This is a basic condition necessary for a tester to properly distinguish whether or not a system has 

correctly implemented specified properties or not. 

It may be fulfilled by satisfying the documentation-specific guidelines of principle 3, and by providing 

information in the TDP that will support this kind of understanding. 

Prior VVSG source: New Requirement

1.3-G – Creation and execution of evaluation methods

The provided documentation and equipment must ensure that a tester is able to derive, construct, 

and execute plausible evaluation methods (are covered by the submitted test methods, etc.) that can 

demonstrate an ability to:-plan.
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1. observe valid and invalid system configurations through plausible use of 

observational tools or techniques;

2. decide whether or not a given system configuration has satisfied the stated 

performance criteria;

3. report the findings resulting from their ability to distinguish correct from incorrect 

configurations of the system.

Discussion

This is a basic condition that is both necessary and sufficient for a tester to properly distinguish 

whether or not a system has correctly implemented specified properties or not. It includes and relies 

upon the satisfaction of the other testability requirements (1.3-A – 1.3-F). 

It may be fulfilled by satisfying the documentation-specific guidelines of principle 3, and by providing 

information in the TDP that will support this kind of understanding. 

Prior VVSG source: New Requirement

Principle 2

High Quality Implementation

The voting system is implemented using high quality best practices. 
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2.1 - The voting system and its software are implemented using 

trustworthy materials and best practices in software development.

2.2 - The voting system is implemented using best practice usercentered design methods that consider a wide range of representative 

voters, including those with and without disabilities, and election 

workers.

2.3 - Voting system logic is clear, meaningful, and well-structured.

2.4 - Voting system structure is modular, scalable, and robust. 

2.5 – The voting system supports system processes and data with 

integrity.

2.6 - The voting system handles errors robustly and gracefully recovers 

from failure. 

2.7 - The voting system performs reliably in anticipated physical 

environments.

Principle 2

High Quality Implementation

The voting system is implemented using high quality best practices. are 

designed to provide transparency.
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This principle covers core processes and functions that contribute to a voting system that has 

been implemented for quality. The requirements in this principle are basic best practices -- not 

a complete set of all quality practices. The guidelines under Principle 2 are:

2.1 - Software quality, including acceptable programming languages and coding styles, as well 

as coding constructs that should or should not be used to improve software integrity and 

security. Additional requirements deal with handling errors or device failures, and others cover 

electrical components. The sections in Guideline 2.1 cover:

1 – Workmanship which deals with best practices for providing high quality systems and parts, 

taking reasonable precautions to prevent defect or damage, and ensuring that system elements 

can be sufficiently durable and available with respect to lifetimes that are appropriate to their 

type and use.

2 – Maintainability covers the ability of a system and its components to be sufficiently 

identified and repaired during its operational lifetime.

2.2 - Design and implementation process so that the voting system can be used effectively by 

voters and election staff.

2.3 - Voting system logic or the overall structuring of voting system software. The goal is that 

the software structure be easily understood and clear to audiences such as test labs and 

maintained without causing major changes in the software structure. The sections in Guideline 

2.3 cover:

1 – Software flow which identifies common pitfalls to be avoided when organizing software 

control flow so as to preserve its clarity and ease of evaluation.

2.4 - Modularity and complexity of the system software structure.

2.5 - System processes and data using basic best practices for software integrity and secure 

coding constructs. The Election Assistance Commission (EAC), working with voting system test 

labs, may augment or change these requirements based on the discovery of new vulnerabilities 

or emerging new threats. The sections in Guideline 2.5 cover:

1 – Code integrity which deals with the protection of code from unauthorized change or 

tampering.

2 – Input/output errors supports practices to ensure the validity of inputs and outputs while 

also guarding against associated errors.

3 – Output protection which deals with the ability to protect against vulnerabilities known to 

affect outputs.
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4 – Error handling addresses the need for internal error checking, particularly for common 

types of coding errors such as various types of overflows, pointer-related errors, and so on.

2.5 and 2.6 - Graceful recovery the capability of the voting system to handle and recover from 

errors, including failures of devices and components.

2.7 - Physical environments includes the ability of a voting device to withstand influences from 

its physical environment whether due to humidity, temperature, shock, vibration, electrical, or 

related influences. 

The requirements on electrical disturbances are primarily covered by conformance to the Rules 

and Regulations of the Federal Communications Commission’s regulationCommission, Part 15, 

Class B [FCC19a]. The requirements here address items not covered by Class B, including the 

behavior of specific voting devices in the presence of electrical disturbances and cases where 

voting devices might interact with other devices or people.
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2.1 - The voting system and its software are implemented using 

trustworthy materials and best practices in software 

development.

2.1-A – Acceptable programming languages

Application logic must be produced in a high-level programming language that has all of the 

following control constructs:

1. sequence;

2. loop with exit condition (for example, for, while, or do-loops));

3. if/then/else conditional;

4. case conditional; and

5. block-structured exception handling (for example, try/throw/catch).

Discussion

A list of acceptable programming languages may be specified by the EAC in conjunction with voting 

system test labs.

This requirement can be satisfied by using COTS extension packages to add missing control constructs 

to languages that could not otherwise conform.

Discussion

A list of acceptable programming languages may be specified by the EAC in conjunction with voting 

system test labs.

By excluding border logic, this requirement allows the use of assembly language for hardware-related 

segments, such as device controllers and handler programs. It also allows the use of an externally -

imposed language for interacting with an Application Program Interface (API) or database query 

engine. However, the special code should be insulated from the bulk of the code, for example, by 

wrapping it in callable units expressed in the prevailing language to minimize the number of places 

that special code appears.

The use of non-COTS extension packages or manufacturer-specific code for this purpose is not 

acceptable, as it would place an unreasonable burden on the test lab to verify the soundness of an 

unproven extension (effectively a new programming language). The package needs to have a proven 

track record of performance supporting the assertion that it would be stable and suitable for use in 

voting systems, just as the compiler or interpreter for the base programming language does.

Prior VVSG source: VVSG 2007 - 6.4.1.2-A

VVSG 2007 - 6.4.1.5-A.1
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Previous versions of VVSG required voting systems to handle such errors by some means, preferably 

using programming language exceptions ([VVSG2005] I.5.2.3.e), but there was no unambiguous 

requirement for the programming language to support exception handling. These guidelines require 

programming language exceptions because without them, the programmer must check for every 

possible error condition in every possible location, which both obfuscates the application logic and 

creates a high likelihood that some or many possible errors will not be checked. Additionally, these 

guidelines require block-structured exception handling because, like all unstructured programming, 

unstructured exception handling obfuscates logic and makes its verification by the test lab more 

difficult. "One of the major difficulties of conventional defensive programming is that the fault 

tolerance actions are inseparably bound in with the normal processing which the design is to provide. 

This can significantly increase design complexity and, consequently, can compromise the reliability 

and maintainability of the software." [Moulding89]

Existing voting system logic implemented in programming languages that do not support blockstructured exception handling can be brought into compliance either through migration to a newer 

programming language (most likely, a descendant of the same language that would require minimal 

changes) or through the use of a COTS package that retrofits block-structured exception handling 

onto the previous language with minimal changes. While the latter path may at first appear to be less 

work, it should be noted that many library functions may need to be adapted to throw exceptions 

when exceptional conditions arise, whereas in a programming environment that had exceptions to 

begin with the analogous library functions would already do this (see Requirement 2.1-B – COTS 

language extensions are acceptable).

2.1-B – COTS language extensions are acceptable

Requirement 2.1-A – Acceptable programming languages may be satisfied by using COTS 

extension packages to add missing control constructs to languages that could not otherwise 

conform.

Discussion

The use of non-COTS extension packages or manufacturer-specific code for this purpose is not 

acceptable, as it would place an unreasonable burden on the test lab to verify the soundness of an 

unproven extension (effectively a new programming language). The package must have a proven 

track record of performance supporting the assertion that it would be stable and suitable for use in 

voting systems, just as the compiler or interpreter for the base programming language must. 

Prior VVSG source: VVSG 2007 - 6.4.1.2-A.1

2.1-C – Acceptable coding conventions

Application logic must adhere to a published, credible set of coding rules, conventions, or 

standards (called "coding conventions") that enhance the workmanship, security, integrity, 

testability, and maintainability of applications.
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Discussion

Coding conventions may be specified by the EAC in conjunction with voting system test labs.

Prior VVSG source: VVSG 2007 - 6.4.1.3-A

The requirement to follow coding conventions serves two purposes. First, by requiring specific risk 

factors to be mitigated, coding conventions support integrity and maintainability of voting system 

logic. Second, by making the logic more transparent to a reviewer, coding conventions facilitate test 

lab evaluation of the logic's correctness to a level of assurance beyond that provided by operational 

testing.

The source code review for workmanship now focuses on coding practices with a direct impact on 

integrity and transparency and on adherence to published, credible coding conventions, in lieu of 

coding conventions embedded within the standard itself.

The vast majority of coding conventions used in practice are tailored to specific programming 

languages. In these guidelines, the few coding conventions that have significant impact on integrity 

and transparency and that generalize relatively well to different programming languages have been 

retained, expanded, and made mandatory, while the many coding conventions that are language 

sensitive and stylistic in nature, and are made redundant by more recent, publicly available coding 

conventions, have been removed in favor of the published conventions.

As discussed, prescriptive coding conventions not directly related to integrity and transparency have 

been avoided in favor of published, credible conventions. 

Coding conventions are considered to be published if they appear in a publicly available book, 

magazine, journal, or new media with analogous circulation and availability, or if they are publicly 

available on the Internet. This requirement attempts to clarify the “published, reviewed, and 

industry-accepted” language appearing in previous iterations of the VVSG, but the intent of the 

requirement is unchanged.

Coding conventions are considered to be credible if at least two different organizations with no ties 

to the creator of the rules or to the manufacturer seeking conformity assessment, and which are not 

themselves voting equipment manufacturers, independently decided to adopt them and made active 

use of them at some point within the three years before conformity assessment was first sought. This 

requirement attempts to clarify the “published, reviewed, and industry-accepted” language 

appearing in previous iterations of the VVSG, but the intent of the requirement is unchanged.

Coding conventions evolve, and it is desirable for voting systems to be aligned with modern practices. 

2.1-D – Records last at least 22 months

All systems must maintain the integrity of election management, voting, and audit data, 

including cast vote records (CVRs), during an election and for a period of at least 22 months 
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afterward, in temperatures ranging from 5 C to 40 C (41 F to 104 F) and relative humidity 

from 5% to 85%, non-condensing.

Prior VVSG source: VVSG 2007 - 6.5.1-A

2.1.1 – Workmanship

2.1.1-A – General build quality

All manufacturers of voting systems must practice proper workmanship. by:

Prior VVSG source: VVSG 2007 - 6.4.3-A

2.1.1-B – High quality products

1. All manufacturers must adoptadopting and adhereadhering to practices and 

procedures that ensure their products are free from damage or defect that could 

make them unsatisfactory for their intended purpose. ; and

Prior VVSG source: VVSG 2007 - 6.4.3-A.1

2.1.1-C – High quality parts

2. All manufacturers must ensureensuring that components provided by external 

suppliers are free from damage or defect that could make them unsatisfactory or 

hazardous when used for their intended purpose.

Prior VVSG source: VVSG 2007 - 6.4.3-A.2

2.1.1-D – Suitability of COTSB – Durability estimation

A manufacturer must submit a warranty model to the EAC, testing labs, and customers, that 

includes for each product, its relevant components, and associated consumables:

1. estimated replacement rates (e.g., 3 years, 10 years);

2. estimated costs per replacement;

3. estimated warranty types and costs;

4. associated replacement policies, services, and available maintenance agreements; 

and

5. plans for collecting, maintaining, and reporting data to the EAC to support and 

validate estimates.
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Discussion

Manufacturers must ensure that all COTS components included in their voting systems are 

designed to be suitable for their intended use under the requirements specified by the VVSG 

2.0.

A number of factors associated with the durability of a product or its components can be highly 

variable and even particular to the type of components (e.g., COTS, consumables). This variance is 

also applicable to the resources of a given manufacturer. Thus, instead of prescribing a pre-estimated 

number for all manufacturers, the manufacturers are asked to make these estimates relative to their 

own products, components, and resources, and to provide the basis for these estimates (these 

warranties, replacement periods, etc.) to the EAC, labs, and customers. In this way, manufacturers 

can perform estimates most relevant to their chosen manufacturing strategies (i.e., COTS-centric vs. 

custom-built, and so on).

Discussion

For example, if the operating or storage environmental conditions specified by the manufacturer of a 

printer do not meet or exceed these requirements, a system that includes that printer cannot be 

found conforming. 

Prior VVSG source: VVSG 2007 - 6.4.3-B

2.1.1-E – Durability

Voting systems must be designed to withstand normal use without deterioration for a period 

of ten years.

Prior VVSG source: VVSG 2007 - 6.4.4-A

2.1.1-FC – Durability of paper

Paper specified for use with the voting system must conform to the applicable specifications 

contained within the Government Paper Specification Standards, February 1999 No. 11, or 

the government standards that have superseded them.

Discussion

This is to ensure that paper records will be of adequate quality to survive the handling necessary for 

recounts, audits, etc. without problematic degradation. The Government Paper Specification 

Standards include different specifications for different kinds of paper. As of 2007-04-052020-02-29, 

the Government Paper Specification Standards, February 1999 No. 11, are available at 

http://www.gpo.gov/acquisition/paperspecs.htm11 [GPO19].
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Prior VVSG source: VVSG 2007 - 6.4.4-B2.1.1-D – Ensure compatibility of 

specified paper and ink

Ink specified for use with the voting system must be compatible with the paper 

specifications provided by the manufacturer.

Discussion

The purpose of this requirement is to ensure that both the types of ink and paper used with a given 

system are compatible with each other in an effort to avoid many of the side-effects of mismatched 

ink and paper (e.g., excessive smudging).

2.1.2 – Maintainability

2.1.2-A – Electronic device maintainability

Electronic devices must exhibit the following physical attributes: 

1. labels and the identification of test points,;

2. built-in test and diagnostic circuitry or physical indicators of condition, ; and

3. labels and alarms related to failures, and.

1. features that allow non-technicians to perform routine maintenance tasks.

Prior VVSG source: VVSG 2007 - 6.4.5-A

2.1.2-B – System maintainability

Voting systems must allow for: 

1. a non-technician to easily detect that the equipment has failed; 

2. a trained technician to easily diagnose problems; 

3. easy access to components for replacement; 

4. easy adjustment, alignment, and tuning of components; and 

5. low false alarm rates (that is, indications of problems that do not exist).

Prior VVSG source: VVSG 2007 - 6.4.5-B

2.1.2-C – Nameplate and labels

All voting devices must: 
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1. Display a permanently affixed nameplate or label containing the name of the 

manufacturer or manufacturer, the name of the device, its part or model number, 

its revision identifier, its serial number, and if applicable, its power requirements. 

2. If service or preventative maintenance is required, display a separate data plate 

containing a schedule for and list of operations required to service or to perform 

preventive maintenance, or a reference to where this can be found in the voting 

equipment user documentation.

3. 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.

Prior VVSG source: VVSG 2007 - 6.4.5-C

2.2 – The voting system is implemented using best practice usercentered design methods that consider a wide range of 

representative voters, including those with and without 

disabilities, and election workers.

2.2-A – User-centered design process

The manufacturer must submit a report providing documentation that the system was 

developed following best practices for a user-centered design process. 

The report must include, at a minimum:

1. a listing of user-centered design methods used;

2. the types of voters and election workers included in those methods;

3. how those methods were integrated into the overall implementation process; and

4. how the results of those methods contributed to developing the final features and 

design of the voting system.

Discussion

The goal of this requirement is to allow the manufacturer to demonstrate, through the report, the 

way their implementation process included user-centered design methods.

“ISO-9241-210:20102019 Ergonomics of human-system interaction—Part 210: Human-centered

design for interactive systems [ISO19b] provides requirements and recommendations for humancentered principles and activities throughout the life -cycle of computer-based interactive systems.”.

It includes the idea of iterative cycles of user research to understand the context of use and user 
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needs, creating prototypes or versions, and testing to confirm that the product meets the identified 

requirements. 

This requirement does not specify the exact user-centered design methods to be used, or their 

number or timing. 

The ISO group of requirements, Software engineering -- Software product Quality Requirements and 

Evaluation (SQUARE) -- Common Industry Format (CIF) for Usability includes several standards that 

are a useful framework for reporting on user-centered design activities and usability reports. :

• • ISO/IEC TR 25060:2010: General framework for usability-related information [ISO10]

• • ISO/IEC 25063:2014: Context of use description [ISO14]

• • ISO/IEC 25062:2006: Usability test reports [ISO06b]

• • ISO/IEC 25064:2013: User needs report [ISO13b]

• • ISO/IEC 25066:2016 Evaluation report [ISO16]

The final research report from the Los Angeles Voting Systems for All People project is an example of 

a summary report of a user-centered design process to design a voting system.

External reference: ISO 9241-210:2010 – Human-centered design for 

interactive systems

Related requirements: 8.3-A- – Usability testingtests with voters

8.4-A- – Usability testingtests with election workers

2.3 - Voting system logic is clear, meaningful, and well-structured.

2.3-A – Block-structured exception handling

Application logic must handle exceptions using block-structured exception handling 

constructs.

Prior VVSG source: VVSG 2007 - 6.4.1.5-A 

Discussion

The concept of "block-structured exception handling," is the ability to associate exception handlers 

with blocks of logic, and implicitly, the presence of the exception concept in the programming 

language. (This simply means try/throw/catch or equivalent statements and should not be confused 

with the specific implementation known as Structured Exception Handling (SEH) [MS20].[2]) Unlike 

deeply nested blocks, exceptions cannot be eliminated by restructuring logic. "When exceptions are 

not used, the errors cannot be handled but their existence is not avoided." [ISO00]
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Previous versions of VVSG required voting systems to handle such errors by some means, preferably 

using programming language exceptions ([VVSG2005] I.5.2.3.e), but there was no unambiguous 

requirement for the programming language to support exception handling. These guidelines require 

programming language exceptions because without them, the programmer must check for every 

possible error condition in every possible location, which both obfuscates the application logic and 

creates a high likelihood that some or many possible errors will not be checked. Additionally, these 

guidelines require block-structured exception handling because, like all unstructured programming, 

unstructured exception handling obfuscates logic and makes its verification by the test lab more 

difficult. "One of the major difficulties of conventional defensive programming is that the fault 

tolerance actions are inseparably bound in with the normal processing which the design is to provide. 

This can significantly increase design complexity and, consequently, can compromise the reliability 

and maintainability of the software." [Moulding89].

2.3-B – Legacy library units 

If application logic makes use of any COTS or third-party logic callable units that do not throw 

exceptions when exceptional conditions occur, those callable units must be wrapped in 

callable units that check for the relevant error conditions and translate them into exceptions, 

and the remainder of application logic must use only the wrapped version.

Discussion

Prior VVSG source: VVSG 2007 - 6.4.1.5-A.1

Existing voting system logic implemented in programming languages that do not support block 

structured exception handling can be brought into compliance either through migration to a newer 

programming language (most likely, a descendant of the same language that would require minimal 

changes) or through the use of a COTS package that retrofits block-structured exception handling 

onto the previous language with minimal changes. While the latter path may at first appear to be less 

work, it should be noted that many library functions may need to be adapted to throw exceptions 

when exceptional conditions arise, whereas in a programming environment that had exceptions to 

begin with the analogous library functions would already do this.

2.3-C – Separation of code and data

Application logic must not compile or interpret configuration data or other input data as a 

programming language.

Discussion

The applicable requirement in VVSG2005 reads "Operator intervention or logic that evaluates 

received or stored data must not re-direct program control within a program routine." That attempt 

to define what it means to compile or interpret data as a programming language caused confusion.
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Distinguishing what is a programming language from what is not requires some professional 

judgment. However, in general, sequential execution of imperative instructions is a characteristic of 

conventional programming languages that should not be exhibited by configuration data. 

Configuration data must be declarative or informative in nature, not imperative.

For example: Configuration data can contain a template that informs a report generating application 

about the form and content of a report that it should generate. However, configuration data cannot 

contain instructions that are executed or interpreted to generate a report, essentially embedding the 

logic of the report generator inside the configuration data.

The reasons for this requirement are 

• mingling code and data is bad design, and 

• embedding logic within configuration data evades the conformity assessment process for 

application logic.

Prior VVSG source: VVSG 2007 - 6.4.1.5-C

2.3-D – Hard-coded passwords and keys

Voting system software must not contain hard-coded, including the use of:

1. passwords, or

2. cryptographic keys.

Discussion

Many examples of this vulnerability have previously been identified in voting system software. 

Additional information about this vulnerability can be found at CWE-259: Use of Hard-coded 

Password and CWE-321: Use of Hard-coded Cryptographic Key.MITRE CWE-259: Use of Hard-coded 

Password [MITRE20a] and MITRE CWE-321: Use of Hard-coded Cryptographic Key [MITRE20b].

External references: CWE-259: Use of Hard-coded Password

CWE-321: Use of Hard-coded Cryptographic Key

2.3.1 – Software flow

2.3.1-A – Unstructured control flow 

Application logic must contain no unstructured control constructs.

Discussion

Although it is typically developed by the voting system manufacturer, border logic is constrained by 

the requirements of the third-party or COTS interface with which it interacts. It is not always possible 

for border logic to achieve its function while conforming to standard coding conventions. For this 
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reason, border logic should be minimized relative to application logic and where possible, wrapped in 

a conforming interface. An example of border logic that could not be so wrapped is a customized 

boot manager that connects a bootable voting application to a COTS BIOS.

2.3.1-B – Goto

Arbitrary branches (also known as gotos) must not be used.

Prior VVSG source: VVSG 2007 - 6.4.1.5-B.1

2.3.1-C – Intentional exceptions

Exceptions must only be used for abnormal conditions. Exceptions must not be used to 

redirect the flow of control in normal ("non-exceptional") conditions.

Discussion

"Intentional exceptions" cannot be used as a substitute for arbitrary branch. Normal, expected 

events, such as reaching the end of a file that is being read from beginning to end or receiving invalid 

input from a user interface, are not exceptional conditions and should not be implemented using 

exception handlers. 

Prior VVSG source: VVSG 2007 - 6.4.1.5-B.2

2.3.1-D – Unstructured exception handling

Unstructured exception handling (for example, On Error GoTo, setjmp/longjmp, or explicit 

tests for error conditions after every executable statement) is prohibited.

Discussion

The internal use of such constructs by a COTS extension package that adds block-structured 

exception handling to a programming language that otherwise would not have it, as described in 

requirement 2.3-B – Legacy library units, is allowed. Similarly, it is not a problem that source code 

written in a high-level programming language is compiled into low-level machine code that contains 

arbitrary branches. It is only the direct use of low-level constructs in application logic that presents a 

problem. 

Prior VVSG source: VVSG 2007 - 6.4.1.5-B.3
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2.4 - Voting system structure is modular, scalable, and robust.

2.4-A – Modularity 

Application logic must be designed in a modular fashion., meeting all the criteria stated in 

the definition of a module, namely that:

1. It must be a structural unit of software or analogous logical design.

2. If it contains callable units, those callable units must be tightly coupled.

3. Coupling between modules (“inter-module coupling”) must:

a. be loose, and

b. occur over defined interfaces.

4. It must contain all elements needed to compile or interpret successfully.

5. It must have limited access to data in other modules.

6. It must be substitutable with another module whose interfaces match the original 

module.

Discussion

The modularity rules described here apply to the component submodules of a library.

Prior VVSG source: VVSG 2007 - 6.4.1.4-A

2.4-B – Module testability 

Each module must have a specific function that can be tested and verified independently of 

the remainder of the code.

Discussion

In practice, some additional modules (such as library modules) can be needed to compile the module 

being tested, but the modular construction allows the supporting modules to be replaced by special 

test versions that support test objectives.

Prior VVSG source: VVSG 2007 - 6.4.1.4-A.1 

2.4-C – Module size and identification

Modules must be small and easily identifiable., such as being:
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1. no more than 50% of all callable units (functions, methods, operations, subroutines, 

procedures, etc.) SHOULD exceed 25 lines of code in length, excluding comments, 

blank lines, and initializers for read-only lookup tables; 

2. no more than 5% of all callable units SHOULD exceed 60 lines in length; and 

3. no callable units SHOULD exceed 180 lines in length.

Discussion

Prior VVSG source: VVSG 2007 - 6.4.1.4-B

"Lines," in this context, are defined as executable statements or flow control statements with 

suitable formatting.

2.4-D – Lookup tablesLarge data structures in separate files

Read-only lookup tableslarge data structures longer than 25 lines must be placed in separate 

files from other source code if the programming language permits it.

Prior VVSG source: VVSG 2007 - 6.4.1.4-B.2

Discussion

In practice, this case has often been illustrated by the need to put read-only large lookup tables into 

separate files. However, the same notion could apply to other kinds of data structures.
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2.5 - The voting system supports system processes and data with 

integrity.

2.5-A – Self-modifying code 

Application logic must not be self-modifying.

Prior VVSG source: VVSG 2007 - 6.4.1.7-A.1

2.5-B – Unsafe concurrency 

Application logic must be free of race conditions, deadlocks, livelocks, and resource 

starvation.

Prior VVSG source: VVSG 2007 - 6.4.1.7-A.2

Discussion

In addressing this requirement, information should be provided in the TDP describing the means by 

which safe concurrency was ensured relative to the design, implementation, and testing of the 

application logic.

2.5.1 – Code integrity

2.5.1-A – COTS compilers

If compiled code is used, it must only be compiled using a COTS compiler.

Discussion

This prohibits the use of arbitrary, nonstandard compilers and, consequently, the invention of new 

programming languages.

Prior VVSG source: VVSG 2007 - 6.4.1.7-A.3

2.5.1-B – Interpreted code, specific COTS interpreter

If interpreted code is used, it must only be run under a specific, identified version of a COTS 

runtime interpreter.

Discussion

This ensures that: 

• no arbitrary, nonstandard interpreted languages are used, and 
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• the software tested and approved during the conformity assessment process does not change 

behavior because of a change to the interpreter.

Prior VVSG source: VVSG 2007 - 6.4.1.7-A.4

2.5.1-C – Prevent tampering with code

Programmed devices must prevent replacing or modifying executable or interpreted code 

(for example, by other programs on the system, by people physically replacing the memory 

or medium containing the code, or by faulty code) except where this access is necessary to 

conduct the voting process.

Discussion

This requirement can be partially satisfied through a combination of:

• read-only memory (ROM), 

• the memory protection implemented by most popular COTS operating systems, 

• error checking, and 

• access and integrity controls.

Prior VVSG source: VVSG 2007 - 6.4.1.7-B

2.5.1-D – Prevent tampering with data

All voting devices must prevent access to or manipulation of configuration data, vote data, or 

audit records (for example, by physically tampering with the medium or mechanism 

containing the data, by other programs on the system, or by faulty code) except where this 

access is necessary to conduct the voting process.

Discussion

This requirement can be partially satisfied through a combination of:

• the memory protection implemented by most popular COTS operating systems, 

• error checking, and 

• access and integrity controls. 

Systems using mechanical counters to store vote data need to protect the counters from tampering. 

If vote data are stored on paper, the paper needs to be protected from tampering. Modification of 

audit records after they are created is never necessary.

Prior VVSG source: VVSG 2007 - 6.4.1.7-C
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2.5.2 – Input/output errors

2.5.2-A – Monitoring- Input validation and defending for I/O errorserror 

defense

Programmed devices must provide the capability to monitor the transfer quality of I/O 

operations, reporting the number and types of errors that occur and how they were 

corrected.

Prior VVSG source: VVSG 2007 - 6.4.1.7-D

2.5.2-B – Validate and filter input

The voting system must: 

1. monitor I/O operations;

1.2. validate all input against expected parameters, such as data presence, length, 

type, format, uniqueness, or inclusion in a set of whitelisted values.; 

3. report any input errors and how they were corrected; and

4. check information inputs to ensure that incomplete or invalid inputs do not lead to 

irreversible error.

Discussion

Input includes data from any input source: input devices (such as touchscreenstouch screens, 

keyboards, keypads, optical/digital scanners, and assistive devices), networking port, data port, or 

file. 

Prior VVSG source: VVSG 2007 - 6.4.1.8-A.1 

2.5.2-C – Detect garbage input

Programmed devices must check information inputs for completeness and validity.

Discussion

This general requirement applies to all programmed devices, while the specific ones following are 

only enforceable for application logic.

Prior VVSG source: VVSG 2007 - 6.4.1.8-A

2.5.2-D – Defend against garbage input

Programmed devices must ensure that incomplete or invalid inputs do not lead to 

irreversible error.
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Prior VVSG source: VVSG 2007 - 6.4.1.8-A.1 

2.5.3 – Output protection

2.5.3-A – Escaping and encoding output 

Software output must be properly encoded, escaped, and sanitized.

Discussion

The output of a software module can be manipulated or abused by attackers in unexpected ways to 

perform malicious actions. Ensuring that outputted data is of an expected type or format assists in 

preventing this abuse. Additional information about this software weakness can be viewed in CWE 

116: Improper Encoding or Escaping of Output.at MITRE CWE 116: Improper Encoding or Escaping of 

Output [MITRE20c].

External sources: CWE 116: Improper Encoding or Escaping of Output

2.5.3-B – Sanitize output

The voting system must sanitize all output to remove or neutralize the effects of any escape 

characters, control signals, or scripts contained in the data which could adversely manipulate 

the output source.

Discussion

Output includes data to any output source: output devices (such as touchscreenstouch screens, LCD 

screens, printers, and assistive devices), networking port, data port, or file. This applies to all parts of 

the voting system including the election management system (EMS).

2.5.3-C – Stored injection

The voting system must sanitize all output to files and databases to remove or neutralize the 

effects of any escape characters, control signals, or scripts contained in the data which could 

adversely manipulate the voting system if the stored data is read or imported at a later date 

or by another part of the voting system.

Discussion

A stored injection attack saves malicious data which is harmless when stored, but which is potent 

when read later in a different context or when converted to a different format. For example, a 

malicious script might be written to a file and do no harm to the voting machine, but later be 
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evaluated and harmful when the file is transferred and read by the EMS. Input should also be filtered, 

but sanitizing stored output provides defense in depth.

2.5.4 – Error handling

2.5.4-A – Mandatory internal error checking

Application logic that is vulnerable to the following types of errors must check for these 

errors at run time and respond defensively when they occur: 

1. common memory management errors, such as out-of-bounds accesses of arrays, 

strings, and buffers used to manage data;

2. uncontrolled format strings;

3. CPU-level exceptions such as address and bus errors, dividing by zero, and the like;

4. variables that are not appropriately handled when out of expected boundaries;

5. numeric and integer overflows;

6. validation of array indices; and

7. known programming language specific vulnerabilities.

Discussion

Logic verification will show that some error checks cannot logically be triggered, and some exception 

handlers cannot logically be invoked. These checks and exception handlers are not redundant – they 

provide defense-in-depth against faults that escape detection during logic verification.

Prior VVSG source: VVSG 2007 - 6.4.1.8-B

2.5.4-B – Array overflows

If the application logic uses arrays, vectors, or any analogous data structures, and the 

programming language does not provide automatic run-time range checking of the indices, 

the indices must be ranged-checked on every access.

Discussion

Range checking code should not be duplicated before each access. Clean implementation approaches 

include: 

• consistently using dedicated accessors (such as functions, methods, operations, subroutines, 

and procedures) that range-check the indices;

• defining and consistently using a new data type or class that encapsulates the range-checking 

logic;
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• declaring the array using a template that causes all accessors to be range-checked; or

• declaring the array index to be a data type whose enforced range is matched to the size of the 

array.

Range-enforced data types or classes can be provided by the programming environment or they can 

be defined in application logic. If acceptable values of the index do not form a contiguous range, a 

map structure can be more appropriate than a vector.

2.5.4-C – Buffer overflows 

If an overflow does not automatically result in an exception, the application logic must 

explicitly check for and prevent the overflow.

2.5.4-D – CPU traps

The application logic must implement such handlers as needed to detect and respond to 

CPU-level exceptions.

Discussion

For example, under Unix, a CPU-level exception would manifest as a signal, so a signal handler is 

needed. If the platform supports it, it is preferable to translate CPU-level exceptions into softwarelevel exceptions so that all exceptions can be handled in a consistent fashion within the voting 

application. However, not all platforms support it.

2.5.4-E – Garbage input parameters

All scalar or enumerated type parameters whose valid ranges as used in a callable unit (such 

as function, method, operation, subroutine, and procedure) do not cover the entire ranges 

of their declared data types must be range-checked on entry to the unit.

Discussion

This applies to parameters of numeric types, character types, temporal types, and any other types for 

which the concept of range is well-defined. In cases where the restricted range is frequently used or 

associated with a meaningful concept within the scope of the application, the best approach is to 

define a new class or data type that encapsulates the range restriction, eliminating the need for 

range checks on each use.

This requirement deals with user input that is expected to contain errors. User input errors are a 

normal occurrence; the errors discussed here are grounds for throwing exceptions.
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2.5.4-F – Numeric overflows

If the programming language does not provide automatic run-time detection of numeric 

overflow, all arithmetic operations that could potentially overflow the relevant data type 

must be checked for overflow.

Discussion

Encapsulate overflow checking as much as possible.

2.5.4-G – Uncontrolled format strings

Voting system software must not contain uncontrolled format strings. 

Discussion

Many examples of this vulnerability have previously been identified in voting system 

software. Prior VVSG source: VVSG 2007 - 6.4.1.8-B.1 

2.5.4-C – Buffer overflows 

If an overflow does not automatically result in an exception, the application logic must 

explicitly check for and prevent the overflow.

Prior VVSG sources: VVSG 2007 - 6.4.1.8-B.2 

2.5.4-D – CPU traps

The application logic must implement such handlers as needed to detect and respond to 

CPU-level exceptions.

Discussion

For example, under Unix, a CPU-level exception would manifest as a signal, so a signal handler is 

needed. If the platform supports it, it is preferable to translate CPU-level exceptions into softwarelevel exceptions so that all exceptions can be handled in a consistent fashion within the voting 

application. However, not all platforms support it.

Prior VVSG source: VVSG 2007 - 6.4.1.8-B.3 

2.5.4-E – Garbage input parameters

All scalar or enumerated type parameters whose valid ranges as used in a callable unit (such 

as function, method, operation, subroutine, and procedure) do not cover the entire ranges 

of their declared data types must be range-checked on entry to the unit.

Discussion
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This applies to parameters of numeric types, character types, temporal types, and any other types for 

which the concept of range is well-defined. In cases where the restricted range is frequently used or 

associated with a meaningful concept within the scope of the application, the best approach is to 

define a new class or data type that encapsulates the range restriction, eliminating the need for 

range checks on each use.

This requirement deals with user input that is expected to contain errors. User input errors are a 

normal occurrence; the errors discussed here are grounds for throwing exceptions.

Prior VVSG source: VVSG 2007 - 6.4.1.8-B.4 

2.5.4-F – Numeric overflows

If the programming language does not provide automatic run-time detection of numeric 

overflow, all arithmetic operations that could potentially overflow the relevant data type 

must be checked for overflow.

Discussion

Encapsulate overflow checking as much as possible.

Prior VVSG source: VVSG 2007 - 6.4.1.8-B.5 

2.5.4-G – Uncontrolled format strings

Voting system software must not contain uncontrolled format strings. 

Discussion

Many examples of this vulnerability have previously been identified in voting system software. 

Additional information about this vulnerability can be found at CWE 134: Use of ExternallyControlled Format String.MITRE CWE 134: Use of Externally-Controlled Format String [MITRE20d].

2.5.4-H – Recommended internal error checking

Application logic that is vulnerable to the following types of errors must check for these 

errors at run time and respond defensively when they occur:

pointer variable errorsExternal reference: CWE 134: Use of Externally-Controlled 

Format String

2.5.4-H – Recommended internal error checking

Application logic that is vulnerable to the following types of errors must check for these 

errors at run time and respond defensively when they occur:

1. pointer variable errors, and
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2. dynamic memory allocation and management errors.

2.5.4-I – Pointers

If application logic uses pointers or a similar mechanism for specifying absolute memory 

locations, the application logic must validate these pointers or addresses before they are 

used.

Discussion

The goal is to prevent improper overwriting, even if read-only memory would prevent the overwrite 

from succeeding. An attempted overwrite indicates a logic fault that must be corrected.

Pointer use that is fully encapsulated within a standard platform library is treated as COTS software.

2.5.4-J – Memory mismanagement

If dynamic memory allocation is performed in application logic, the application logic must be 

able to be instrumented or analyzed with a COTS tool for detecting memory management 

errors.

Discussion

Dynamic memory allocation that is fully encapsulated within a standard platform library is treated as 

COTS software. 

2.5.4-K – Nullify freed pointers

If pointers are used, any pointer variables that remain within scope after the memory they 

point to is deallocated must be set to null or marked as invalid (pursuant to the idiom of the 

programming language used).

Discussion

If this is not done automatically by the programming environment, a callable unit should be 

dedicated to the task of deallocating memory and nullifying pointers. Equivalently, "smart pointers" 

like the C++ std::auto_ptr can be used to avoid the problem. One should not add assignments after 

every deallocation in the source code.

In languages using garbage collection, memory is not deallocated until all pointers to it have gone out 

of scope, so this requirement is moot.

2.5.4-L – React to errors detected

Detecting any of the errors enumerated in these requirements must be treated as a 

complete failure of the callable unit in which the error was detected. 
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1. An appropriate exception must be thrown, and 

2. Control must pass out of the unit immediately.

2.5.4-M – Election integrity monitoring

Electronic devices must proactively detect or prevent basic violations of election integrity (for 

example, stuffing the ballot box or accumulating negative votes) and alert an election official 

or administrator if they occur.

Discussion

Equipment can only verify those conditions that are within the scope of what the equipment does. 

However, if the equipment can detect something that is blatantly wrong, it should do so and raise the 

alarm. This provides defense-in-depth to supplement procedural controls and auditing practices.

2.5.4-N – SQL injection 

The voting system application must defend against SQL injection. 

Discussion

SQL injection is a classic type of software weakness still prevalent today. SQL injection is not just a 

web-based issue, as any application accepting untrusted user input and passing it to a database can 

be vulnerable. Additional information about this software weakness can be viewed at MITRE CWE 89: 

Improper Neutralization of Special Elements used in an SQL Command ('SQL Injection') [MITRE20e].

2.5.4-O – Parameterized queries 

Any structured statement or command being prepared using dynamic data (including user 

input) to be sent to a database or other process must parameterize the data inputs and 

apply strict type casting and content filters on the data (such as prepared statements).

Discussion

Parametrized queries are a common defense against this class of software weakness.
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2.6 - The voting system handles errors robustly and gracefully recovers 

from failure.

2.6-A – Surviving device failure

All systems must be capable of resuming normal operation following the correction of a 

failurePrior VVSG source: VVSG 2007 - 6.4.1.8-C 

2.5.4-I – Pointers

If application logic uses pointers or a similar mechanism for specifying absolute memory 

locations, the application logic must validate these pointers or addresses before they are 

used.

Discussion

The goal is to prevent improper overwriting, even if read-only memory would prevent the overwrite 

from succeeding. An attempted overwrite indicates a logic fault that must be corrected.

Pointer use that is fully encapsulated within a standard platform library is treated as COTS software.

Prior VVSG source: VVSG 2007 - 6.4.1.8-C.1

2.5.4-J – Memory mismanagement

If dynamic memory allocation is performed in application logic, the application logic must be 

able to be instrumented or analyzed with a COTS tool for detecting memory management 

errors.

Discussion

Dynamic memory allocation that is fully encapsulated within a standard platform library is treated as 

COTS software. 

Prior VVSG source: VVSG 2007 - 6.4.1.8-D 

2.5.4-K – Nullify freed pointers

If pointers are used, any pointer variables that remain within scope after the memory they 

point to is deallocated must be set to null or marked as invalid (pursuant to the idiom of the 

programming language used).

Discussion

If this is not done automatically by the programming environment, a callable unit should be 

dedicated to the task of deallocating memory and nullifying pointers. Equivalently, "smart pointers" 
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like the C++ std::auto_ptr can be used to avoid the problem. One should not add assignments after 

every deallocation in the source code.

In languages using garbage collection, memory is not deallocated until all pointers to it have gone out 

of scope, so this requirement is moot.

Prior VVSG source: VVSG 2007 - 6.4.1.8-E

2.5.4-L – React to errors detected

Detecting any of the errors enumerated in these requirements must be treated as a 

complete failure of the callable unit in which the error was detected. 

1. An appropriate exception must be thrown, and 

2.1. Control must pass out of the unit immediately.

Prior VVSG source: VVSG 2007 - 6.4.1.8-F

2.5.4-M – Election integrity monitoring

To the extent possible, Electronic devices must proactively detect or prevent basic violations 

of election integrity (for example, stuffing the ballot box or accumulating negative votes) and 

alert an election official or administrator if they occur.

Discussion

Equipment can only verify those conditions that are within the scope of what the equipment does. 

However, if the equipment can detect something that is blatantly wrong, it should do so and raise the 

alarm. This provides defense-in-depth to supplement procedural controls and auditing practices.

Prior VVSG source: VVSG 2007 - 6.4.1.8-K

2.5.4-N – SQL injection 

The voting system application must defend against SQL injection. 

Discussion

SQL injection is a classic type of software weakness still prevalent today. SQL injection is not just a 

web-based issue, as any application accepting untrusted user input and passing it to a database can 

be vulnerable. Additional information about this software weakness can be viewed in within CWE 89: 

Improper Neutralization of Special Elements used in an SQL Command ('SQL Injection').

External source: CWR 89: Improper Neutralization of Special Elements used 

in an SQL Command (‘SQL Injection’)
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2.5.4-O – Parameterized queries 

Any structured statement or command being prepared using dynamic data (including user 

input) to be sent to a database or other process must parameterize the data inputs and 

apply strict type casting and content filters on the data (such as prepared statements).

Discussion

Parametrized queries are a common defense against this class of software weakness.
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2.6 - The voting system handles errors robustly and gracefully recovers 

from failure.

2.6-A – Surviving device failure

All systems must be capable of resuming normal operation following the correction of a 

failure in any device.

Prior VVSG source: VVSG 2007 - 6.4.1.9-A

2.6-B – No compromising voting or audit data

Exceptions and system recovery must be handled in a manner that protects the integrity of 

all recorded votes and audit log information.

Prior VVSG source: VVSG 2007 - 6.4.1.9-A

2.6-C – Surviving component failure

All voting devices must be capable of resuming normal operation following the correction of 

a failure :

1. in any device;

1.2. in any component (for example, memory, CPU, ballot reader, or printer) 

provided that catastrophic electrical or mechanical damage has not occurred.; and

3. in a controlled fashion so that system status can be restored to the initial state 

existing before the error occurred.

Discussion

"Initial state" refers to the state existing at the start of a logical transaction or operation. Transaction 

boundaries must be defined in a conscientious fashion to minimize the damage. The final state is 

optional because election officials responding to the error condition might want the opportunity to 

select a different state, such as a controlled shutdown with memory dump for later analysis.

2.6-B – No compromising voting or audit data

Exceptions and system recovery must be handled in a manner that protects the integrity of 

all recorded votes and audit log information.

Prior VVSG source: VVSG 2007 - 6.4.1.9-C
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2.6-D – Controlled recovery

2.1. Error conditions must be corrected in a controlled fashion so that system status 

can be restored to the initial state existing before the error occurred.

Discussion

"Initial state" refers to the state existing at the start of a logical transaction or operation. Transaction 

boundaries must be defined in a conscientious fashion to minimize the damage. The final state is 

optional because election officials responding to the error condition might want the opportunity to 

select a different state, such as a controlled shutdown with memory dump for later analysis.

Prior VVSG source: VVSG 2007 - 6.4.1.9-D

2.6-E – Nested error conditions

Nested error conditions that are corrected without reset, restart, reboot, or shutdown of the 

voting device must be corrected in a controlled sequence so that system status can be 

restored to the initial state existing before the first error occurred.

Prior VVSG source: VVSG 2007 - 6.4.1.9-D.1

2.6-F – Reset CPU error states

CPU-level exceptions that are corrected without reset, restart, reboot, or shutdown of the 

voting device must be handled in a manner that restores the CPU to a normal state and 

allows the system to log the event and recover as with a software-level exception.

Discussion

System developers should test to see how CPU-level exceptions are handled and make any changes 

necessary to ensure robust recovery. Invocation of any other error routine while the CPU is in an 

exception handling state is to be avoided – software error handlers often do not operate as intended 

when the CPU is in an exception handling state.

If the platform supports it, it is preferable to translate CPU-level exceptions into software-level 

exceptions so that all exceptions can be handled in a consistent fashion within the voting application. 

However, not all platforms support it.

Prior VVSG source: VVSG 2007 - 6.4.1.9-D.2

2.6-GC – Coherent checkpoints

When recovering from non-catastrophic failure of a device or from any error or malfunction 

that is within the operator's ability to correct, the system must restore the device to the 

operating conditionlast known good state existing immediately before the error or failure, 

without loss or corruption of voting data previously stored in the device.
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Discussion

If the system is left in something other than the last known good state for diagnostic reasons, this 

requirement clarifies that it must revert to the last known good state before being placed back into 

service.

2.7 - The voting system performs reliably in anticipated physical 

environments.

Discussion

If the system is left in something other than the last known good state for diagnostic reasons, this 

requirement clarifies that it must revert to the last known good state before being placed back into 

service.

Prior VVSG source: VVSG 2007 - 6.4.1.9-E

2.7 - The voting system performs reliably in anticipated physical 

environments.

Requirements in this section deal with voting system reliability with regard to environmental 

conditions and electrical surges and interference. 

2.7-A – Assessment of reliability

The voting system’s reliability must be assessed using a combination of evidence items 

gathered during the entire course of testing, including:

1. continuous operation of the voting system under typical environmental conditions;

2. continuous operation of the voting system under varied environmental conditions 

across defined ranges; and

3. resistance of the voting system to electrical surges, interference, and loss of power.

Discussion

As with accuracy, reliability cannot be positively ascertained; a judgment of reliability has to be 

determined from evidence. In this case, a volume test [CA06] is used during various environmental 

conditions to determine the reliability of the voting system operations, as well as data from the test 

campaign regarding relevant VVSG requirements. 
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2.7-B – Continuous operation – typical environmental conditions

The voting system must operate for a continuous period of time during which ballots are cast 

and ballot positions are read and tabulated without error.

2.7-C – Continuous operation – varied environmental conditions

The voting system must operate for a continuous period of time during which ballots are cast 

and ballot positions are read and tabulated without error and in which temperature and 

humidity are varied.

2.7-D – Ability to support maintenance and repair physical environment 

conditions – non-operating

AllThe voting systemssystem must be able to withstand non-operating physical 

environmental conditions exercised in accordance with MIL-STD-810H, Method 516.6. 

Procedure VI [MIL19].

simulatingDiscussion

This test simulates stresses facedthat occur during maintenance and repair.

External reference MIL-STD-810H

Prior VVSG source: VVSG-2007 - 5.1.4-A.1

2.7-BE – Ability to support transport and storage physical environment 

conditions – non-operating

All voting systemsThe voting system must be able to withstand non-operating physical 

environmental conditions simulating stresses that occur during transport between storage 

locations and polling places.

2.7-F – Ability to support storage temperatures in physical environment –

non-operating

The voting system must be able to withstand non-operating physical environmental 

conditions exercised in accordance with MIL-STD-810H, Method 514.6, Category 4—

Truck/trailer - secured cargo, 2.1.3.1 Truck transportation over U. S. highways [MIL19].

simulatingDiscussion

This test simulates stresses faced during transport between storage locations and polling places. 

External reference MIL-STD-810H

Prior VVSG source: VVSG-2007 - 5.1.4-A.2
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2.7-C – Ability to support storage temperatures in physical environment –

non-operating

All voting systems must be able to withstand non-operating physical environmental 

conditions exercised in accordance with MIL-STD-810H: Method 502.5, Procedure I –

Storage, and Method 501.5, Procedure I – Storage. The minimum temperature shall be -20 

degrees C (-4 degrees F), and the maximum temperature shall be 60 degrees C (140 degrees 

F) [MIL19].

-related and humidity-relatedDiscussion

This test simulates stresses facedthat occur during storage.

External reference MIL-STD-810H

Prior VVSG source: VVSG-2007 - 5.1.4-A.3

2.7-D – Ability to support storage humidity levels in physical environment –

non-operating

All voting systems must be able to withstand non-operating physical environmental 

conditions exercised in accordance with humidity testing specified by MIL-STD-810H: 

Method 507.5, Natural Hot-humid (Cycle B3), with test conditions that simulate a storage 

environment. [MIL19].

Discussion

This test is intended to evaluate the ability of voting equipment to survive exposure to an 

uncontrolled temperature and humidity environment during storage. 

External reference MIL-STD-810H

Prior VVSG source: VVSG-2007 - 5.1.4-A.4

2.7-E – Ability to operate as intended at low and high temperatures -

operating

All voting systems must be able to withstand operating physical environmental conditions 

exercised in the low temperature and high temperature testing specified by MIL-STD-810H: 

Method 502.5, Procedure II–Operation and Method 501.5, Procedure II–Operation, with test 

conditions that simulate system operation [MIL19].

External reference MIL-STD-810H

Prior VVSG source: VVSG-2007 - 5.1.5-A.1
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2.7-F – Ability to operate as intended at specified humidity conditions -

operating

All voting systems must be able to withstand operating physical environmental conditions 

exercised in the humidity testing specified by MIL-STD-810-H: Method 507.5 with test 

conditions that simulate system operation [MIL19].

Prior VVSG source: VVSG-2007 - 5.1.5-A.2

2.7.1 – Ability to withstand 2.7-G – Electrical disturbances

2.7.1-A – Electrical disturbances

AllThe voting devicessystem must continue to operate in the presence of electrical 

disturbances generated by other devices and people and must not cause electrical disruption 

to other devices and people.

Discussion

Voting devices located in a polling place or other places need to continue to operate despite 

disruption from electrical emanations generated by other devices, including static discharges from 

people. Likewise, voting devices need to operate without causing disruption to other devices and 

people due to electrical emanations from the devices.

2.7.1-B – FCC Part 15 Class A and B conformance

Voting devices must comply with the requirements of the Federal Communications 

Commission, Part 15:

1. Voting devices located in polling places must comply with Class B requirements.

2. Voting devices located in non-place setting, such as back offices, must minimally 

comply with Class A requirements. 

2.7.1-C – Power supply from energy service provider

Voting devices located in polling places must be powered by a 120 V, single phase power

supply derived from typical energy service providers. 

Discussion

It is assumed that the AC power necessary to operate the voting system will be derived from the 

existing power distribution system of the facility housing the polling place. This single-phase power 
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may be a leg of a 120/240 V single phase system, or a leg of a 120/208 V three-phase system, at a 

frequency of 60 Hz.

2.7.1-D – Power port connection to the facility power supply

All electronic voting systems installed in a polling place must comply with Class B emission 

limits affecting the power supply connection to the energy service provider.

Discussion

The normal operation of an electronic system can produce disturbances that will travel upstream and 

affect the power supply system of the polling place, creating a potential deviation from the expected 

electromagnetic compatibility of the system. The issue is whether these actual disturbances (after 

possible mitigation means incorporated in the equipment) reach a significant level to exceed 

stipulated limits.

2.7.1-E – Leakage from grounding port

All electronic voting systems installed in a polling place must comply with limits of leakage 

currents effectively established by the trip threshold of all listed Ground Fault Current 

Interrupters (GFCI), if any, installed in the branch circuit supplying the voting system.

Discussion

Excessive leakage current is objectionable for two reasons:

• For a branch circuit or wall receptacle that could be provided with a GFCI (depending upon the 

wiring practice applied at the particular polling place), leakage current above the GFCI built-in 

trip point would cause the GFCI to trip and therefore disable the operation of the system.

• Should the power cord lose the connection to the equipment grounding conductor of the 

receptacle, a personnel hazard would occur. (Note the prohibition of “cheater” adapters in the 

discussion of general requirements for the polling place.)

2.7.1-F –-H – Power outages, sags, and swells

All electronicThe voting systemssystem must be able to withstand, without disruption of 

normal operation or loss of data, a complete loss of power lasting two hours.

Discussion

The Information Technology industry has adopted a recommendation that IT equipment should be 

capable of operating correctly for swells reaching 120 % of the nominal system voltage with duration 

ranging from 3 ms to 0.5 s and permanent overvoltages up to 110 % of nominal system voltage.

Essentially, battery backup must keep the voting system operational so that voting can continue for a 

minimum of two hours.
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2.7.1-G-I – Withstand conducted electrical disturbances

All electronic voting systems must withstand conducted electrical disturbances that affect 

the power ports of the system.

2.7.1-H-J – Emissions from other connected equipment

All elements of an electronic voting system must be able to withstand the conducted 

emissions generated by other elements of the voting system.

2.7.1-I-K – Electrostatic discharge immunity

All electronic voting systems must withstand, without disruption of normal operation or loss 

of data, electrostatic discharges (ESD) associated with human contact and contact with 

mobile equipment (such as service carts and wheelchairs).

Discussion

ESD events can originate from direct contact between an “intruder” (person or object) charged at a 

potential different from that of the units of the voting system, or from an approaching person about 

to touch the equipment – an “air discharge.” The resulting discharge current can induce disturbances 

in the circuits of the equipment. This requirement is meant to ensure that voting devices are 

conformant to the typical ESD specifications met by other electronic devices used by the public such 

as ATMs and vending kiosks.
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2.7.1-J – Radiated radio frequency emissions

All electronic voting systems installed in a polling place must comply with emission limits 

according to the Rules and Regulations of Class B for radiated radio-frequency emissions.

Discussion

Electronic equipment in general and modern high-speed digital electronic circuits in particular have 

the potential to produce unintentional radiated and conducted radio-frequency emissions over wide 

frequency ranges. These unintentional signals can interfere with the normal operation of other 

equipment, especially radio receivers, in close proximity. 

Principle 3

Transparent

The voting system and voting processes are designed to provide 

transparency. 

3.1 - The documentation describing the voting system design, 

operation, accessibility features, security measures, and other aspects 

of the voting system can be read and understood. 

3.2 - The processes and transactions, both physical and digital, 

associated with the voting system are readily available for inspection. 
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3.3 - The public can understand and verify the operations of the voting 

system throughout the entirety of the election.

Principle 3

TRANSPARENT

The voting system and voting processes are designed to provide 

transparency.

Guideline 3.1 contains requirements for the documentation that manufacturers supply to 

jurisdictions that use their systems. In this context, "user" refers to election officials, and 

"system" refers to a voting system or individual voting device. The user documentation is 

also included in the technical date package (TDP) given to test labs. The sections in 3.1 cover

1 - System overview documentation covers documentation that explains the physical and 

logical structure of the system, its components, how it is structured, details about the 

software, and so forth. 

2 - System performance documentation gives details on how the system performs in normal 

operation as well as its constraints and limits.
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3 - System security documentation describes the features of the system that provide or 

contribute to its security and includes how to operate the system securely. Physical security 

and audit are included in this documentation.

4 - Software installation documentation describes in exact detail what software is installed, 

how it is installed, and how it is to be maintained.

5 - System operations documentation deals with operating and using the equipment to 

conduct elections, including setup, testing, voting operations, reporting, and so forth.

6 - System maintenance documentation deals with proper maintenance of the voting 

equipment and how to correct various issues or problems.

7 - Training material documentation lists what the manufacturer needs to cover about the 

personnel resources and training required for a jurisdiction to operate and maintain the 

system.

8 - Training documentation lays out various information that would be important when 

training users on the voting equipment. 

It is not the intent of these requirements to prescribe an outline for user documentation. 

Manufacturers are encouraged to innovate in the quality and clarity of their user 

documentation.

In 3.2, Setup inspection documentation explains how to verify that the system is properly 

setup and configured, and how to monitor its operations.

In 3.3, Public documentation requirements cover details of how a manufacturer codes the 

election event log, implements a CDF, builds barcodes, and implements audits.

3.1 – The documentation describing the voting system design, 

operation, accessibility features, security measures, and other 

aspects of the voting system can be read and understood.

3.1.1 – System overview documentation

3.1.1-A – System overview documentation

In the system overview, The manufacturer must provide informationsystem overview

documentation that enables the user to identifyidentifies the functional and physical 

components of the system, how the components are structured, and the interfaces between 

them.
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3.1.1-B – System overview, functional diagram

The System overview documentation must include a high-level functional diagramdiagrams

of the voting system that includesinclude all of its components. The diagramdiagrams must 

portray how the various components relate and interact.

Discussion

The diagrams could be engineering renderings or photographs.

3.1.1-C – System description

The system descriptionSystem overview documentation must include written descriptions, 

drawings, and diagrams that present the following, as applicable: 

1. a description of the functional components (or subsystems) as defined by the 

manufacturer (for example, environment, election management and control, vote 

recording, vote conversion, reporting, and their logical relationships));

2. a description of the operational environment of the system that provides an 

overview of the hardware, firmware, software, and communications structure;

3. a concept of operations that explains each system function and how the function 

is achieved in the design;

4. descriptions of the functional and physical interfaces between components;

5. identification of all COTS products (both hardware and software) included in the 

system or used as part of the system's operation, identifying the name, 

manufacturer, and version used for each such component;

6. communications (dial-up, network) software;

7. interfaces among internal components and interfaces with external systems;

8. for components that interface with other components for which multiple 

products may be used, file specifications, data objects, or other means used for 

information exchange including the public standard used for such file 

specifications, data objects, or other means; and

9. benchmark directory listings for all software, firmware, and associated 

documentation included in the manufacturer's release in the order in which each 

piece of software or firmware would normally be installed upon system setup and 

installation.

Discussion

The diagrams could be engineering renderings or photographs.
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3.1.1-D – Identify software and firmware by origin

The System overview documentation must include thefull identification of all software and 

firmware items, indicating items that were: 

1. written in-house including subcontracted;

1. written by a subcontractor

2. procured as COTS, unmodified; and

3. procured as COTS and modified, including descriptions of the modifications to the 

software or firmware and to the default configuration options.

Description

Full identification would include authorship, version numbers, where procured, and other items to 

positively identify the COTs or in-house developed software

3.1.1-E – Traceability of procured software

The system descriptionSystem overview documentation must include a declaration that 

procured software items were obtained directly from the manufacturer or a licensed dealer 

or distributor.

Discussion

For most noncommercial software, this would mean a declaration that the software was downloaded 

from the canonical site or a trustworthy mirror. It is generally accepted practice for the core 

contributors to major open-source software packages to digitally sign the distributions. Verifying 

these signatures provides greater assurance that the package has not been modified.

3.1.2 – System performance documentation

3.1.2-A – System performance documentation

The manufacturer must provide system performance information including:documentation 

that includes:

1. device capacities and limits that were stated in the implementation statement;

2. if not already covered in the implementation statement, performance 

characteristics of each operating mode and function in terms of expected and 

maximum speed, throughput capacity, maximum volume (maximum number of 
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voting positions and maximum number of ballot styles supported), and processing 

frequency;

3. quality attributes such as reliability, maintainability, availability, usability, and 

portability;

4. provisions for safety, security, privacy, and continuity of operation; and

5. design constraints, applicable standards, and compatibility requirements.

3.1.2-B – Maximum tabulation rate

The System performance documentation must include the maximum tabulation rate for a 

bulk-fed scanner must be documented by the manufacturer. This documentation must 

include the maximum tabulation rate for individual components that impact the overall 

maximum tabulation rate.

Discussion

The capacity to convert the marks on individual ballots into signals is uniquely important to central 

count systems.

3.1.2-C – Reliably detectable marks

For anSystem performance documentation must include, for all types of optical scanner, the 

manufacturer must document scanners:

1. what constitutes a reliably detectable mark versusthat is tabulatable;

2. what constitutes a mark that is ambiguous and may require adjudication; and

3. what constitutes a marginal mark that would not be tabulatable.

Discussion

Marginal marks could include those marks considered as stray or caused by defects or folds on the 

ballot.

3.1.2-D – Processing capabilities

The manufacturerSystem performance documentation must provideinclude a listing of the 

system's functional processing capabilities, encompassing capabilities required by the VVSG, 

and any additional capabilities provided by the system, with a description of each capability. 

Therefore, this documentation must include the following attributes:

1. The manufacturer must explainan explanation regarding the capabilities of the 

system that were declared in the implementation statement.;
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2. additional capabilities (extensions) must be clearly indicated.;

3. required capabilities that may be bypassed or deactivated during installation or 

operation by the user must be clearly indicated.;

4. additional capabilities that function only when activated during installation or 

operation by the user must be clearly indicated.; and

5. additional capabilities that normally are active but may be bypassed or 

deactivated during installation or operation by the user must be clearly indicated.

3.1.3 – System security documentation

3.1.3-A – System security documentation

The manufacturerManufacturers must provide a specific system security document that 

includes detailed information that enableson the user to understand thesecurity architecture 

of the voting system and its security-related functions and how users are to properly employ 

them.

Discussion

This document is intended to further ensure transparency of the system and voting system. It 

includes a complete specification of the voting system security architecture, its different 

components, and how they are to bework together when used properly. Information about securityrelated functions and components may also appear in other parts of the TDP as applicable but should 

also appear in this document. The document may contain detailed technical information but also is 

to contain usage instructions for employing security controls that are written clearly for the intended 

types of users, e.g., administrator, pollworker, etc.

3.1.3-B – Access control implementation

Manufacturers must provide user documentation containing:

The system security document must include:

1. guidelines and usage instructions on implementing, configuring, and managing 

access control capabilities;

2. an access control policy template or instructions to facilitate the implementation 

of the access control policy and associated access controls on the voting system;

3. an access control policy under which the voting system was designed to operate 

and a description of the hazards of deviating from this policy; and

4. information on all privileged accounts included on the voting system.
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Discussion

Access control policy requirements include the minimum baseline policy definitions necessary for 

testing and implementing the voting system. The policies may be defined within the voting system or 

provided as guidelines in the documentation. The access control policy includes the assumptions that 

were made when the system was designed, the justification for the policy, and the hazards of 

deviating from the policy. Information on privileged accounts include the name of the account, 

purpose, capabilities, and permissions, and how to disable the account in the user documentation.

3.1.3-C – Physical security

ManufacturersThe system security document must provide user documentation 

explaininginclude an explanation of how to implement all physical security controls for 

voting devices and other security-sensitive components of the voting devicesystem, including 

model procedures necessary for effective use of countermeasures.

3.1.3-D – Audit procedures

The manufacturersystem security document must provide information that enables the 

userinclude an explanation of how to conduct audit procedures to determine whether 

tabulation is accurate.

3.1.3-E – Risk Analysis

The manufacturer must provide a report of a risk analysis for the voting system that contains 

a list of possible threats, risks of threat occurrence, and mitigation strategies employed by 

the voting system.

3.1.4 – Software installation documentation

3.1.4-A – Software installation documentation

The manufacturer must provide a list ofsoftware installation documentation that lists all 

software to be installed on the programmed devices of the voting system and the installation 

software used to install the software in the user documentation.

Discussion

Software to be installed on programmed devices of the voting system includes executable code, 

configuration files, data files, and election specific software.
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3.1.4-B – Software information

The manufacturer must provide at a minimum in the userSoftware installation

documentation must include the following information for each piece of software to be 

installed or used to install software on programmed devices of the voting system: 

1. software product name;

2. software version number

3. software manufacturer name;

4. software manufacturer contact information;

5. type of software (application logic, border logic, third party logic, COTS software, 

or installation software));

6. list of software documentation; and

7. component identifiers (such as filenames) of the software, and type of software 

component (executable code, source code, or data)).

8. flag to indicate whether or not the given software product should be considered 

“election-specific” (e.g., election-specific=[True|False]) to differentiate software 

used for implementing essential election application logic functions (such as 

counting) from more generic software (such as generic file-system functions).

3.1.4-C – Software location information 

The manufacturer must provide in the userSoftware installation documentation must include

the location (such as full path name or memory address) and storage device (such as type 

and part number of storage device) where each piece of voting system software is installed 

on programmed devices of the voting system.

Discussion

This requirement applies to voting system software installed on programmed devices of the voting 

system. The full directory path is the final destination of the software when installed on non-volatile 

storage with a file system.

3.1.4-D – Election specific software identification 

The manufacturerSoftware installation documentation must identify election specific 

software in the user documentation.

Discussion
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This requirement applies to voting system software installed on programmed devices of the voting 

system. If the documentation can provide information (such as what is indicated in item 8 from 

3.1.4-B – Software information) then this should be sufficient to clearly distinguish those pieces of 

software that perform essential election functions (such as counting) from those that perform more 

generic, non-election-specific tasks (such as those that might perform only general file-system 

operations, regardless of election concerns).

3.1.4-E – Installation software and hardware

The manufacturer must provideSoftware installation documentation must include a list of 

software and hardware required to install software on programmed devices of the voting 

system in the user documentation.

3.1.4-F – Software installation procedureprocedures

The manufacturer must documentSoftware installation documentation must include the 

software installation procedures used to install software on programmed devices of the 

voting system in user documentation.

3.1.4-G – Compiler installation prohibited

The software installation procedures used to install software on programmed devices of the 

voting system must result in no compilers being installed on the programmed device.

3.1.4-H – Baseline binary image creation

To replicate programmed device configurations, the software installation procedures must 

create a baseline binary image of the initial programmed device configuration on an 

unalterable with storage media with and mechanism for verifying the image’s validity using a 

digital signature.

3.1.4-IH – Programmed device configuration replication

The software installation procedures must use the baseline binary image and associated 

digital signature and digital signature validation mechanism of the initial programmed device 

configuration on an unalterable storage mediavalidated image to replicate the configuration 

onto other programmed devices.

Discussion

The main point of this requirement is to ensure transitive immutability of a given device 

configuration (based on a valid, original image that corresponds to an original cryptographic 

signature). In this way, it seeks to ensure that the starting image that is used for the replication of an 
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image to a particular configuration or target device is the same as the one that was validated via 

digital signature mechanisms.

The process for dealing with varying details of alternative target platforms can be addressed with the 

use of modern deployment technologies to create configurable installation mechanisms. This is not 

uncommon for major software technology providers. Thus, technology providers will be expected to 

develop appropriate install and configuration mechanisms that can have configurable images that 

can be signed through this digital signature mechanism at the outset and when replicating to any 

target configuration to ensure that both the image and the mechanisms for transforming that image 

in a given target deployment environment have been understood and validated from the beginning.

The above descriptions are meant to provide a way to validate a much wider range of deployment 

scenarios than has been experienced in the past. As a result, it is not expected or intended that this 

process would necessarily require strictly binary images, but rather, configurable ones, with the 

configuration settings and mechanisms for installation and signature verification provided, signed, 

and validated from the beginning.

3.1.4-JI – Software installation record creation

The software installation procedures must specify the creation of a software installation 

record that includes at a minimum: 

1. a unique identifier (such as a serial number) for the record;

2. a list of unique identifiers of unalterable storage media associated with the record;

3. the time, date, and location of the software installation;

4. names, affiliations, and signatures of all people present;

5. copies of the procedures used to install the software on the programmed devices of 

the voting system;

6. the certification number of the voting system;

7. list of the software installed as well as associated digital signatures and mechanisms 

for installation and verification on programmed devices of the voting system; and

8. a unique identifier (such as a serial number) of the vote-capture device or election 

management system (EMS) which the software is installed.

Discussion

The purpose of this requirement is a continuation of 3.1.4-KI – Software installation record creation, to 

ensure transitive immutability from the original baseline image through a given installation process (i.e., 

installation of certified software).
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The requirement emphasizes the importance of the final act of performing an installation of certified 

software on a target system configuration. It is a requirement to ensure that this event have some 

means by which an appropriate record, attesting to the facts of the installation event itself, can be 

produced and can provide the given information.

Creators of software installation mechanisms and procedures are asked to provide information in their 

installation user documentation specifying the elements of this record and that it should be recorded in 

the event of a certified software installation.

Related requirements: 3.1.4-H – Programmed device configuration replication

3.1.4-J – Procurement of voting system software

The Software installation proceduresdocumentation must specifyinclude that voting system 

software be obtained from test labs ora trusted distribution repositoriesrepository.

Discussion

Distribution repositories provide software they receive to parties approved by the owner of the 

software.

3.1.4-LK – Open market procurement of COTS software

The Software installation proceduresdocumentation must specifyinclude that COTS software 

be obtained from the open market.

3.1.4-ML – Erasable storage media preparation

The Software installation proceduresdocumentation must specify how previously stored 

information on erasable storage media is removed before installing software on the media.

Discussion

The purpose of this requirement is to prepare erasable storage media for use by the programmed 

devices of the voting system. The requirement does not mandate the prevention of previously stored 

information leakage or recovery. Simply deleting files from file systems, flashing memory cards, and 

removing electrical power from volatile memory satisfies this requirement.

3.1.4-N – UnalterableM – Trusted storage media

The Software installation proceduresdocumentation must specify that unalterabletrusted

storage media be used to install software on programmed devices of the voting system.

Discussion

Trusted storage media can include read-only media.
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Previous VVSGs emphasized the use of unalterable storage media which is believed to be too 

restrictive in the current technological context. Instead, it is preferable that read-only storage be 

used. And, as indicated in related requirements, it is assumed that any use of media, transport, or use 

of original images be associated with a mechanism for verifying the cryptographic signatures of those 

original images.

Related requirements: 3.1.4-H – Programmed device configuration replication

3.1.4-I – Software installation record creation

3.1.5 – System operations documentation

3.1.5-A – Operations manualSystem operations documentation

TheManufacturers must provide a specific system operations manual must provide all 

information necessary for systemdocument for use by all personnel who support preelection and election preparation, polling place activities, and central counting activities, as 

applicable, with regard to all system functions and operations. It must: 

1. provide a detailed description of procedures required to initiate, control, and verify 

proper system operation;

2. provide procedures that clearly enable the operator to assess the correct flow of 

system functions (as evidenced by system-generated status and information 

messages);

3. provide procedures that clearly enable the administrator to intervene in system 

operations to recover from an abnormal system state;

4. define and illustrate the procedures and system prompts for situations where 

operator intervention is required to load, initialize, and start the system;

5. define and illustrate procedures to enable and control the external interface to the 

system operating environment if supporting hardware and software are involved. 

(This information is provided for the interaction of the system with other data 

processing systems or data interchange protocols.);

6. provide administrative procedures and off-line operator duties (if any) if they relate 

to the initiation or termination of system operations, to the assessment of system 

status, or to the development of an audit trail;

7. support successful election definition and software installation and control by 

central election officials;

8. provide a schedule and steps for the software and ballot installation, including a 

table outlining the key dates relative to the start of voting, events, and deliverables; 

and
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9. specify diagnostic tests that may be employed to identify problems in the system, 

verify the correction of problems, and isolate and diagnose faults from various 

system states.

Discussion

The nature of the instructions for operating personnel will depend upon the overall system design 

and required skill level of system operations support personnel.

3.1.5-B – Support training

The system operations manualdocument must containinclude all information that is required 

for the preparation of detailed system operating procedures and for the training of 

administrators, central election officials, election judges, and election workers.

3.1.5-C – Functions and modes

The manufactureroperations document must provideinclude a summary of system operating 

functions and modes to permit understanding of the system's capabilities and constraints.

3.1.5-D – Roles

The operations document must identify the roles of operating personnel must be identified 

and relatedrelate them to the operating modes of the system.

3.1.5-E – Conditional actions

The operations document must describe decision criteria and conditional operator functions 

(such as error and failure recovery actions) must be described.

3.1.5-F – References

3.1.5-F – References

The manufactureroperations document must also list all reference and supporting 

documents pertaining to the use of the system during election operations.

3.1.5-G – Operational environment

The manufactureroperations document must identify all facilities, furnishings, fixtures, and 

utilities that will be required for equipment operations, including a statement of all 

requirements and restrictions regarding: 
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1. environmental protection;

2. electrical service;

3. recommended auxiliary power;

4. telecommunications service; and

5. any other facility or resource required for the proper installation and operation of 

the system.

3.1.5-H – Readiness testing

The manufactureroperations document must provideinclude specifications for testing 

system installation and readiness.

Discussion

Readiness testing refers to steps that election officials can take after configuring equipment to 

establish that it was correctly configured. Logic and accuracy testing would be part of this.

3.1.5-I – Features

The manufactureroperations document must provideinclude documentation of system 

operating features that includes: 

1. detailed descriptions of all input, output, control, and display features accessible to 

the operator or voter;

2. examples of simulated interactions to facilitate understanding of the system and its 

capabilities;

3. sample data formats and output reports; and

4. illustration and description of all status indicators and information messages.

3.1.5-J – Operating proceduresSupport

The manufactureroperations document must provideinclude documentation of system 

operating procedures that: 

1. provides a detailed description of procedures required to initiate, control, and verify 

proper system operation

2. provides procedures that clearly enable the operator to assess the correct flow of 

system functions (as evidenced by system-generated status and information 

messages)
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3. provides procedures that clearly enable the administrator to intervene in system 

operations to recover from an abnormal system state

4. defines and illustrates the procedures and system prompts for situations where 

operator intervention is required to load, initialize, and start the system

5. defines and illustrates procedures to enable and control the external interface to the 

system operating environment if supporting hardware and software are involved. 

(This information is provided for the interaction of the system with other data 

processing systems or data interchange protocols.)

6. provides administrative procedures and off-line operator duties (if any) if they relate 

to the initiation or termination of system operations, to the assessment of system 

status, or to the development of an audit trail

7. supports successful ballot and program installation and control by central election 

officials

8. provides a schedule and steps for the software and ballot installation, including a 

table outlining the key dates, events, and deliverables

9. specifies diagnostic tests that may be employed to identify problems in the system, 

verify the correction of problems, and isolate and diagnose faults from various 

system states

3.1.5-K – Support

The manufacturer must provide documentation of system operating procedures that: 

1. defines the procedures required to support system acquisition, installation, and 

readiness testing

2.1. describes procedures for providing technical support, system maintenance, and 

correction of defects, and for incorporating hardware upgrades and new software 

releases; and

2. defines the procedures required to support system installation and readiness testing.

3.1.5-LK – Transportation and storage

The manufactureroperations document must include any special instructions for the care 

and handling of voting devices and any removable media or records for:

1. shipment;

2. storage; and
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3. archiving information.

3.1.6 – System maintenance documentation

3.1.6-A – System maintenance manualdocumentation

TheManufacturers must include system maintenance manual must providedocumentation 

that provides information to support election workers, information systems personnel, or 

maintenance personnel in adjusting or removing and replacing components or modules in 

the field.

Discussion

Technical documentation needed solely to support the repair of defective components or modules 

ordinarily done by the manufacturer or software developer is not required.

Election workers such as polling place workers may not be permitted to replace components, 

however in some cases they may be permitted to adjust them. Thus, the documentation should be 

geared to the appropriate personnel.

3.1.6-B – General contents

The manufacturerMaintenance documentation must describeinclude service actions 

recommended to correct malfunctions or problems, personnel and expertise required to 

repair and maintain the system, and equipment and materials facilities needed for proper 

maintenance.

3.1.6-C – Maintenance viewpoint

The manufacturerMaintenance documentation must describeinclude the structure and 

function of the hardware, firmware, and software for election preparation, programming, 

vote recording, tabulation, and reporting in sufficient detail to provide an overview of the 

system for maintaining and identifying faulty hardware or software.

3.1.6-D – Equipment overview details

The descriptionMaintenance documentation must include a concept of operations that fully 

describes such items as: 

1. electrical and mechanical functions of the equipment;

2. for paper-based systems, how ballot handling and reading processes are performed;
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3. for electronic vote-capture devices, how vote selection and ballot casting are 

performed;

4. how data transmission over a network is performed (if applicable));

5. how data are handled in the processor and memory units;

6. how data output is initiated and controlled; 

7. how power is converted or conditioned; and

8. how test and diagnostic information is acquired and used.

Discussion

The documentation should indicate how and when information is written from volatile to nonvolatile memory, including redundant storage.

3.1.6-E – Maintenance procedures

The manufacturerMaintenance documentation must describeinclude preventive and 

corrective maintenance procedures for hardware, firmware, and software.

3.1.6-F – Preventive maintenance procedures

The manufacturerMaintenance documentation must identify and describe: 

1. all required and recommended preventive maintenance tasks, including software and 

data backup, database performance analysis, and database tuning;

2. the number and skill levels of personnel required for each task;

3. the parts, supplies, special maintenance equipment, software tools, or other 

resources needed for maintenance; and

4. any maintenance tasks that must be coordinated with the manufacturer or a third 

party (such as coordination that may be needed for COTS used in the system)).

3.1.6-G – Troubleshooting procedures

The manufacturer must provide fault detection, fault isolation, correction procedures, and 

logic diagrams for all operational abnormalities identified by design analysis and operating 

experience.
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3.1.6-H – Troubleshooting procedure details

The manufacturerMaintenance documentation must identify specific procedures to be used 

in diagnosing and correcting problems in the system hardware, firmware, and software. 

Descriptions must include: 

1. steps to replace failed or deficient equipment;

2. steps to correct deficiencies or faulty operations in software or firmware;

3. modifications that are necessary to coordinate any modified or upgraded software or 

firmware with other modules;

4. number and skill levels of personnel needed to accomplish each procedure;

5. special maintenance equipment, parts, supplies, or other resources needed to 

accomplish each procedure; and

6. any coordination required with the manufacturer, or other party, for COTS.

3.1.6-IH – Special equipment

The manufacturerMaintenance documentation must identify and describe any special 

purpose test or maintenance equipment recommended for fault isolation and diagnostic 

purposes.

3.1.6-JI – Parts and materials

Manufacturers Maintenance documentation must provideinclude detailed documentation of 

parts and materials needed to operate and maintain the system.

3.1.6-KJ – Approved parts list

The manufacturerMaintenance documentation must provideinclude a complete list of 

approved parts and materials needed for maintenance.to operate and maintain the system.

This list must contain sufficient descriptive information to identify all parts by: 

1. type,

2. size,

3. value or range,

4. manufacturer's designation,

5. individual quantities needed, and

6. sources from which they may be obtained.
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3.1.6-LK – Marking devices

The manufacturerMaintenance documentation must identify specific marking devices that, if 

used to make the prescribed form of mark, produce readable marked ballots so that the 

system meets the performance requirements for accuracy.

Discussion

Includes pens or pencils and possibly a compatible ballot marking device (BMD).

3.1.6-ML – Approved manufacturers

Maintenance documentation must include a listing of sources and model numbers for 

marking devices manufactured by multiple external sources , the manufacturer must specify 

a listing of sources and model numbers that satisfy these requirements.

3.1.6-NM – Ballot stock specification

The manufacturerMaintenance documentation must:

1. specify the required paper stock, weight, size, shape, opacity, color, watermarks, field 

layout, orientation, size and style of printing, size, and location of vote response 

fields; and 

2. identify unique ballot styles, placement of alignment marks, ink for printing, and 

folding and bleed-through limitations for preparation of ballots that are compatible 

with the system.

3.1.6-ON – Ballot stock specification criteria

UserMaintenance documentation for optical scanners must include specifications for ballot 

materials to ensure that votes are read from only a single ballot at a time, without bleedthrough or transferal of marks from one ballot to another.

3.1.6-PO – Printer paper specification

UserMaintenance documentation for voting systems that include printers must include 

specifications of the paper necessary to ensure correct operation, and minimize jamming, 

and satisfy Requirement 2.1.1-E – Durability and 2.1.1-F – Durability of paper.

Discussion

This requirement covers all printers, either stand-alone or integrated with another device, regardless 

whether they are used for reporting, for logging, for voter verified paper records (VVPR), etc.
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Prior VVSG: Requirement Part 1:6.4.4-B and Requirement Part 1:6.5.1-

A.

Related requirements: 2.1.1-E – Durability, 2.1.1-F – Durability of paper

3.1.6-QP – System maintenance, maintenance environment

The manufacturerMaintenance documentation must identify all facilities, furnishings, 

fixtures, and utilities that will be required for equipment maintenance.

3.1.6-RQ – System maintenance, maintenance support and spares

ManufacturersMaintenance documentation must specifyidentify: 

1. recommended number and locations of spare devices or components to be kept on 

hand for repair purposes during periods of system operation;

2. recommended number and locations of qualified maintenance personnel who need 

to be available to support repair calls during system operation; and

3. organizational affiliation (for example, jurisdiction, manufacturer) of qualified 

maintenance personnel.

3.1.7 – Training materialdocumentation

3.1.7-A – Training manualdocumentation

The manufacturer must describe the personnel resources and training required for a 

jurisdiction to operate and maintain the system.

3.1.7-B – Personnel

The manufacturer must specify the number of personnel and skill levels required to perform 

each of the following functions: 

1. pre-election or election preparation functions (such as, entering an election, contest 

and candidate information, designing a ballot, and generating pre-election reports));

2. system operations for voting system functions performed at the polling place;

3. system operations for voting system functions performed at the central count facility;

4. preventive maintenance tasks;

5. diagnosis of faulty hardware, firmware, or software;
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6. corrective maintenance tasks; and

7. testing to verify the correction of problems.

3.1.7-C – User functions versus manufacturer functions

The manufacturer must distinguish which functions may be carried out by user personnel 

and which must be performed by manufacturer personnel.

3.1.7-D – Training requirements

The manufacturer must specify requirements for the orientation and training of 

administrators, central election officials, election judges, and election workers.

3.2 – The processes and transactions, both physical and digital, 

associated with the voting system are readily available for 

inspection.

3.2-A – Setup inspection process

The manufacturerManufacturers must specify aprovide setup inspection process 

documentation that includes the setup inspection process that the voting device was 

designed to support andincluding a description of the risks of deviating from the process in 

the user documentation.

Discussion

The setup inspection process provides a means to inspect various properties of voting devices as 

needed during the election process. 

3.2-B – Minimum properties included in the setup inspection process

The Setup inspection process documentation must at a minimum include:

1. inspecting voting system software;

2. inspecting storage locations that hold election information that changes during an 

election;

3. inspecting other voting device properties; and

4. executing logic and accuracy testing related to readiness of use in an election.
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3.2-C – Setup inspection record generation

The Setup inspection process documentation must describe the records that result from 

performing the setup inspection process.

3.2-D – Installed software identification procedure

The manufacturerSetup inspection process documentation must provideinclude the 

procedures to identify all software installed on programmed devices of the voting system in 

the user documentation.

Discussion

This requirement provides the ability to identify if the proper software is installed and that no other 

software is present on programmed devices of the voting system. This requirement covers software 

stored on storage media with or without a file system.

3.2-E – Software integrity verification procedure

The manufacturer must describeSetup inspection process documentation must include the 

procedures to verify the integrity of software installed on programmed devices of the voting 

system in the user documentation.

3.2-F – Election information value 

The manufacturerSetup inspection process documentation must provide the valuesinclude a 

list of voting device storage locations that holdfor holding election information that 

changescan change during the election, except for the static values set to conduct a specific 

election in the user documentation.

3.2-G – Maximum and minimum values of election information storage 

locations

The manufacturerSetup inspection process documentation must provideinclude the 

maximum and minimum values thatof voting device storage locations that holdfor holding

election information changesthat can change during an election can store in the user 

documentation.

3.2-H – Variable value inspection procedure

The manufacturerSetup inspection process documentation must provideinclude the 

procedures to inspect the values of voting device storage locations that holdfor holding
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election information that changes forcan change during an election in the user 

documentation.

3.2-I – Backup power operational range

The manufacturersSetup inspection process documentation must provideinclude the 

nominal operational range for the backup power sources of the voting device in the user 

documentation.

3.2-J – Backup power inspection procedure

The manufacturerSetup inspection process documentation must provideinclude the 

procedures to inspect the remaining charge of the backup power sources of the voting 

device in the user documentation.

3.2-K – Cabling connectivity inspection procedure

The manufacturerSetup inspection process documentation must provideinclude the 

procedures to inspect the connectivity of the cabling attached to the voting device in the 

user documentation.

3.2-L – Communications operational status inspection procedure

The manufacturer must provideSetup inspection process documentation must include the 

procedures to inspect the operational status of the communications capabilities of the voting 

device in the user documentation.

3.2-M – Communications on/off status inspection procedure

The manufacturer must provide Setup inspection process documentation must include the 

procedures to inspect the on/off status of the communications capabilities of the voting 

device in the user documentation.

3.2-N – Quantity of voting equipment

The manufacturer must provideSetup inspection process documentation must include a list 

of consumables associated with the voting device, including estimated number of usages per 

unit in the user documentation.
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3.2-O – Consumable inspection procedure

The manufacturerSetup inspection process documentation must provideinclude the 

procedures to inspect the remaining amount of each of the voting device’s consumables in 

the user documentation.

3.2-P – Calibration of voting device components 

The manufacturerSetup inspection process documentation must provideinclude:

1. a list of components associated with the voting device that require calibration;

2. the nominal operating ranges for each component in the user documentation ;

3. the procedures to inspect the calibration of each component in the user 

documentation; and

4. the procedures to adjust the calibration of each component in the user 

documentation.

3.2-Q – Checklist of properties to be inspected

The manufacturer must provideSetup inspection process documentation must include a 

checklist of other properties of the voting device to be inspected, to include:

1. a description of the risks of not performing each documented inspection;

2. power sources;

3. cabling for communications;

4. capabilities; 

5. consumables;

6. calibration of voting device components;

7. general physical features of the voting device; and

8. securing external interfaces of the voting device not being used.
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3.3 – The public can understand and verify the operations of the voting 

system throughout the entirety of the election.

3.3-A – System security, system event logging 

Manufacturers must provide documentation to be publicly available at no cost 

documentation that:

1. describes system event logging capabilities and usage, and

2. fully documents the log format information.

Discussion

The log format and the meaning of all possible types of log entries must be fully documented in 

sufficient detail to allow independent manufacturers to implement utilities to parse the log file. This 

documentation must be publicly available, free of charge, and not just in the TDP. The 

documentation may be housed by the EAC.

3.3-B – Specification of common data format usage

Voting device and system Manufacturers must provide documentation to be publicly 

available at no cost documentation describing how the manufacturer has implemented a

NIST CDF specification for a particular device or function. This includes such items as:

1. descriptions of how elements and attributes are used;

2. constraints on data elements; and

3. extensions as well as any constraints.

Discussion

Conformance to a common data format does not guarantee data interoperability. The manufacturer 

needs to document fully how it has interpreted and implemented a NIST CDF specification for its 

voting devices and the types of data exchanged or exported. Here is list of related references: NIST SP 

1500-103 Cast Vote Records Common Data Format Specification [CVR_CDF], NIST SP 1500-100 

Election Results Common Data Format Specification [NIST16], NIST SP 1500-101 Election Event 

Logging Common Data Format Specification [LOG_CDF], NIST SP 1500-102 Voter Records 

Interchange(VRI) CDF Specification [VRI_CDF].

3.3-C – Bar and other codes

The voting system’s documentation Manufacturers must provide documentation to be 

publicly available at no cost documentation that fully specifies the barcode or, how barcoded 
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data is formatted, and any other encoding standards or algorithmsmethods used on ballots 

or audit material.

Discussion

The voting system documentation needs to include the name and version of the standard used for 

barcodes or for any other codes that encode information that the public sees on ballots or other 

material that can be used in audits or verification of the election. 

3.3-D Encodings

The voting system’s documentation must provide documentation to be publicly available at 

no cost that fully specifies any compression, packing, or otherwise encodings of data used on 

ballots, including how data may be compressed or otherwise altered prior to encoding within 

a barcode.

Discussion

The voting system documentation needs to include the name and version of the standard used for 

barcodes or for any other codes that encode information that the public sees on ballots or other 

material that can be used in audits or verification of the election. The documentation also needs to 

include how the data may be packed or compressed within the encoding. The report should be 

sufficient for a voter to understand the barcoded contents and for an auditor to develop applications 

that examine the barcoded contents.

3.3-ED – Ballot selection codes

The voting system must be capable of producing a report to be publicly available at no 

coston an election-by-election basis to show the meaning of codes and other data used 

within a barcodebarcodes and CVRs to represent ballot selections and ballot style 

information.

Discussion

Codes are commonly used with barcodes that represent a voter’s ballot selections are commonly 

used within barcodes and CVRs so as to save space. The codes will likely change for each election. 

The codes are meaningless to a voter or an auditor unless the voting system can produce a report 

that shows all codes possible and what contests and ballot selections they represent. If, for example, 

a code of 90 is used to represent a particular contest, then the report must show that 90 refers to the 

title or description of that particular contest. This includes other information within the barcode 

generally found on clear-text ballots to identify the ballot style.
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Principle 4

Interoperable

The voting system is designed to support interoperability in its 

interfaces to external systems, its interfaces to internal components, its 

data, and its peripherals. 

4.1 - Voting system data that is imported, exported, or otherwise 

reported, is in an interoperable format. 

4.2 - Standard, publicly -available formats for other types of data are 

used, where available. 

4.3 - Widely-used hardware interfaces and communications protocols 

are used. 

4.4 - Commercial-off-the-shelf (COTS) devices can be used if they meet 

applicable VVSG requirements.
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Principle 4

INTEROPERABLE

The voting system is designed to support interoperability in its 

interfaces to external systems, its interfaces to internal components, its 

data, and its peripherals.

This principle covers requirements that ensure all system data is in an interoperable format 

and explains when standard, publicly available formats are used. It also addresses widely 

used hardware interfaces and when COTS devices are permitted. The guidelines under 

Principle 4 are:

1 - Interoperable formatformats requirements, which include voting system data that is 

imported, exported, or otherwise reported.

2 - Standard formats covering when publicly available formats for other types of data not 

addressed by NIST CDF specifications can be used.

3 - Interfaces and communication protocols, describing the need to use standard hardware 

interfaces and communication protocol when connecting devices.

4 - COTS covering the requirement that any COTs devices used meet all applicable 

requirements. 
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4.1 – Voting system data that is imported, exported, or otherwise 

reported, is in an interoperable format. 

4.1-A – Data export and exchange format

Voting devices must include support for the NIST SP Common Data Format (CDF) 

specifications for data inputs and output:

1. Election programming and results reporting data, NIST SP 1500-100

1. Election event logging data, NIST SP 1500-101

2. Cast vote records, NIST SP 1500-102

3. Voter registration-related data, NIST SP 1500-104

Discussion

Manufacturers can use proprietary data formats but need to also include support for the NIST CDF 

specifications. Implementations that do this using translations or conversions from a proprietary 

format would be considered in conformance. 

4.1-B – Election programming data input and output

Election definition processesThe voting system must include support for the NIST CDF 

specificationsspecification(s) regarding:

1. import and export of election programming data, and

2. import and export of ballot programming data.

Discussion

This requirement concerns import and export of pre-election data into an election definition device, 

such as for identification of political geography, contest, candidate, ballot data, and other preelection information used to setup an election and produce ballots. This also includes reports of preelection data from the election definition device that can be used to verify the election programming 

setup. More information can be found in SP 1500-100 Election Results Common Data Format 

Specification [NIST16].

Applies to: election definition

4.1-CB – Tabulator report data

Tabulation processesThe voting system must include support for the NIST CDF 

specificationsspecification(s) for import and export of election results reporting data.
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Discussion

Importing results data is required so as to provide support for aggregations of vote data from 

different election management systems such as what occurs during state roll-ups on election night 

and during the process of election results certification. More information can be found in: NIST SP 

1500-100 Election Results Common Data Format Specification [NIST16].

External reference: URL to SP 1500-100, 102

Applies to: tabulation, reporting

4.1-DC – Exchange of cast vote records (CVRs)

Casting, tabulation, and The voting system’s audit processes that use CVRs must include support 

for the NIST CDF specifications for export and import of those records.,

Applies to: casting, tabulation, auditand vote-capture functions dealing with CVRs must have 

the capability of importing or exporting CVRs according to CDF specification(s). 

Discussion

Devices that export or import CVRs typically include voter-facing and batch-fed scanners, election 

management systems, and other devices used for adjudication or auditing. This requirement 

indicates that these devices have the capability to import or export CVRs in the respective CDF(s). 

More information can be found in: NIST SP 1500-103 Cast Vote Records Common Data Format 

Specification [CVR_CDF].

4.1-ED – Exchange of voting device election event logs

The voting devices comprising the voting system must include support for the NIST CDF 

specificationsspecification(s) for import or export of election event log data.

Discussion

This requirement refers to election event logs and not system logs provided by common operating 

systems such as Microsoft Windows or Apple iOS. This requirement does not mandate that 

manufacturers use the format for storing election log information; a manufacturer can meet this 

requirement by conversion or translation from a native format into the CDF. More information can 

be found in:], NIST SP 1500-101 Election Event Logging Common Data Format Specification

[LOG_CDF].

4.1-FE – Voting device event code documentation

Voting device and system Manufacturers must includeprovide a publicly available 

specification for event codes used in their equipment and make this available upon request.

Discussion
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Use of NIST SP 1500-101 Election Event Logging Common Data Format Specification [LOG_CDF] for 

election event logs only addresses the data format; it does not mandate a common lexicon for event 

codes. NIST SP 1500-101 [LOG_CDF] provides a separate schema for including documentation of 

event codes; manufactures may make this available publicly or upon request without condition.

4.1-GF – Specification of common format usage

Voting device and system Manufacturers must include a specification describing how the 

manufacturer has implemented a NIST CDF specification for a particular device or function.

This includes such items as descriptions of how elements and attributes are used, as well as 

any constraints or extensions.

Discussion

Conformance to a common data format does not guarantee data interoperability. The manufacturer 

needs to document fully how it has interpreted and implemented a NIST CDF specification for its 

voting devices and the types of data exchanged or exported.
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4.2 - Standard, publicly -available formats for other types of data not 

addressed by NIST CDF specifications are used. 

4.2-A – Standard formats

Standard, publicly-Publicly available, and publicly-documented non-proprietary formats must 

be used, where possible, for exchanging data or encoding data.

Discussion

Examples include the use of common data encodings such as bar or QR codes.

4.2-B – Public documented manufacturer formats

Where it ispublicly available non-proprietary formats are not possible to meet requirement 

4.1-Aavailable, manufacturers must include a publicly documented specification that 

describes the protocol or data format.

Discussion

As an example, a manufacturer’s algorithm or method for packing or compressing of data before 

encoding in a QR code will be documented so that its implementation and usage is available publicly.

4.3 - Widely-used hardware interfaces and communications protocols 

are used. 

4.3 – Interfaces and communication protocols

4.3-A – Standard device interfaces

Standard, common hardware interfaces and protocols must be used to connect devices. 

Discussion

Examples include using published communications protocols, such as, IEEE, and using common 

hardware interfaces, such as, USB, when connecting to printers, disks, and other devices. 
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4.4 - Commercial-off-the-shelf (COTS) devices can be used if they meet 

all applicable VVSG requirements. 

4.4-A – COTS devices meet applicable requirements

COTS devices, if used, must satisfy all applicable VVSG requirements. 

Discussion

As an example, use of a COTS scanner to scan ballots is potentially possible, but there needs to be 

associated software to interpret the voter marks, create a cast vote record, and include support for 

the NIST CVR CDF. Together, the COTS scanner and associated software will meet applicable 

requirements for casting, counting, reporting, etcit will need to meet applicable environmental and 

electrical requirements and, potentially, other requirements depending on how the scanner is used. 

For example, if it is used to create CVRs, it will need to meet those requirements dealing with CVR 

creation and handling.
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Principle 5

Equivalent and Consistent

Voter Access

All voters can access and use the voting system regardless of their 

abilities.

5.1 - Voters have a consistent experience throughout the voting process 

within any method of voting.

5.2 - Voters receive equivalent information and options in all modes of 

voting.
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Principle 5

EQUIVALENT AND CONSISTENT VOTER ACCESS

All voters can access and use the voting system regardless of their 

abilities.

Principle 5 ensures that all voters can cast their votes easily and accurately, regardless of any 

disabilities they may have. This fulfills the requirements of the Help America Vote Act 

(HAVA), Section 301(a)(3) [HAVA02] which states, “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.”

It also addresses Section 508 of the Rehabilitation Act (amended in 1998)Information and 

Communication Technology (ICT) Final Standards and Guidelines [USAB18] which requires 

that electronic and information technology be accessible to people with disabilities, and the 

language access requirements in the Voting Rights Act (VRA) [VRA65].

The goal of both guidelines in Principle 5 is to ensure that everyone can use the voting 

system, regardless of their abilities or preferences. Voting equipment can present ballot 

choices in a variety of ways which make it possible for people with a wide range of 

disabilities to vote. The equipment must also fully support all the languages that the 

manufacture claims to support. The big differences are that guidelines:

1 – Consistent experience also covers the requirement that all vote records must be 

auditable by those who speak only English. AndAlso, in addition to actually casting their 

votes, peoplevoters must have access to those same display formats and interaction modes

of presentation for all information and instructions related to casting those votes. 

2 – Equivalent information also addresses the requirement that these modes of 

presentationdisplay formats (visual, audio, enhanced video) orvisual) and interaction modes 

(touch, tactile, non-manuallimited dexterity) must offer consistent and equivalent support 

for the actions required to vote, and offer them in a way that does not introduce bias. In 

addition, if the voter switches modesformats mid-stream, for example from videovisual to 

audio mode or from Spanish to English, the system must preserve all settings and votes cast.

Finally, note that this principle’s requirements, including supporting the display formats and

interaction modes listed in 5.1-A – Voting methods and interaction modes, also apply to all of 

the usability and accessibility requirements in Principles 6-8.
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5.1 – Voters have a consistent experience throughout the voting 

process within any method of voting.

5.1-A – Voting methods and interaction modes

Within any method of voting, all display formats including enhanced visual and audio and all 

interaction modes including audio, tactile, enhanced visual, and non-manuallimited dexterity

must have the same capabilitiesfunctionality as the visual interactionformat and touch mode

including ballot activation, voting, verification, and casting.

Discussion

Methods of voting that a voting system might support include in-person voting, vote-by-mail, remote 

ballot marking, among others. The VVSG scope is in-person voting. For voting systems to meet this 

requirement they would need to include (among others):, for example:

• Features that support non-manuallimited dexterity interaction to enable voters with limited 

dexterity, that is those who lack fine motor control or the use of their hands, to submit their 

ballots privately and independently without manually handling the ballot. 

• Features for paper ballots or paper verification records that assist voters with poor reading vision 

to read these ballots and records. 

• Features to allow blind voters and voters with limited dexterity to perform paper-based 

verification, or feed their own optical scan ballots into a readerscanner, if all other voters do so. 

For example, ballot papers or smart cards might provide tactile cues that allow the correct 

insertion of the card.

• Support for all voting variations. For example, if a visual ballot supports voting a straight-party 

ticket and then changing the vote for a single contest, so do all other display formats and

interaction modes.

External reference:

This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG sources: VVSG 1.1 - 3.2.5g, 3.3.3.b.i, 3.3.3.d, 3.3.3.e, 3.3.4.b, 3.3.8

5.1-B – Languages 

The voting system must be capable of displaying, and printing, and storing the ballot, contest 

options, review screens, vote verificationvoter verifiable paper records, and voting 

instructions in all languages the manufacturer has declared the system supports, in both 

visual and audio formats where applicable.

Discussion

Both written and unwritten languages are within the scope of this requirement.

The system will be tested in all languages that the manufacturer claims it is capable of supporting.
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External reference: VRA

Prior VVSG sources: VVSG 1.1 - 3.2.7.a, 7.8.6.c, 7.8.6,ci, 7.8.6.cii

This requirement originates with the VRA [VRA65].

5.1-C – Vote records 

All records, including paper ballots and voter verifiable paper verification records, must have 

the information required to support auditing by election workers and others who can only 

read only English. 

Discussion

Although the system needs to be easily usable by voters using an alternative language, records of the 

vote also need to be fully available to English-only readers for auditing purposes. Additional 

information, such as precinct and election identifiers may be in English to support election 

administration and auditing. See 9.4 - The voting system supports efficient audits for related 

requirements.

To meet this requirement, a paper ballot may not be a fully bilingual ballot. For instance, the full text 

of a ballot question might appear only in the alternative language, but the contest option (for 

example, “yes / no”) needs to be readable by English-only readers. 

Prior VVSG source: VVSG 1.1 - 3.2.7.a.iii

5.1-D – Accessibility features 

Accessibility features must be integrated into the manufacturer’s voting system so 

accessibility for voters with disabilities is supported throughout the voting session, including 

any steps to activate the ballot at the voting station, ballot marking, verification, and casting.

Discussion

This requirement ensures accessibility to the voter throughout the entire session. Not only are 

individual system components (such as ballot markers, paper records, and optical scanners) 

accessible, but they also work together to support voters with disabilities. support voters with 

disabilities throughout the process of voting from activation through casting. Requirements for 

individual system components are described in Principle 7: Marked, Verified, and Cast as Intended.

This general requirement supports HAVA [HAVA02].

Related requirements: External Reference: HAVA

Prior VVSG source: VVSG 1.1 - 3.3.1.a

6.1-B – Warnings
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5.1-E – Reading paper ballots

If the voting system generates a paper record (or some other durable, human-readable 

record) that can be the official ballot or determinative vote record, then the voting system 

must allow the voter to verify the paper record using the same access features they used to 

mark the ballot, including audio, tactile, enhanced visual, and non-manualaudio formats and 

tactile and limited dexterity modes.

Discussion

Paper records present difficulties for voters who use large font, high contrast, alternative languages, 

and other settings. The purpose of this requirement is to ensure that all voters have a similar 

opportunity for vote verification. For ballot marking devices, for example, if the voter is using audio 

to make their selections, the voter verifiable paper record, not the stored voter selections, must be 

read back.

This requirement allows the voter to use the same access features throughout the entire voting 

session. It also does not preclude the voter from choosing a different access feature to verify the 

record. For example, the voting system might provide a reader that converts the paper record 

contents into audio output.

External reference: HAVA

Prior VVSG sources: VVSG 1.1 - 3.3.1.e, 3.2.2.1.g, 7.8.7.b

This requirement supports HAVA [HAVA02].

Related requirementrequirements: 7.1-I – Text size (paper)

5.1-F – Accessibility documentation

As part of the overall system documentation the manufacturer must include descriptions 

and instructions for all accessibility features that describe:

• recommended procedures that fully implement accessibility for voters with 

disabilities, and

• how the voting system supports those procedures. 

Discussion

The purpose of this requirement is for the manufacturer not simply to deliver system components, 

but also to describe the accessibility scenarios they are intended to support, so that election offices 

have the information they need to effectively make accessibility features available to voters with 

disabilities. 

External reference:

This requirement is based on WCAG 2.0 /[W3C10] and Section 508 [USAB18].
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Prior VVSG source: VVSG 1.1 - 3.3.1.a.i

Related requirements: 7.3-N -– Instructions for voters

7.3-O - Instruction– Instructions for election workers
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5.2 – Voters receive equivalent information and options in all modes of 

voting.

5.2.-A – No bias

The voting system must not introduce bias for or against any of the contest options 

presented to the voter. In audio, tactile, enhanced visual, and non-manualaudio formats and

tactile and limited dexterity modes, all ballot options are to be presented in an equivalent 

manner.

Discussion

Discussion

Certain differences in ballot presentation are mandated by state law, such as the order in which 

candidates are listed and provisions for voting for write-in candidates. This requirement ensures that 

comparable characteristics such as font size or audio volume and speed are the same for all ballot 

options. 

Prior VVSG source: VVSG 1.1 - 3.2.4.d

5.2-B – Presenting content in all languages

All information that is presented to the voter in English must also be capable of being

presented in all other languages that are supported, whether the language is in visual or 

audio format. This includes instructions, warnings, messages, notification of undervotes or 

overvotes, contest options, and vote verification information.

Discussion

It is not sufficient simply to present the ballot options in the alternative languages. All the supporting 

information voters need to mark their ballot is also covered in this requirement.

External reference: VRA

Prior VVSG source: VVSG 1.1 - 3.2.7.a.ii

This requirement originates with the VRA [VRA65].

5.2-C – Information in all modes

Instructions, warnings, messages, notifications of undervotes or overvotes, and contest 

options must be presented to voters in the display formats and interaction modes required 

in 5.1-A – Voting methods and interaction modes for all functions.. This includes ballot 

activation, voting, verification, and casting.
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Discussion

Examples of how to meetFor audio mode, this requirement in the audio format include:

can be met with an audio that includes cues to help users know what to expect. For example,

announcing the number of items in a list of candidates or contests makes it easier to jump from one 

item to another without waiting for the audio to complete. Audio cues also ensure that the voter is 

aware of possible undervotes or overvotes. This includes information about activation.

• Audio cues that also ensure the voterThis requirement is aware of possible undervotes or 

overvotes.

External reference: based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source: VVSG 1.1 - 3.3.1.b

5.2-D – Audio synchronized

The voting system must provide the option for synchronized audio output to convey the 

same information that is displayed visually to the voter.

Discussion

This requirement covers all information, including information entered by the voter such as write-in 

votes.

This requirement applies to any audio output, whether it is recorded or generated as text-to-speech.

Any differences between audio and visual information are for functional purposes only, with 

variations only based on differences in the display format and interaction mode, especially for 

instructions. 

This feature can assist voters with cognitive disabilities. 

External reference: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source: VVSG 1.1 - 3.3.2.c

5.2-E – Sound cues

Sound and visual cues must be coordinated so that:

• sound cues are accompanied by visual cues unless the system is inset to audio-only

mode.; and

• visual cues are accompanied by sound cues, unless the system is inset to visual-only

mode.

Discussion
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The voting equipment might beep if the voter attempts to overvote. If so, there has to be an 

equivalent visual cue, such as the appearance of an icon or a blinking element. If the voting system 

has been set to audio-only mode, there would be no visual cue. 

Audio output also supports non-written languages, voters with low literacy, or voters with low vision.

External reference: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source: VVSG 1.1 - 3.3.6.b

5.2-F – Preserving votes

The voting systemAt any time during a voting session, an electronic voting interface must 

allow the voter to switch amongchange all modes including audio, tactile, enhanced 

visual,language and non-manualdisplay format options, and change languages at any time 

during the voting sessioninteraction settings that the voter can chose directly, while 

preserving theall current votes.vote selections. When switching mode or languagechanging 

settings, the system will alsomust preserve navigation, screen position, visual settings, audio 

settings, and other information within and across contests.

Discussion

A voter who initially chooses an English version of the ballot might switch to another language in 

order to read a referendum question. 

Many blind voters have preferences for audio settings, including the rate of speech and volume that 

are important for comprehension. 

Changing visual settings for text size might change the layout of the information on the screen, 

making it important to maintain the screen position.

External reference: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].
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Prior VVSG sources: VVSG 1.1 - 3.3.2.c.ii, 3.3.2.a, 3.2.7.a.i, 3.3.3.c.v, 3.3.3.c.vii, 

3.3.6.a

Principle 6

Voter Privacy

Voters can mark, verify, and cast their ballot privately and 

independently. 

6.1 - The voting process preserves the privacy of the voter's interaction 

with the ballot, modes of voting, and vote selections. 

6.2 - Voters can mark, verify, and cast their ballot or other associated 

cast vote record, without assistance from others.
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Principle 6

VOTER PRIVACY

Voters can mark, verify, and cast their ballot privately and 

independently.

Privacy for voters refers to the property of a voting system that is designed and deployed to 

enable voters to obtain a ballot, and mark, verify, and cast it without revealing their ballot 

selections or selections of language, display formats, and interaction modes to anyone else.

Privacy covers:

• electronic and paper interfaces, 

• audio and videovisual systems, and

• warning systems that must also preserve confidentiality. 

Principle 6: Voter Privacy, covers voter privacy during voting. Requirements in Principle 6

help ensure private and independent voting as mandated in the Help America Vote Act 

(HAVA).

The related Principle 10: Ballot Secrecy covers preventing links between a voter and a ballot

after the ballot has been cast.

The guidelines under Principle 6 cover:
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1 – Privacy of interaction which describes the requirement that the voting process preserves 

the privacy of the voter’s interaction with the ballot, modes ofdisplay format and other 

options for voting, and vote selections.

2 – Voting without assistance which mandates that voters can mark, verify, and cast their 

ballot or other cast vote record without assistance from others.
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6.1 - The voting process preserves the privacy of the voter’s interaction 

with the ballot, modes of voting, and vote selections.

6.1-A – Preserving privacy for voters

Privacy for voters must be preserved during the entire voting session including ballot 

activation, voting, verifying, and casting the ballot.

Discussion

This requirement allows for different approaches for electronic and paper interfaces. 

In both cases, appropriate shielding of the voting station is important -- for example, privacy screens 

for the voting stations.

When a paper record with ballot information needs to be transported by the voter, devices such as 

privacy sleeves can be necessary. This requirement applies to all records with information on votes 

(such as a vote verification record) even if that record is not itself a ballot. 

External reference: HAVA

Prior VVSG source: VVSG 1.1 - 7.8.5.a, 3.2.3.1.b

This requirement supports HAVA [HAVA02].

Related requirements: 7.2-F – Voter speech

6.1-B – Warnings

During the voting session, the voting system must issue all warnings in a way that preserves 

privacy for voters and the confidentiality of the ballot. 

Discussion

HAVA 301 (a)(1)(C) [HAVA 02] mandates that the voting system notifies the voter of an attempted 

overvote in a way that preserves privacy for voters and the confidentiality of the ballot. This 

requirement addresses that mandate. 

External reference: HAVA

Prior VVSG source: VVSG 1.1 - 3.2.3.1.d

Related requirements: 7.3-K– Warnings, alerts, and instructions

6.1-C – Enabling or disabling output

During the voting session, the voting system must make it possible for the voter to 

independently enable or disable either the audio or the videovisual output and be notified of 

the change, resulting in a videovisual-only or audio-only presentation.
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Discussion

Voters can be notified of the change to the display or audio output in a variety of ways including 

beep, voice, or visual notification. An unobtrusive notification that the system has changed the visual 

display modeformat is helpful to voters who cannot see the screen to confirm the change visually.

External reference: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source: VVSG 1.1 - 3.3.2.c.i

Related requirements: 7.2-A – Display and interaction options

7.3-K – Warnings, alerts, and instructions

6.1.-D – Audio privacy

Audio during the voting session must be audible only to the voter.

Discussion 

Voters who are hard of hearing but need to use an audio interface sometimes need to increase the 

volume of the audio. Such situations require headphones or other devices (such as a hearing loop) 

with low sound leakage so the contents of the audio cannot be overheard and understood by others. 

Voters who are hard of hearing can share audio interfaces with their designated assistants.

External reference: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source: 3.2.3.1.c

Related requirements: 7.2-F – Voter speech

8.1-J – Hearing aids 
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6.2 - Voters can mark, verify, and cast their ballot or other associated 

cast vote record without assistance from others.

6.2-A - Voter independence

Voters must be able to mark, verify, and cast their ballot or other associated cast vote 

records independently and without assistance from others. 

1. If a voting system includes any features voters might use after casting a ballot as 

part of end-to-end (E2E) verifiable system ballot tracking, they must be accessible. 

Discussion

This requirement ensures that voters can vote with their own interaction preferences and without 

risk of intimidation or influence.

HAVA 301 (a)(1)(C))[HAVA02] mandates that the voting system 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. This requirement directly addresses this mandate.

Examples ofNote that in addition to features for voters after casting their ballot includefor E2E 

system ballot tracking, there are other features, not in the scope of VVSG requirements that should 

be designed for accessibility such as forms or notices to cure problems with a vote-by-mail ballot, and 

sites to learn whether a provisional ballot was accepted for counting.

External reference: HAVA

Prior VVSG source: 7.8.5.a, 3.2.3.1.b

Related requirements: 2.2-A – User-centered design process

5.1-D – Accessibility features

5.1-E – Reading paper ballots

28.2-A – User-centered design process.Federal standards 

for accessibility 
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Principle 7

Marked, Verified, and Cast as 

Intended

Ballots and vote selections are presented in a perceivable, operable, 

and understandable way and can be marked, verified, and cast by all 

voters. 

7.1 - The default voting system settings present a ballot usable for the 

widest range of voters, and voters can adjust settings and preferences 

to meet their needs. 

7.2 - Voters and election workers can use all controls accurately, and 

voters have direct control of all ballot changes and selections. 

7.3 - Voters can understand all information as it is presented, including 

instructions, messages from the system, and error messages.
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Principle 7

MARKED, VERIFIED, AND CAST AS INTENDED

Ballots and vote selections are presented in a perceivable, operable, 

and understandable way and can be marked, verified, and cast by all 

voters.

This principle covers the core actions of voting, supporting voters in marking, verifying, and 

casting their ballot. It includes all voting systems including both paper ballots and electronic 

interfaces. 

The requirements in P-Principle 7 are derived from federal laws, including:

• the Help America Vote Act of 2002 (HAVA), 

• Section 508 (part of the Rehabilitation Act of 1973)

• Web Content and Accessibility Guidelines (WCAG), and,

• the Voting Rights Act.

This principle is divided into three sections which follow 508/ WCAG’s well-known organizing 

principles of Perceivable, Operable, and Understandable. Robust, the final POUR principle is 

included in Principle 8 – Robust, safe, usable and accessible. The guidelines under Principle 7

are:

1 – Default settings covers how ballot information is presented using audio and visual 

settings, as well as the voter’s ability to adjust the voting system to meet their needs or 

preferences. This includes using color and contrast, adjusting font size, and ensuring audio 

settings result in understandable speech.

2 – Controls covers a voter’s operation of the voting system, that is, the interaction with and 

control of the ballot during voting, including how the information is displayed and the voter’s 

ability to navigate the system. It addresses the voter’s ability to scroll though the electronic 

ballot, use the audio and touch controls, and use simple gestures. It also includes the need 

for adequate space for those who use wheelchairs. Both voters and election workers must 

be able to use all controls accurately.

3 – Understandable information covers the ability of the voter to understand all information 

on the ballot as it is presented, including instructions and messages from the system. Among 

other elements, it includes preventing contest layouts that can cause confusion, making clear 

the maximum number of choices a voter has, notifying the voter of any errors on the ballot 

(such as overvotes) before it is cast, and letting the voter know when they have successfully 

voted. It also covers ensuring that instructions for election workers are understandable.
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7.1 – The default voting system settings present a ballot usable for the 

widest range of voters, and voters can adjust settings and 

preferences to meet their needs.

7.1-A – Reset to default settings

If the adjustable settings of the voter interface have been changed by the voter or election 

worker during the voting session, the system must automatically reset to the default setting 

when the voter finishes voting, verifying, and casting. 

Discussion

This ensures that the voting system presents the same initial appearance to every voter. 

This requirement covers all settings that can be adjusted, including font size, color, contrast, audio 

volume, rate of speech, turning on or off audio or video, and enabling alternative input devices. 

External reference: WCAG 2.0/Section 508

Prior VVSG source: VVSG 1.1 - 3.2.5.b

Related requirement: 7.1-K – Audio settings 

Applies to: Electronic interfaces

Related requirements: 7.1-K – Audio settings 

7.1-B – Reset by voter

If either the voter or an election worker can adjust the settings of the voter interface, there 

must be a way for the voter to restore the default settings while preserving the current 

votes. 

Discussion

This requirement allows a voter or election worker who has adjusted the system to an undesirable 

state to reset all settings and start overwith the ballot presented to the voter using the new settings, 

but still keeping what was selected thus far. 

External reference: WCAG 2.0/Section 508

Prior VVSG source: VVSG 1.1 - 3.2.5.c

Related requirement: 5.2F – Preserving votes

Applies to: Electronic interfaces

Related requirements: 5.2-F – Preserving votes
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7.1-C – Default contrast

The default contrast ratio must be at least 10:1 for all elements that visually convey 

information such as text, controls, and infographics or icons. 

1. For electronic displays for voters and election workers, this is measured as a 

luminosity contrast ratio between the foreground and background colors of at least 

10:1. 

2. For paper ballots and other paper records, the contrast ratio will be at least 10:1 as 

measured based on ambient lighting of at least 300 lx. 

Discussion

For example, this applies to:

• candidate names, 

• a broken arrow, 

• the outline of an oval, circle, or rectangular target used to mark voter selections, or

• informational icons identifying voter selections or other information. 

Purely decorative elements that do not communicate meaning do not have to meet this requirement.

A 10:1 luminosity contrast ratio provides enough difference between the text and background to 

enable people with most color vision deficiencies to read the ballot. This is higher than the highest 

contrast requirements of 7:1 in WCAG 2.0 Checkpoint 1.4.6 (Level AAA) to accommodate a wider 

range of visual disabilities. There are many free tools available to test color luminosity contrast using 

the WCAG 2.0 algorithm. 

External reference: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source VVSG 1.1 - 3.2.2.2.f.ii, 3.2.5.h, 3.2.5.h.i, 3.2.5.h.ii

Applies to: Electronic interfaces

7.1-D – Contrast options

The voting system must provide options for high and low contrast displays, including the 

alternative display contrast options as listed below:

1. A high contrast option with a white background and dark text, with a luminosity 

contrast ration of at least 20:1.

2. A high contrast option with a black background (between #000000 and #111111) and 

one of the following foreground options, including:

a. yellow text similar to #FFFF00, providing a contrast ratio of at least 17.5:1, 

b. cyan text similar to #00FFFF, providing a contrast ratio of at least 15:1, and
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c. white text similar to #FAFAFA, providing a contrast ratio of at least 18:1.

3. A low contrast option, providing a contrast ratio in the range of 4.5:1 to 8:1.

Discussion

This requirement for options for the overall display contrast ensures that there is an option for the 

visual presentation for people whose vision requires either high or low contrast. 

High and low contrast options apply to the entire screen, including decorative elements.

Examples of color combinations for a low contrast options include:

• brown text similar to #BB9966 on a black background (7.8:1)),

• black text on a background with text similar to #BB9966 (7.8:1)),

• grey text similar to #6C6C6C on a white background (5.2:1)),

• grey/brown text similar to #97967E on a black background (6.9:1)), and

• grey text similar to #898989 on a dark background similar to #222222 (4.5:1)).

This External reference: requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source: VVSG 1.1 - 3.3.2.a.i, 3.2.5.h.ii

Applies to: Electronic interfaces

7.1-E – Color conventions 

The use of color by the voting system must follow these common conventions:

1. Green, blue, or white is used for general information or as a normal status indicator;

2. Amber or yellow is used to indicate warnings or a marginal status; and

3. Red is used to indicate error conditions or a problem requiring immediate attention.

External reference: WCAG 2.0/Section 508

Prior VVSG source: VVSG 1.1 - 3.2.4.f

7.1-F – Using color 

Color coding must not be used as the only means of communicating information, indicating 

an action, prompting a response, distinguishing a visual element, or providing feedback on 

voter actions or selections.

Discussion

While color can be used for emphasis, some other non-color modedesign element is also needed. 

This could include shape, lines, words, text, or text style. For example, an icon for “stop” can be red 
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enclosed in an octagon shape. Or, a background color can be combined with a bounding outline and a 

label to group elements on the ballot.

External reference: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source VVSG 1.1 - 3.2.5.i

7.1-G – Text size (electronic display)

A voting system’s electronic display must be capable of showing all information in a range of 

text sizes that voters can select from, with a default text size at least 4.8 mm (based on the 

height of the uppercase I), allowing voters to both increase and decrease the text size.

The voting system may meet this requirement in one of the following ways:

1. Provide continuous scaling with a minimum increment of 0.5 mm that covers the full 

range of text sizes from 3.5 mm to 9.0 mm.

2. Provide at least four discrete text sizes, in which the main ballot options fall within 

one of these ranges.

a. 3.5-4.2 mm (10-12 points) 

b. 4.8-5.6 mm (14-16 points)

c. 6.4-7.1 mm (18-20 points)

d. 8.5-9.0 mm (24-25 points)

Discussion 

The text size requirements have been updated from the VVSG 1.1 [VVSG2015] requirement to better 

meet the needs of voters who need larger text, including older voters, voters with low literacy, and 

voters with some cognitive disabilities. 

This requirement also fills a gap in the text sizes required in VVSG 1.1 which omitted text sizes 

needed or preferred by many voters. Although larger font sizes assist most voters with low vision, 

certain visual disabilities such as tunnel vision require smaller text. 

The sizes are minimums. These ranges are not meant to limit the text on the screen to a single size. 

The text can fall in several of these text sizes. For example, candidate names or voting options might 

be in the 4.8-5.6 mm range, secondary information in the 3.5-4.2 mm range, and titles or button 

labels in the 6.4-7.1 mm range.

The default text size of 4.8 mm is based on “Information and Communication Technology (ICT) Final 

Standards and Guidelines” (36 CFR Parts 1193 and 1194, RIN 3014-AA37, published in the Federal 

Register on January 18, 2017)

External reference: WCAG 2.0/ [W3C10] and Section 508 [USAB18].
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Prior VVSG source: VVSG 1.1 - 3.2.5.d, 3.2.5.e

Related requirements: 5.2-A – No bias

5.2-F – Preserving votes

7.2-D – Scrolling

7.3-B – No split contests

Applies to: Electronic interfaces

Related requirements: 5.2-A – No bias

5.2-F – Preserving votes

7.2-D – Scrolling

7.3-B – No split contests

7.1-H – Scaling and zooming (electronic display)

When the text size is changed, all other information in the interface, including informational 

icons, screen titles, buttons, and ballot marking target areas, must change size to maintain a 

consistent relationship to the size of the text. Informational elements in the interface do not 

have to be scaled beyond the size of the text.

1. When the text is enlarged up to 200% (or 7.1 mm text size), the ballot layout must 

adjust so that there is no horizontal scrolling or panning of the screen. 

2. When the text is enlarged more than 200%, there may be horizontal scrolling or 

panning if needed to maintain the layout of the ballot and a consistent relationship 

between the text for ballot options and associated marking targets.

Discussion 

The intention of this requirement is that all of the informational elements of the interface change 

size in response to the text size. However, some interface designs include elements that are already 

large enough that making them larger would distort the layout. In this case, this does not require 

those elements to grow proportionately beyond the size of the text.

Techniques for managing scaling and zooming an electronic interface while adjusting the layout to fit 

the new size are sometimes called responsive design or responsive programming.

This requirement does not preclude novel approaches to on-screen magnification such a zoom lens 

showing an enlarged view of part of a screen (as long as it meets the requirements in 7.2 for the 

operability of the controls).

This requirement follows WCAG 2.0 [WCAG10] in requiring scaling with no horizontal scrolling up to 

200% and allowing zooming with horizontal scrolling for larger text.

Applies to: Electronic interfaces
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External reference: WCAG 2.0/Section 508

Related requirements: 7.1-G – Text size (electronic 

display)

7.2-D – Scrolling

5.1-A- – – Voting methods and interaction modes

5.2-A – No bias

5.2-C – All information in all modes

5.2-F – Preserving votes

7.1-G – Text size (electronic display)

7.2-D – Scrolling
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Applies to: Electronic interfaces

7.1-I – Text size (paper)

The voting system must be capable of printing paper ballots and other paper records with a 

minimum font size of at least 3.5 mm (10 points).

Discussion

Although the system can be capable of printing in several font sizes, local or State laws and 

regulations can also govern the use of various font sizes. 

If the voting system includes a large-print display option, a good range for the text size is 6.4-7.1 mm 

matching the size in 7.1-G- – Text size (electronic display)

If typography changes such as text size or display style are used to differentiate languages on a multilingual ballot, the requirements in 5.2-A- – No bias (and relevant state election law for ballot design) 

still apply.

Applies to: Printed Material

Prior VVSG source: VVSG 1.1 - 3.2.5.i

Related requirements: 5.1-E – Reading paper ballots

7.1-G – Text size (electronic display)

Applies to: Printed Material

7.1-J – Sans-serif font 

The voting system must be capable of presenting text intended for the voter in a sans-serif 

font. 

Discussion

This requirement ensures that systems are capable of best practice while allowing them to also meet 

local or state laws or regulations that might differ.

In general, sans-serif fonts are easier to read on-screen, look reasonably good when their size is 

reduced, and tend to retain their visual appeal across different platforms. Examples of sans-serif 

fonts with good readability characteristics include Arial, Calibri, Microsoft Tai Le, Helvetica, Univers, 

Clearview ADA, or Open Sans.

“Information and Communication Technology (ICT) Final Standards and Guidelines” (36 CFR Parts 

1193 and 1194, RIN 3014-AA37, published in the Federal Register on January 18, 2017) 

requiresWCAG 2.0 [W3C10] and Section 508 [USAB18] require that at least one mode of characters 

displayed on the screen be a sans-serif font.
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The guidance on suitable fonts replaces the detailed text characteristics in VVSG 1.1

External reference: WCAG 2.0/Section 508

Prior VVSG sources: VVSG 1.1 - 3.2.5.f, 3.2.5.d

7.1-K – Audio settings

The voting system’s audio format interface must meet the following requirements:

1. The settings for volume and rate of speech are followed regardless of the technical 

means of producing audio output. 

2. The default volume for each voting session is set between 60 and 70 dB SPL. 

3. The volume is adjustable from a minimum of 20dB20 dB SPL up to a maximum of 

100 dB SPL, in increments no greater than 10 dB.

4. The rate of speech is adjustable throughout the voting session while preserving the 

current votes, with 6 to 8 discrete steps in the rate. 

5. The default rate of speech is 120 to 125 words per minute (wpm).

6. The range of speech rates supported is from 60-70 wpm to 240-250 wpm (or 50% to 

200% of the default rate), with no distortion.

7. Adjusting the rate of speech does not affect the pitch of the voice. 

Discussion

The top speech rate is slower than some audio users prefer for narrative reading to ensure that 

candidate names are pronounced clearly and distinctively. 

Note that calculation of rate of speech can vary based on the length of the words in the sample, so 

requirements are stated as a small range. 

Speech rates as slow as 50 wpm and as fast as 300 wpm can be included if this can be done without 

distortion or flanging.

This requirement is intended to be tested using “real ear” measurements not simply measurements 

at the point of the audio source.

According to an explanation written by the Trace Center (http://trace.umd.edu/docs/2004-AboutdB),[TC04], 60 dB SPL is the volume of ordinary conversation.

FCC regulations for hearing aids, 47 CFR Parts 20 and 68: Hearing Aid Standard, [FCC18], includes 

useful information about how to test audio volume and quality.

External reference: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].
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Prior VVSG source: VVSG 1.1 - 3.3.3.c.iv

Related requirements: 7.1-A – Reset to default settings

7.1-L – Speech frequencies

The voting system’s audio format interface must be able to reproduce frequencies over the 

audible speech range of 315 Hz to 10 KHz. 

Discussion

The required frequencies include the range of normal human speech. This allows the reproduced 

speech to sound natural. 

This is a requirement for the capability of the system so that it is possible to create intelligible audio. 

It is not a requirement for a ballot in a real election, which is outside of the scope of the VVSG.

External reference: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source VVSG 1.1 - 3.3.3.c.vi

7.1-M – Audio comprehension

The voting system’s audio format interface must be capable of presenting audio content so 

that it is comprehensible to voters who have normal hearing and are proficient in the 

language with:

1. proper enunciation, normal intonation, accurate pronunciation in the context of 

the information, and the capability to pronounce candidate names as intended;

2. low background noise; and

3. recording or reproduction in dual-mono, with the same audio information in both 

ears. 

Discussion

This requirement covers both recorded and synthetic speech. It applies to those aspects of the audio 

content that are inherent to the voting system or that are generated by default. To the extent that 

election officials designing the ballot determine the audio presentation, it is beyond of the scope of 

this requirement. 

Support for non-written languages and low literacy includes audio output that is usable by voters 

who can see the screen.

The International Telecommunications Union (ITU) provides a set of freely available test signals for 

testing audio quality in Rec. ITU-T P.50 Appendix I (http://www.itu.int/net/itut/sigdb/genaudio/AudioForm-g.aspx?val=1000050)[ITU19].
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External reference: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].
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ITU-T P.50 Appendix I

Prior VVSG source: VVSG 1.1 - 3.3.3.c.vii

7.1-N – Tactile keys

Mechanically operated controls, buttons, keys, or any other hardware interfaces (including 

dual switches or sip-and-puff devices) on the voting system available to the voter must:

1. be tactilely discernible without activating those controls or keys;

2. include a Unified English Braille, Contracted label if there is a text label; and

3. not require sequential, timed, or simultaneous presses or activations, unless using a 

full keyboard.

Discussion 

A blind voter can operate the voting system by “feel” alone. This means that vision is not necessary 

for such operations as inserting a smart card or plugging into a headphone jack. 

Controls that are distinguished only by shape without a text label do not need a Braille label.

Controls do not depend on fine motor skills.

External reference: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source VVSG 1.1 - 3.3.3.f

Related requirement;requirements: 7.2-E – TouchscreenTouch screen gestures

7.2-H – Accidental activation

7.2-R – Control labels visible

7.3-L – Icon labels

7.1-O – Toggle keys

The status of all locking or toggle controls or keys (such as the "shift" key) for the voting 

system available to the voter must be visually discernible, and also discernible through either 

touch or sound. 

DiscussionExternal reference:

This applies to any physical controls or keys that have a locking or toggle function.

This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source: VVSG 1.1 - 3.3.3.g
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7.1-P – Identifying controls

Buttons and controls for the voter that perform different navigation or selection functions 

must be distinguishable by both shape and color for visual and tactile and visual perception. 

Well-known arrangements of groups of keys may be used only for their primary purpose. For 

example, a full alphabetic keyboard is acceptable for entering a write-in candidate name, but 

individual keys cannot be used for navigation or selection.

Discussion

This applies to buttons and controls implemented either on-screen or in hardware. For on-screen 

controls, shape includes the label on the button. Redundant cues help those with low vision. They 

also help individuals who have difficulty reading the text on the screen, those who are blind but have 

some residual vision, and those who use the controls on a voting system because of limited dexterity. 

While this requirement primarily focuses on those with low vision, features such as tactile controls 

and on-screen controls intended primarily to address one kind of disability often assist other voters 

as well. The Trace Center’s EZ Access design is an example of button functions distinguishable by 

both shape and color: https://trace.umd.edu/ez [TCnd].

EAC RFI 2007-05 is incorporated into this requirement.

External Reference: Some examples are:

• Color can be helpful to make different sets of functions visually distinct: groups of buttons can 

share a color, such as Volume UP/DOWN.

• Tactile perception requires different shapes, so that finding a control does not rely solely on the 

layout: all the shapes cannot be squares, but two or four triangles can be used if they point in 

different directions.

• As a group of well-known keys, a full alphabetic keyboard is acceptable for entering a write-in 

candidate name, but individual keys cannot be used for navigation or selection. Using these keys 

for functions would require a voter to see the visual labels or know the arrangement for those 

functions.

This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].
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EAC RFI 2007-05

Prior VVSG source: VVSG 1.1 - 3.3.2.b

7.2 – Voters and election workers can use all controls accurately, and 

voters have direct control of all ballot changes.

7.2-A – Display and interaction options

The voting system must provide at least the following display formatsformat and control or 

navigationinteraction mode options to enable voters to activate their ballot, mark their 

ballot to vote, and verify and cast their ballot, supporting the full functionality in each mode:

1. Visual format with ;

1.2. Enhanced visual optionsformat;

2.3. Audio format;

1. Tactile controls

4. Touch mode; and

3.5. Limited dexterity controlsmode.

Discussion

Voters need to be able to choose the combination of display formats and types of controls that work 

for them, for example, combining the audio format with tactilely discernible controlsthe tactile 

mode. 

Limited dexterity mode controls are defined in the Glossary asinclude those that do not require 

dexterity and those that can be operated without use of hands. 

Full functionality includes at least instructions and feedback regarding:

• on initial activation of the ballot (such as insertion of a smart card), if applicable; 

• on how to use accessibility features and setting;

• on a change in the display format or control options;

• for navigating the ballot; 

• for contest options, including write-in candidates; 

• on confirming and changing votes; and 

• on final ballot submission. 

This requirement External reference: is based on WCAG 2.0/ [W3C10] and Section 508

[USAB18].
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Prior VVSG sources: VVSG 1.1 - 3.3.3.b, 3.3.8

Related requirements: 5.1-A- – – Voting methods and interaction modes

5.2-A – No bias

7.2-B – Navigation between contests 

The electronic ballot interface must provide navigation controls that allow the voter to 

advance to the next contest or go back to the previous contest before completing their vote. 

Discussion

For example, voters are not forced to proceed sequentially through all contests before going back to 

check their votes within a previous contest. 

This requirement applies whether the voter is using the visual or audio format, or synchronized audio 

and videovisual.

As with all requirements, this applies to all display formats and interaction modes.

External reference: WCAG 2.0/Section 508

Prior VVSG sources: VVSG 1.1 - 3.2.2.1.e, 3.3.3.3.e

Related requirements: 7.2-A – Display and interaction options 

7.2-C – Voter control

An electronic ballot interface must give voters direct control over making or changing vote 

selections within a contest. This requirement includes the following:

1. In a vote-for-one contest, selecting a candidate may deselect a previously selected 

candidate, but the system must announce the change in audio and visual display.

2. In a vote-for-N-of-M contest, the system must not deselect any candidate 

automatically.

3. In a vote-for-N-of-M contest, the system must inform the voter that they have

attempted to make too many selections and offer an opportunity to change their 

selections.

4. Ballot options intended to select a group of candidates, such as straight-party voting, 

must provide clear feedback on the result of the action of selecting this option.

5. Ballots with preferential or ranking voting methods must not re-order candidates 

except in response to an explicit voter command. 

Discussion
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This requirement covers any selection, de-selection, or change to ballot options. It can be met in a 

variety of ways, including notifications or announcements of the action the system is taking. For 

example, if a voter attempts to mark a selection for more candidates than allowed, the system does 

not take an independent action to de-select a previously selected candidate, but instead notifies the 

voter of the problem and offers ways to correct it.

As with all requirements, this applies to all display formats and interaction modes.

This requirement addresses situations in which the voter cannot see the change take effect because 

the previously selected candidate is on another screen, has scrolled off the visible display area, or is 

out of the voter’s field of vision. It is particularly important to voters using the audio format and no 

visual display because they often do not have a way to know that a change that occurs higher up in 

the contest has taken place. 

Examples of feedback include visual changes on the screen and related sounds or messages in text 

and audio. For example, selecting a candidate is often announced visually with a check-mark image 

and in audio by naming the candidate selected. 

If there is a visual change or announcement about the number of candidates selected (or selections 

still available), for example, the audio says “you have selected the maximum number of candidates in 

this contest” in a vote-for-N contest.

An example of feedback on the result of a complex action, such as making a selection in straightparty voting, might be a message confirming the party whose candidates were selected, or even the 

number of candidates and contests affected by the voter’s action. 

Related requirements: 7.2-A – Display and interaction options

7.3-E – Feedback

7.3-F – Correcting the ballot

7.2-D – Scrolling 

If the number of candidates or length of the ballot question means that the contest does not 

fit on a single screen using the voter’s visual display preferences, the voting system must 

provide a way to navigate through the entire contest.

1. The voting system may display the contest by:

a. pagination - dividing the list of candidates or other information into “chunks,” 

each filling one screen and providing ways for the voter to navigate among the 

different chunks,; or

b. scrolling – keeping all of the content on a single long display and providing 

controls that allow the voter to scroll continuously through the content.

2. For either display method, the voting system interface must: 
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a. have a fixed header or footer that does not disappear, so voters always have 

access to navigation elements, the name of the current contest, and the voting 

rules for the contest,;

b. include easily perceivable cues in every interaction modedisplay format to 

indicate that there is more information or there are more contest options 

available,; and

c. include an option for an audio format and visual presentationformat that sync 

during scrolling.

3. The navigation method must ensure that the voting system:

a. meets all requirements for providing feedback to the voter,;

b. accurately issues all warnings and alerts including notifications of undervotes 

and overvotes,;

c. meets all requirements for control size and interaction, and keeping all 

controls visible,;

d. does not rely only on conventional platform scroll bars,; and 

e. provides an opportunity to review and correct selections before leaving the 

contest.

Discussion

The ability to scroll through a list of candidates on a single logical page can be particularly important 

when a voter selects larger text or is using the audio format.

Information elements that need not scroll might include the name of the contest (“City Council 

Member”), the voting rules (“vote for 1”) and general controls including preference settings or 

navigation between contests.

A scrolling interface that meets this requirement offers voters a combination of easily perceivable 

controls or gestures to navigate through the list of candidates or text of a ballot question. For 

example:

• Navigation within the contest does not rely on knowledge of any particular computer platform 

or interface standard.

• Navigation within the contest does not only rely on conventional platform scroll bars, which 

operate differently on two of the major commercial computer platforms.

• Controls have visible labels that include words or symbols.

• Controls are located in the voter’s visual viewing area at the bottom (or top) of the scrolling 

area, for example in the center of the column of names or paragraph of text. This is especially 

helpful for people with low digital or reading literacy.
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• Controls are identified in the audio format and can be activated in all interaction modes.

This overall requirement relates to 7.1-G- – Text size, (electronic display), 7.1-H- – Scaling and 

zooming, (electronic display), and 7.3-B- – No split contests

The controls used to meet this requirement also need to meet all other requirements including 7.2-H 

– Accidental activation, 7.2.I- – Touch area size, 7.2-F- – Voter speech, and 7.2-E- – Touch screen

gestures.

Meeting requirements for notifications relates to 7.3-E- – Feedback, 7.3-F- – Correcting the ballot, 

7.3-H- – Overvotes, 7.3-I- – Undervotes, and 7.3-K- – Warnings, alerts, and instructions.

Applies to: Electronic interfaces

Prior VVSG source: VVSG 1.1 - 3.2.6.a

Related requirements: 7.1-G – Text size (electronic display)

7.1-H – Scaling and zooming (electronic display)

7.3-B – No split contest

7.2-E – Touch screen gestures

7.2-F – Voter speech

7.2-H – Accidental activation

7.2.I– – Touch area size

7.3-B – No split contests

7.2-F – Voter speech

7.2-E – Touch gestures

7.3-E – Feedback

7.3-F – Correcting the ballot

7.3-H – Overvotes

7.3-I – Undervotes

7.3-K – Warnings, alerts, and instructions

Applies to: Electronic interfaces

7.2-E – TouchscreenTouch screen gestures

Voting system devices used by voters with a touch screen may use touchscreentouch screen

gestures (physical movements by the user while in contact with the screen to activate 

controls) in the interface if the following conditions are met:

1. Gestures are offered as another way of interacting with a touch screen and an 

optional alternative to the other interaction modestouch interactions.

2. Gestures work consistently across the entire voting interaction.

3. Gestures do not include navigation off the current contest.
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4. Gestures are used in a way that does not create accidental activation of an action 

through an unintended gesture. 

5. Gestures are limited to simple, well-known gestures.

6. Gestures do not require sequential, timed or simultaneous actions.

Discussion

This requirement ensures that the use of gestures does not interfere with the accessibility features of 

the voting system or make the interface difficult to use by relying on a controlan interaction mode 

with no easy way to make them perceivable in the visual or audio formats.

In relying on simple and common gestures, this requirement does not intend to fully duplicate the 

gestures for commercial mobile platforms used with an audio modeformat for accessibility.

Tapping (touching the screen briefly) is the most basic gesture and is used on all touch screens. Other 

commonly used gestures include:

• pinching or spreading fingers to zoom,

• swiping to scroll, and

• pressing and holding to drag

Examples of gestures that require sequential or simultaneous actions are double-tapping, 2, 3 or 4 

finger swiping, touch and hold for a set period of time, or those that require coordinated actions with 

fingers on both hands. On desktop systems, assistive preference options like Sticky Keys can make 

these complex gestures accessible, but they require familiarity beyond what is acceptable in a voting 

system.

Examples of timed gestures include differentiating between long and short touches, or which require 

touching twice in rapid succession to highlight and then activate the button or selection.

Related requirement: 7.2-H – Accidental activation

7.1-N – Tactile keys

Applies to: Electronic interfaces

Related requirements: 7.1-N – Tactile keys

7.2-H – Accidental activation

7.2-F – Voter speech

If the voting system includes speech or human sounds as a way for voters to control the 

system:

1. it must not require the voter to speak recognizable voting selections out loud, and

2. speech input must not be the only non-visual interaction mode. 
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Discussion

This requirement allows the use of speech input as long as voters can choose other ways of 

interacting with the voting system that do not require either vision or use of their hands. 

It is also important to consider how speech would work as a way of voting in a noisy polling place 

environment.

External reference: WCAG 2.0/Section 508

Prior VVSG source VVSG 1.1 - 3.3.9.a

Related requirements: 6.1-A- – Preserving privacy for voters

6.1-D-– Audio privacy 

7.2.-G – Voter control of audio

The voting system must allow the voter to control the audio presentationformat including: 

1. pausing and resuming the audio;

2. repeating any information;

3. skipping to the next or previous contest,; and

4. skipping over the reading of the ballot question text.

Discussion

These features can also be useful to voters with cognitive disabilities. 

This is comparable 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, or

• skip over the wording of a referendum on which they have already made a decision prior to the 

voting session (for example, "Vote yes on proposition #123"). 

External reference: WCAG 2.0/Section 508

Prior VVSG sources; VVSG 1.1 - 3.3.3.b.ii, 3.3.3.b.iii, 3.3.3.b.iv, 3.3.3.b.v, 3.3.8

Applies to: Electronic interfaces

7.2-H – Accidental activation

Both on-screen and physical controls on the voting system must be designed to prevent 

accidental activation. 

Discussion
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There are at least two kinds of accidental activation: 

• When a control is activated to execute an action as it is being “explored” by the voter because 

the control is overly sensitive to touch. 

• When a control is in a location where it can easily be activated unintentionally. For example, 

when a button is in the very bottom left corner of the screen where a voter might hold the unit 

for support. 

Work onThe draft of WCAG 2.1, the next version of WCAG 2.0 [W3C10] includes a similar 

requirement and offers guidelines for preventing accidental activation including that the activation 

be on the release of the control (an “up-event”) or equivalent, or that the system provides an 

opportunity to confirm the action. 

In addition to the accessibility needs for preventing accidental activation, it can be an issue if voters 

perceive the voting system as changing their voting selections. 

External references: WCAG 2.0/Section 508

Prior VVSG source: VVSG 1.1 - 3.2.6.c

Related requirements: 7.1-N – Tactile keys

7.2-E – Touch screen gestures

7.1-N – Tactile keys

7.2-I – Touch area size

If the voting system has a touch screen, the touch target areas must: 

1. be at least 12.7 mm (0.5 inches) in both vertical and horizontal dimensions,;

2. be at least 2.54 mm (0.1 inches) away from adjacent touch areas,; and

3. not overlap another touch area.

Discussion

The requirements for touch size areas on voting systems are larger than commercial standards for 

mobile devices:

• to ensure that the touch areas are large enough for voters with unsteady hands,;

• to ensure that voting systems allow full adjustment to the most comfortable posture,; and

• to allow for touchscreenstouch screens that do not include advanced algorithms to detect the 

center point of a touch. 

The required touch area size is larger than some of the commercial standards for mobile phones to 

allow for use by voters with limited dexterity. 
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The required marking area size is within sizes suggested in the draft WCAG 2.1 (the next version of 

WCAG 2.0 [W3C10]) for target areas that accept a touch action.

An MIT Touch Lab study of Human Fingertips to Investigate the Mechanics of Tactile Sense found 

that the average human finger pad is 10-14 mm and the average fingertip is 8-10 mm.

External references: WCAG 2.0/Section 508

Prior VVSG sources: VVSG 1.1 - 3.2.6.c.i

Applies to: Touch screen interfaces

7.2-J – Paper ballot target areas

On a paper ballot that a voter marks by hand, the area of the target used to mark a voting 

selection must be at least 3 mm (0.12 inches) across in any direction.

Discussion 

This requirement applies to marking ovals, circles, squares, or other optical scan ballot designs.

Although the marking target for hand-marked paper ballots needs to be large enough to see, a target 

that is too large can also make it hard to fill in the area completely. 

 

Prior VVSG source: VVSG 1.1 - 3.2.2.2.f.i

Applies to: Paper ballots

7.2-K – Key operability

Physical keys, controls, and other manual operations on the voting station must be operable 

with one hand and not require tight grasping, pinching, or twisting of the wrist. The force 

required to activate controls and keys must be no greater than 5 lbs. (22.2 N). 

Discussion

Voters can operate controls without excessive force. This includes operations such as inserting an 

activation card, and inserting and removing ballots. 

This does not apply to on-screen controls.

External references: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source: VVSG 1.1 - 3.3.4.c

Applies to: Physical controls
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7.2-L – Bodily contact

The voting station controls must not require direct bodily contact or for the body to be part 

of any electrical circuit. If some form of contact is required, a stylus or other device with 

built-in permanent tips will be supplied to activate capacitive touch screens.

Discussion

This requirement ensures that controls and touch screens can be used by individuals using prosthetic 

devices or that it is possible to use a stylus on touch screens for either greater accuracy or limited 

dexterity input. 

One type of touch screen – capacitive touch panels – rely on the user’s body to complete the circuit.

EAC RFI 2015-05 states that They can be used if manufacturers supply a stylus or other device that 

activates the capacitive screen.

External references: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source: VVSG 1.1 - 3.3.4.d

Applies to: Electronic interfaces

7.2-M – No repetitive activation

Voting system keys or controls must not have a repetitive effect when they are held in an 

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. 

External references: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source: VVSG 1.1 - 3.2.6.c.ii

7.2-N – System response time

The voting system’s response time must meet the following standard response times:

1. The system initially responds to a voter action in no more than:

a. 0.1 seconds for a visual change, and

b. 0.5 seconds for an audio response.

2. The system responds to a voter marking a vote in no more than 1 second for both a 

visual response and an initial audio response.
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3. The system completes the visual response or display in no more than 1 second or 

displays an indicator that a response is still being prepared.

Discussion

This is so the voter can very quickly perceive that an action has been detected by the system and is 

being processed. The voter never gets the sense of dealing with an unresponsive or "dead" system. 

Note that this requirement applies to both auditory and visual voting system responses. 

For example, if the voter touches a button to indicate a vote for a candidate, a visual system might 

display an "X" next to the candidate's name, and an audio system might announce, "You have voted 

for John Smith for Governor". Even for "large" operations such as initializing the ballot or painting a 

new screen, thetouch screen system never takesideally should not take more than 10 seconds. 

In the case of audio systems, no upper limit is specified, since certain operations can take longer, 

depending on the length of the text being read (for example, reading out a long list of candidates 

running in a contest). For instance, the system might present a progress bar indicating that it is 

"busy" processing the voter's request. This requirement is intended to preclude the "frozen screen" 

effect, in which no detectible activity is taking place for several seconds. There need not be a specific 

"activity" icon, as long as some visual change is apparent (such as progressively "painting" a new 

screen or providing audio feedback). 

External references: WCAG 2.0/Section 508

Prior VVSG sources; VVSG 1.1 - 3.2.6.1.a, 3.2.6.1.b, 3.2.6.1.c, 3.2.6.1.d

Applies to: Electronic interfaces

7.2-O – Inactivity alerts

If the voter has not interacted with the voting system for a long time (, that is, between 2-5 

minutes),, the system must notify the voter and meet the following requirements:

1. EachThe system must specify what they mean bydocument the inactivity time and 

keep a record of it.

2. When the voter’s inactivity time expires, the electronic ballot interface must issue 

an alert and provide a way for the voter to receive additional time. 

3. The alert time must be between 20 and 45 seconds. 

4. If the voter does not respond to the alert within the alert time, the electronic ballot 

interface must go into an inactive state requiring election worker intervention. 

Discussion
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Each type of system will have a given inactivity time that is consistent among and within all voting 

sessions. This ensures that all voters are treated equitably. 

The For a referendum, in audio format, the timer starts when the voteraudio finishes reading a 

referendum.

External references: WCAG 2.0/Section 508

Prior VVSG sources: VVSG 1.1 - 3.2.6.1.e, 3.2.6.1.f

Applies to: Electronic interfaces

7.2-P – Floor space

When used according to the manufacturer’s installation instructions, the voting station must 

allow floor space for voters using a wheelchair or a voter’s assistant by:

1. providing a clear area for a wheelchair of 760 mm (30 inches) wide and 1220 mm (48 

inches) deep, and

2. providing adequate room for a voter’s assistant, including enough room for both the 

voter and an assistant to enter the area of the voting station. 

Discussion

This requirement sets minimum dimensions for clear floor space around a voting station and ensures 

that the manufacturer’s voting station design and associated installation instructions support polling 

place layouts that can achieve this requirement. 

In planning a polling place layout, election officials should consult the U.S Access Board Technical 

Guide: Clear Floor or Ground Space and Turning Space (https://www.accessboard.gov/attachments/article/1553/clear%20floor%20sapce-ABA.pdf)[USAB14a] and the U.S. 

Department of Justice ADA Checklist for Polling Places 

(https://www.ada.gov/votingchecklist.htm)[USDOJ16] to be sure that a voter using a wheelchair 

can reach the voting station. They should also consider space needed if a voter’s assistant also uses a 

mobility device. 

External references: WCAG 2.0/Section 508

US Access Board Clear Floor or Ground Space and Turning 

Space

U.S. Department of Justice ADA Checklist for Polling Places

Prior VVSG sources: VVSG 1.1 - 3.3.5.a, 3.3.5.b
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7.2-Q – Physical dimensions

The physical dimensions of the voting station must meet the U.S. Access Board requirements 

in Appendix A to Part 1194 – Section 508 of the Rehabilitation Act: Application and Scoping 

Requirements, Chapter 4: Hardware, Section 407.8 Operable Parts: Reach Height and Depth.

[USAB14b].

Discussion

This requirement is part of Information and Communication (ICT) Standards and Guidelines, 

published in the Federal Register on January 8, 2017, Amended March 23, 2017 as 36 CFR Parts 1193 

and 1194.The text of the requirements for reach height and depth with illustrations can be found on 

the U.S. Access Board website at https://www.access-board.gov/guidelines-andstandards/communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-andguidelines#407-operable-parts

This requirement is part of Section 508 [USAB18]. with the text of the requirements for reach height 

and depth with illustrations in the “#407 operable parts” section.

Many voting systems can be set up in a variety of ways for use in a polling place or vote center. For 

example, a system might sit on a table that allows voters to put their legs under the table in a polling 

place, but on a counter with no legroom in a vote center. Wheelchairs and scooters also allow voters 

different abilities to reach controls, and the voter might approach the voting system from the front or 

side, depending on the physical design and how it is presented to the voter.

A guide to meeting the requirements in the ADA standard for ensuring that voters can reach and use 

all operable parts can be found online at the Access Board website: https://www.accessboard.gov/guidelines-and-standards/buildings-and-sites/about-the-ada-standards/guide-to-theada-standards/chapter-3-operable-partsus all operable parts can be found at [USAB14b].

External reference: WCAG 2.0/Section 508

U.S. Access Board Section 508 Chapter 3.407-Operable 

Parts

Prior VVSG sources: VVSG 1.1 - 3.3.5.c, 3.3.5.1.a, 3.3.5.1.b, 3.3.5.1.c, 3.3.5.1.d

7.2-R – Control labels visible 

Labels for physical controls used by voters must be placed:

1. on a surface of the voting system where voters can see them from a seated or 

standing posture, and

2. within the dimensions required in 7.2-Q – Physical dimensions.

Discussion
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This requirement ensures that voters can find controls, even if they are placed on a side or top 

surface of the voting system, and that blind voters can discover any Braille labels associated with the 

text label by touch.

Related requirements: 7.1-N – Tactile keys

7.2-Q – Physical dimensions

7.3-L – Icon labels
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7.3 – Voters can understand all information as it is presented, including 

instructions, messages from the system, and error messages.

7.3-A – System-related errors

The voting system must help voters complete their ballots effectively, ensuring that the 

features of the system do not lead to voters making errors during the voting session. 

Discussion

Prior VVSG sources: VVSG 1.1 - 3.2.1.a, 3.2.1.b

This requirement provides a general scope that supports the other requirements in 7.3. It is meant to 

encourage innovation in meeting this principle while ensuring that any new design features not 

covered explicitly in 7.3 help and not hinder voters in understanding and voting their ballots 

effectively.

7.3-B – No split contests

The voting system must have the capability to displayof displaying a ballot so that no contest 

is split into two groups of options.

1. For paper ballot formats, the system must include a way of presenting a contest that 

does not divide the options across two columns or two pages.

2. For electronic interfaces, if a contest does not fit onto one screen view, the system 

must include a way to meet the requirements in 7.2-D- – Scrolling for managing the 

way the list of options is displayed. 

Discussion

There is strong evidence from recent elections that when a contest is split into two or more sections, 

there is a risk that the voter can perceive one contest as two (and overvote), or fail to see all of the 

contest options (and vote for a candidate other than the one they intend to). 

This a requirement for a capability of the ballot design or election management tools for the voting 

system to allow election officials to lay out a ballot with good usability.

External reference: WCAG 2.0/Section 508

Prior VVSG source: VVSG 1.1 - 3.2.4.e.i

Related requirementrequirements: 7.2-D – Scrolling
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7.3-C – Contest information 

All ballots must clearly indicate the office or question title and the maximum number of 

choices allowed for each contest.

1. In an electronic ballot marking interface, the information for each contest includes, in 

a consistent order: The title of the office or ballot question, including any 

distinguishing information such as the length of the term or the jurisdiction.

2. The maximum number of selections allowed in the contest.

3. In the audio format only, the number of options or candidates.

4. If any selections have already been made, the number of selections remaining.

5. In the audio format only, if any selections have been made, the currently selected 

candidates or options.

6. Any instructions or reminders of how to find marking instructions, placed visually and 

in audio after the contest information.

Discussion

This requirement is intended to work with any relevant state election laws or regulations for ballot 

design. 

For voters using audio features, best practice is to announce how many candidates or voting options 

are available, providing an audio cue similar to a visual scan of the ballot in a similar way to assistive 

technology such as screen readers. 

Placing basic instructions last helps voters using the audio format know when they can skip to making 

selections in the contest without missing any important information. 

Prior VVSG source: VVSG 1.1 - 3.2.4.e.ii

Related requirements: 7.3-C – Maximum number of selections

7.3-D – Consistent relationship 

The relationship between the name of a candidate or other voting option and the way the 

voter marks that selection, including the location onspatial relationship in the ballot layout, 

must be consistent throughout the ballot including, all typesfor each type of contestscontest.

Discussion

A type of contest includes contests to:

• vote for one or more candidates,

• answer a ballot question,
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• vote whether to retain a judge,

• indicate preferential ranking of candidates, or

• make a selection in other contests with distinct voting methods.

An example of how to meet This requirement is to ensureensures that the mechanism for marking a 

selection in a contest to elect one or more candidates to an office is not to the left of some 

candidates' names and to the right of others. If there is more than one spatial relationship, the 

difference should not be contradictory or confusing to a voter when combined on a single ballot.

Prior VVSG source: VVSG 1.1 - 3.2.4.e.iii

Related requirements: 2.2-A – User-centered design process

5.2-A – No bias

7.3-N – Instructions for voters

5.28.3-A – No biasUsability tests with voters

7.3-E – Feedback

The voting system must provide unambiguous feedback confirming the voter’s selection, 

such as displaying a checkmark beside the selected option or conspicuously changing its 

appearance. .

Discussion

This requirement applies to electronic interfaces because on paper ballots the voter supplies the 

mark to indicate a selection, not the voting system. For example, the system can display a checkmark 

beside the selected option or conspicuously change its appearance.

This requirement also applies to the audio format. It is especially important that the way the status of 

the process of making selections is announced in the audio format is unambiguous. For example, the 

phrase “is selected” and “de-selected” can sound similar, especially at faster audio speeds. Choosing 

phrases that are more distinct, paying attention to the audio phrasing, and testing with the maximum 

audio speed can help avoid this problem. 

Designers of paper ballots that include straight-party voting should test feedback features carefully to 

ensure that voters can understand the scope of their selection and the ballot options it affects.

Prior VVSG source: VVSG 1.1 - 3.2.6.b

Applies to: Electronic interfaces

Related requirements: 7.2-C – Voter control

7.3-G – Full ballot selections review
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7.3-F – Correcting the ballot 

The voting system must provide the voter the opportunity to correct the ballot before it is 

cast and counted. 

An electronic ballot interface must:

1. allow the voter to change a vote within a contest before advancing to the next 

contest,;

2. provide the voter the opportunity to correct the ballot before it is cast or printed,;

and

3. allow the voter to make these corrections without assistance. 

Discussion

For paper ballots, this can be achieved through appropriately placed written instructions, including 

requiring the voter to obtain a new paper ballot to correct a mistake.

Vote-by-mail ballots can have different instructions for making corrections from those cast in-person. 

Some voting methods allow a voter to print a replacement ballot, as long as they only cast one.

Also, note the requirements for both electronic ballot interfaces and scanners and precinct-count 

optical scanners in 7.3-H- – Overvotes belowand in 7.3-I – Undervotes.

External reference: HAVA

Prior VVSG sources: VVSG 1.1 - 3.2.2.c, 3.2.2.1.c, 3.2.2.1.d, 3.2.2.2.d

This requirement supports HAVA [HAVA02].

Related requirementrequirements: 5.2-F – Preserving votes

7.3-H – Overvotes

7.3-I – Undervotes

7.3-G – Full ballot selections review 

A voting system with an electronic voting interface must provide the voter with a function to 

review their selections before printing or casting their ballot that:

1. displays all of the contests on the ballot with:

a. the voter’s selections for that contest, or

b. a notification that they have not made a selection, or

c. a notification that they have made fewer selections than allowed, and;
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2. offers an opportunity to change the selections for a contest and return directly to 

the review screen to see the results of that change,; and

3. allows the voter to continue to the function for casting the ballot without making a 

correction at any time in the review process. 

The review function may also be provided on a scanner or other device where the voter 

marks and casts a paper ballot.

Discussion

This requirement is an implementation of the HAVA [HAVA02] requirement that voters be able to 

review and change their ballot before casting.

Electronic interfaces are required to prevent overvotes. This is usually done while originally marking a 

contest, so there are no overvoted contests to display on the review screen.

Including a review screen on a scanner that accepts ballots marked by hand gives those voters an 

opportunity to review how their ballot will be read by the scanner and make any corrections before 

casting the ballot.

External reference: HAVA

Related requirements: 5.2-F – Preserving votes

7.3-H – Overvotes

7.3-I – Undervotes

7.3-H – Overvotes 

The voting system must notify the voter if they attempt to select more than the allowable 

number of options within a contest (overvotes) and inform them of the effect of this action 

before the ballot is cast and counted. 

1. An electronic ballot interface must prevent voters from selecting more than the 

allowable number of options for each contest. 

2. A scanner or other device that a voter uses to cast a paper ballot must be capable of 

providing feedback both visually and in audio format to the voter that identifies 

specific contests for which the voter hasthat have been overvoted. in visual format, 

and with either audio format or sound cues.

Discussion

This requirement does not specify exactly how the system will respond when a voter attempts to 

select an "extra" candidate. For instance, the system can present the warning, or, in the case of a 

single-choice contest (vote for 1), simply change the vote selection and issue a warning.
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For electronic ballot interfaces, this requirement does not allow disabling the features that prevent 

overvotes. 

In the case ofVoters marking paper ballot systems, votersballots can be informed of the effect of 

overvoting through appropriately placed instructions.

This requirement supports HAVA [HAVA02].

Applies to:In all cases, all requirements for accessibility apply to the notifications and warnings.

External reference: HAVA

Prior VVSG sources: VVSG 1.1 - 3.2.2.a, 3.2.2.1.a, 3.2.2.2.a

Electronic interfaces and ballot scanners

Related requirements: 5.1-D – Accessibility features 

7.2-C – Voter control

7.3-K – Warnings, alerts, and instructions

Applies to: Electronic interfaces and ballot scanners

7.3-I – Undervotes

The voting system must notify voters in both visual and audio formats of the specific contest 

in which they select fewer than the allowable number of options (that is, for undervotes).

1. Both electronic interfaces and scanners must allow the voter to submit an 

undervoted ballot without correction. 

2. The voting system may allow election officials to disable the notification of 

undervotes on a scanner.

Discussion

For electronic interfaces, this notification can be incorporated into the review feature. 

External reference: HAVA

Prior VVSG sources: VVSG 1.1 - 3.2.2.b, 3.2.2.1.b

This requirement supports HAVA [HAVA02].

Applies to: Electronic interfaces and scanners

Related requirementrequirements: 7.2-C – Voter control

7.3-K – Warnings, alerts, and instructions
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Applies to: Electronic interfaces and scanners7.3-J – Notification of 

casting

If the voter successfully casts or prints the ballot, the The voting system must letnotify the 

voter know in both visual and audio format that they succeeded. 

1. If the voter takes the appropriate action to whether their ballot was successfully or 

unsuccessfully cast. If a ballot, but the electronic interface does is not accept and 

record it successfully cast (that is, the device did not complete the documented 

procedures for the system, including failure to store thereading a paper ballot, 

recording an electronic image, then or record, or transporting the interfaceballot to a 

ballot box), the voting device must letnotify the voter know and provide clear 

instruction as to the steps the voter willneeds take to cast the ballot.

1. If the voter takes the appropriate action to cast a ballot, but the system does not accept 

and record it successfully, including failure to read the ballot or to transport it into the 

ballot box, the system must let the voter know. 

2. A scanning device must also be capable of notifying the voter that they have 

submittedcast a paper ballot that is blank on one or both sides. The system may 

provide a means for an authorized election official to deactivate this capabilitythe 

notification of a blank ballot.

Discussion

The purpose of this requirement is to provide feedback to voters to assure them that the voting 

session has been completed. Note that either a false notification of success or a missing confirmation 

of actual success violates this requirement. 

Detecting situations in which the voter might be unaware that the ballot is two-sided and left one 

side blank is distinct from the ability to detect and warn about undervoting. 

At a minimum, this requirement is intended to ensure that blind and low-vision voters receive an 

audio notification that a ballot is successfully cast. This might be a sound that is the audio equivalent 

of a waving flag or other visual.

External references: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG sources: VVSG 1.1 - 3.2.2.d, 3.2.2.1.f, 3.2.2.2.c, 3.2.2.2.g, 3.2.2.2.a, 

3.2.2.1.b

7.3-K – Warnings, alerts, and instructions

Warning, alerts, and instructions issued by the voting system must be distinguishable from 

other information.

1. Warnings and alerts must clearly state in plain language:
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a. the nature of the issue or problem,

b. whether the voter has performed or attempted an invalid operation or 

whether the voting system itself has malfunctioned in some way, and

c. the responses available to the voter. 

2. Each distinctstep in an instruction or item in a list of instructions must be separated

from others:

a. spatially in a visual presentation, formats, and

b. with a noticeable pause forin audio formats.

Discussion

For instance, “Do you need more time? Select ‘Yes’ or ‘No’.” rather than “System detects imminent 

timeout condition.” In case of an equipment failure, the only action available to the voter might be to 

get assistance from an election worker. 

Keeping instructions separate includes not "burying" several unrelated instructions in a single long 

paragraph. 

Alerts intended to confirm visual changes to a voter using the audio format (such as confirmation 

that the screen has been turned on or off) can be communicated in audio, with a short text or sound.

External references: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG sources: VVSG 1.1 - 3.2.4.c.i, 3.2.4.c.iv

7.3-L – Icon labels

When an icon is used to convey information, indicate an action, or prompt a response, it 

must be accompanied by a corresponding label that uses text. 

The only exception is that the two 3.5 mm (1/8 inch) jacks for audio and personal assistive 

technology (PAT) may be labeled with tactilely discernable and visually distinct icons of a 

headset (for audio) and wheelchair (for the PAT connector) that are at least 13 x 13 mm in 

size.

Discussion 

While icons can be used for emphasis when communicating with the voter, they are not to be the 

only means by which information is conveyed, since there is no widely accepted "iconic" language, 

and therefore, not all voters might understand a given icon. The exception is based on the ADA 

Standards for Accessible Design. Chapter 7 [ADA10]. 

External references: WCAG 2.0/Section 508
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Prior VVSG source: VVSG 1.1 - 3.2.4.g

Related requirementrequirements: 7.1-N – Tactile keys

7.2-R – Control labels visible

8.1-E – Standard audio connectors

8.1-I – Standard PAT jacks

7.3-M – Identifying languages

When presenting a list of languagesA vote-capture device or other voting session device that 

offers language options to thea voter:

the electronic ballot interface must use the native name of each language, and:

1. visibly present the controls to identify or change language must be visible on the 

screen at all times, not hidden inwithin a help or settings feature., and

1.2. include the native version of each language name in the list of language options.

Discussion 

Voters looking for an option for an alternative language can recognize it more easily as it is written in 

the language itself. 

The English name or spelling can also be used to identify language, along with the native name.

External reference: VRA

Prior VVSG source: VVSG 1.1 - 3.2.7.a.i

Applies to: Electronic interfaces

7.3-N – Instructions for voters 

The voting system must provide voters withaccess to instructions for all its operations at any 

time during the voting session. 

1. For electronic interfaces, the voting system must provide a way for voters to get help 

directly from the system.

2. For paper ballots, the system must be capable of including on the ballot both text and 

images with instructions for how to mark the ballot. 

3. Best practice is for all Voting systems tomust present all instructions, including the 

verification process, near to where they are needed during the voting session.

Discussion

The purpose of this requirement is to minimize voters’ need for assistance from an election worker 

and to permit the voter to cast and verify and cast, privately and independently, the votes selected.
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When the system works correctly, the voter will find the help they need from the system when and 

where they need it. For instance, only general instructions should be grouped at the beginning of the 

ballot; those pertaining to specific situations should be presented near those situations.

If an operation is available to the voter, it will be documented. Examples include how to make a vote 

selection, navigate among contests, cast a straight-party vote, cast a write-in vote, adjust display and 

audio characteristics, or select a language.

Electronic ballot interface systems often provide assistance with a distinctive "help" button. 

Instructions can be on the ballot itself or separate from the ballot, as long as the voter can find them 

easily.

External references: WCAG 2.0/Section 508

Prior VVSG sources: VVSG 1.1 - 3.2.4.a, 3.2.4.b, 3.2.4.e.iv, 7.8.6.g

Related requirementrequirements: 5.1-F – Accessibility documentation 

7.3-O – Instructions for election workers

The voting system must include clear, complete, and detailed instructions and messages for 

setup, polling, shutdown, and how to use accessibility features. 

1. The documentation required for normal voting system operation must be:

a. presented at a level appropriate for election workers who are not experts in 

voting system and computer technology, and 

b. in a format suitable for use in the polling place.

2. ThePrinted procedural instructions, and on-screen instructions and messages must

enable the election workers to verify that the voting system

a. has been set up correctly (setup),

b. is in correct working order to record votes (polling), and

c. has been shut down correctly (shutdown).

Discussion

This requirement covers documentation for those aspects of system operation normally performed 

by election workers and other "non-expert" operators. It does not address inherently complex 

operations such as ballot definition. The instructions are usually in the form of a written manual, but 

can also be presented on other media, such as a DVD or videotape. In the context of this 

requirement, "message" means information delivered by the system to the election workers as they 

attempt to perform a setup, polling, or shutdown operation. For Specific guidance on how to 
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implement this requirement, please see: “NISTIR 7519: Style Guide for Voting System 

Documentation” at http://www.nist.gov/itl/vote/upload/NISTIR-7519.pdf. is contained in [NIST08].

For instance, the documentation should not presuppose familiarity with personal computers. And a 

single large reference manual that simply presents details of all possible operations would be difficult 

to use, unless accompanied by aids such as a simple "how-to" guide.

It is especially important that election workers and other non-expert workers know how to set up 

accessibility features which are not used frequently. This will help ensure voters who need these 

features can vote privately and independently.

Overall, election workers should not have to guess whether a system has been setup correctly. The 

documentation should make it clear what the system "looks like" when correctly configured.

Prior VVSG sources: VVSG 1.1 - 3.2.8.1.c, 3.2.8.1.c.i, 3.2.8.1.c.ii, 3.2.8.1.c.iii

Related requirementrequirements: 5.1-F – Accessibility documentation 

7.3-P – Plain language

Information and instructions for voters and election workers must be written clearly, 

following the best practices for plain language. This includes messages generated by the 

voting system for election workers in support of the operation, maintenance, or safety of the 

system. 

Discussion

The plain language requirements apply to instructions that are inherent to the voting system or that 

are generated by default. To the extent that instructions are determined by election officials 

designing the ballot, they are beyond of the scope of this requirement. 

Any legally required text is an exception to this plain language requirement.

Plain language best practices are guidelines for achieving clear communication and include: 

• Using familiar, common words and avoiding technical or specialized words that voters are not 

likely to understand. For example, "There are more contests on the other side" rather than 

"Additional contests are presented on the reverse." 

• Issuing instructions on the correct way to perform actions, rather than telling voters what not to 

do. For example, “Fill in the oval for your write-in vote to count” rather than, “If the oval is not 

marked, your write-in vote cannot be counted.”

• Addressing the voter directly rather than use passive voice when giving instructions. For 

example, "remove and retain this ballot stub" rather than "this ballot stub must be removed and 

retained by the voter."
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• Stating a limiting condition first, followed by the action to be performed when an instruction is

based on a condition. For example, use "In order to change your vote, do X", rather than "Do X, 

in order to change your vote."

• Avoiding the use of gender-based pronouns. For example, "Write in your candidate’s name 

directly on the ballot" rather than "Write in his name directly on the ballot." 

For specific guidance on how to implement this requirement, see: “Guidelines for Writing Clear 

Instructions and Messages for Voters and Poll Workers” at 

https://www.nist.gov/sites/default/files/documents/itl/vote/032906PlainLanguageRpt.pdf .

[NIST09a]. Although part of general usability, using plain language is also expected to assist voters 

with cognitive disabilities. 

Information written in plain language is easier to translate to meet language access requirements. 
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See the guidance paper on Testing for Plain Language for information on how this requirement 

might be tested using both automated evaluation programs and manual inspection.

External references: WCAG 2.0/Section 508

Prior VVSG sources: VVSG 1.1 - 3.2.4.c, 3.2.8.a, 3.2.4.c,ii, 3.2.4.c.iii, 3.2.4.c.v, 

3.2.4.c.vi, 3.2.4.c.vii

Principle 8

Robust, Safe, Usable, and 

Accessible

The voting system and voting processes provide a robust, safe, usable, 

and accessible experience. 

8.1 - The voting system’s hardware, software, and accessories are 

robust and do not expose users to harmful conditions. 

8.2 - The voting system meets currently accepted federal standards for 

accessibility. 

8.3 - The voting system is evaluated for usability with a wide range of 

representative voters, including those with and without disabilities. 

8.4 - The voting system is evaluated for usability with election workers.
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Principle 8

ROBUST, SAFE, USABLE, AND ACCESSIBLE

The voting system and voting processes provide a robust, safe, usable, 

and accessible experience.

This principle covers how the voting system performs in use, including physical safety and 

the usability and accessibility of the complete voting system. The guidelines under Principle 8

are:

1 - Protect from harmful conditions covers requirements that ensure the voting system is 

Robust (completing the Web Content Accessibility Guidelines’ (WCAG’s) organizing principles 

known as POUR (Perceivable, Operable, Understandable, Robust)) and does not present any 

harmful conditions to voters and election workers. It addresses how an electronic screen 

displays information the voter needs and covers personal assistive technology (PAT) and 

topics such as audio connectors, jacks, hearing aids, and handsets.

2 - Meet accessibility standards explicitly includes the entire federal standard for 

accessibility, the basis for many of the requirements in Principle 7 for voting system 

electronic interfaces. This standard can fill in any gaps the VVSG 2.0 does not specifically 

address. This is especially important for the part of the voting system that might use general 

interfaces, such as a browser-based ballot marking system that runs on personal computers.

3 and 4 - Usability tests require usability testing the voting system to ensure that it not only 

meets the detailed design requirements but will function well for both voters and election 

workers in use. Testing with a variety of voters, including those with and without disabilities, 

ensures the voting system is usable and assessibleaccessible to all voters. The testing with 

election workers ensures that he system’s setup, polling, and shutdown are relatively easy to 

learn, understand, and perform.

Principle 8 is related to Guideline 2.2, which requires a user-centered design and 

development process for the entire voting system. It covers election workers and a wide 

range of representative voters, including those with and without disabilities.
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8.1 – The voting system’s hardware, software, and accessories are 

robust and do not expose users to harmful conditions.

8.1-A – Electronic display screens

If the voting system uses an electronic display screen, the display must have the following 

characteristics:

1. For all electronic display screens:

a. antiglare screen surface that shows no distinct virtual image of a light source 

or a means of physically shielding the display from such reflections, and

b. minimum uniform diffuse ambient contrast ratio for 500 lx illuminance: 10:1.

2. If the display is the primary visual interface for making vote selections:

a. minimum diagonal display size: 12 inches, and

b. minimum display resolution: 1920 x 1080 pixels.

3. If the display screen is for messages to voters or poll workers:

a. minimum diagonal display size: 7.9.5 inches, and

b. minimum display resolution: 1280x8001024x768 pixels.

Discussion

Displays that measure larger than the 12-inch diagonal provide the opportunity for ballot layouts that 

can more easily use large text settings.

Prior VVSG sources: VVSG 1.1 - 3.2.5.a, 3.2.5.a.ii, 3.2.5.a.iii, 3.2.5.a.iv, 3.2.5.a.v, 

3.2.5.a.vi, 3.2.5.a.vii

Applies to: Electronic interfaces

8.1-B – Flashing

If the voting system emits lightslight in flashes, there must be no more than three flashes in 

any one-second period.

Discussion

This requirement has been updated to meet WCAG 2.0 [W3C10] and Section 508 [USAB18] software 

design issue standards, see:.
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Requirements for VVSG 2.0 February 29, 202010, 2021

• WCAG 2.0 requirements for flickering and flashing 

• Section 508 requirements for flicker and flash 

External references: WCAG 2.0/Section 508

Prior VVSG sources: VVSG 1.1 - 3.2.5.a.i

Applies to: Electronic interfaces

Applies to: Electronic interfaces

8.1-C – Personal Assistive Technology (PAT) 

The support provided to voters with disabilities must be intrinsic to the voting system. This 

means so that a voter’s personal assistive devices will not be necessary to operate the voting 

system correctly. This does not apply to personal assistive technology required to comply 

with 5.1-A.

Discussion

This requirement does not preclude the voting system from providing interfaces to assistive 

technology. (See definition of "personal assistive devices" in theAppendix A - Glossary). Its purpose is 

to ensure that voters are not required to bring special devices with them in order to vote 

successfully. 

This requirement assumes that voters will have with them anycan use their personal headsets, 

hearing aids, eyeglasses, canes, or other assistive devicesaids they customarily usetypically have with 

them.

See the White Paper: Assistive Technology in the Polling Place: Current and emerging technology, 

Dec. 28, 2016 

External references: WCAG 2.0/Section 508

Prior VVSG source: VVSG 1.1 - 3.3.1.c

8.1-D – Secondary ID and biometrics

If a voting system uses biometric measures for identifying or authenticating voters and 

election workers, it must provide an alternative that does not depend on the same biometric 

capabilities. 

Discussion

For example, if fingerprints are used for voter identification, another mechanism will be provided for 

voters without usable fingerprints. 

External references: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

Prior VVSG source: VVSG 1.1 - 3.3.1.d
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8.1-E – Standard audio connectors

The voting system must provide its audio signal for the audio format interface through an 

industry standard connector using a 3.5 mm (1/8 inch) stereo headphone jack to allow voters 

to use their own audio assistive devices for private listening.

External references: WCAG 2.0/Section 508

Prior VVSG source: VVSG 1.1 - 3.3.3.c.i

Applies to: Electronic interfaces

8.1-F – Discernable audio jacks

The audio jack on any voting station device must be in a location that voters can easily 

discover, discernable by touch while sitting or standing in front of the unit, and not located 

near a sharp edge.

Discussion

For example, if the jack is slightly recessed with a round bezel, it will be easier for voters to identify 

the jack and to insert the headset plug into it. 

8.1-G – Telephone style handset

If the voting system uses a telephone style handset or headphone to provide audio 

information, it must provide a wireless T-Coil 9 coupling for assistive hearing devices so it 

provides access to that information for voters with partial hearing, achieving at least a 

category T4 rating as defined by the American National Standard Institute (ANSI) for 

Methods of Measurement of Compatibility between Wireless Communications Devices and 

Hearing Aids, ANSI C63.19 [ANSI11-2019 [ANSI19]. 

Discussion

External references: This requirement applies only to telephone style handsets/headphones to 

ensure their compatibility with assistive hearing devices. 

This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

ANSI C63.19

Prior VVSG source: VVSG 1.1 - 3.3.3.c.ii

Related requirement: requirements: 6.1-D – Audio privacy

8.1-J – Hearing aids

6.1.2 – Audio privacy
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8.1-H – Sanitized headphones

The voting system must be supplied with a means to sanitize headphones or handsets and 

instructions for election workers on the procedure to ensure that a sanitized headphone or 

handset must be madeis available to each voter. 

Discussion

This requirement can be achieved in various ways, including the use of "throwaway" headphones or 

sanitary coverings. 

Prior VVSG source: VVSG 1.1 - 3.3.3.c.iii

8.1-I – Standard PAT jacks 

A vote-capture device or other voting stationvoter-facing device must provide a 3.5 mm (1/8 

inch) industry standard jack voters can use to connect their personal assistive technology 

switch to the system. 

1. ThisThe jack must allow only switch dataactivations to be transmitted to the system.

2. The system must accept switch input that is functionally equivalent to other input 

methods. 

3. All the functionality of the voting system must be available through technology using 

this input mechanism.

Discussion 

This requirement is related to the requirements for low dexterity modes (in 5.1-A – Voting methods 

and interaction modes and in 7.2-A – Display and interaction options). It ensures that the voting 

systems are operable by voters with limitedvery low dexterity, in particular those who do not have 

the use of their hands. can use the vote-capture devices by providing a means for them to connect 

personal assistive technology (PAT) if they cannot use the supplied touch or tactile input devices. 

Examples of personal assistive technology switches include dual switches (sometimes called 

“adaptive switches” or “jelly switches”) and "sip and puff" devices that communicate as a single key 

press.

Ideally, the jack will be on the tactile keypad or have some other mechanism to provide sufficient 

reach to a wheelchair tray or the voter’s lap.

While it is desirable that the voter be able to independently initiate use of the non-manual input 

mechanism, this requirement guarantees only that the voter can vote independently once the 

mechanism is enabled.

The PAT jack is separate from the audio jack required in 8.1-F – Discernible audio jacks, which 

connects to the audio output provided by the system.
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Related requirements: External references: WCAG 2.0/Section 508

Prior VVSG source: VVSG 1.1 - 3.3.4.a

5.1-A – Voting methods and interaction modes

7.2-A – Display and interaction options

8.1-J – Hearing aids

Voters who use assistive hearing devices must be able to use voting devices as intended:

1. The voting device must not cause electromagnetic interference with assistive 

hearing devices that would substantially degrade the performance of those devices. 

2. The voting device, measured as if it were a wireless device, must achieve at least a 

category T4 rating as defined by American National Standard [ANSI11] for Methods 

of Measurement of Compatibility between Wireless Communications Devices and 

Hearing Aids, ANSI C63.19 [ANSI11-2019 [ANSI19].

Discussion

"Hearing devices" include hearing aids and cochlear implants.

External references: This requirement is based on WCAG 2.0/ [W3C10] and Section 508 [USAB18].

ANSI C63.19

Prior VVSG source: VVSG 1.1 - 3.3.6.c

Related requirementrequirements: 8.1-G – Telephone style handset

8.1-K – Eliminating hazards

Devices associated with the voting system must be certified in accordance with the 

requirements of IEC/UL 6095062368-1 [UL07],UL19], Edition 3: Standard for Audio/video,

Information and Communication Technology Equipment –- Part 1: Safety – Part 

1requirements by a certification organization accredited by the Department of Labor, 

Occupational Safety and Health Administration’s Nationally Recognized Testing Laboratory 

program. 

The certification organization’s scope of accreditation is acceptable if it includes IEC/UL 

6095062368-1 [UL07UL19]. 

Discussion 

IEC/UL 6095062368-1 is a comprehensive standard for IT equipment and addresses all the hazards 

discussed above under Safety. It replaces IEC/UL 60950-1 [UL07]. 
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External references: IEC/UL 60950-1

Prior VVSG sources: VVSG 1.1 - 3.2.8.2.a, 3.2.8.2.b
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8.2 – The voting system meets currently accepted federal standards for 

accessibility.

8.2-A – Federal standards for accessibility

Voting systems must meet federal standards for accessibility, including the current version of 

Section 508 of the Rehabilitation Act,Information and Communication Technology (ICT) Final 

Standards and Guidelines [USAB18], in effect as of January 18, 2018, and the WCAG 2.0 Level 

AA checkpoints [W3C10] included in that standard.

Discussion

The This applies to all parts of the voting system including the election management system (EMS).

Section 508 standards apply to electronic and information technology, including computer hardware 

and software, websites, multimedia, and other technology such as video, phone systems, and 

copiers. The final rule was published in the Federal Register on January 18, 2017 as 36 CFR Parts 1193 

and 1194 (RIN 3014-AA37) and can be found on the Access Board website: https://www.accessboard.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-ruleThis 

requirement also supports the ADA [ADA10].

External references: WCAG 2.0/Section 508 and ADA

Applies to: Electronic interfaces, including EMS

Applies to: Electronic interfaces
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8.3 – The voting system is evaluated with a wide range of 

representative voters, including those with and without 

disabilities.

8.3-A – Usability tests with voters

The manufacturer must conduct usability tests onwith voters using the voting system, 

including all voter activities in a voter session from ballot activation to verification and 

casting. 

The test participants must include voters who represent the following:

1. General population, using the visual interface (without audio), including:

a. voters who speak all are native speakers of the language being tested for each 

language defined as supported languages as their primary languagein the 

technical data package (TDP);

b. blind voters, using the audio format plus tactile controls;

c. voters with low vision, using the enhanced visual features with orand without 

audio; and

d. voters with limited dexterity, using the visual-tactile interface with low and no 

dexterity controls.

2. The manufacturer must submit a report of the results of their usability tests, 

including effectiveness, efficiency, and satisfaction measures, as part of the Technical 

Data Package (TDP) using the version of theISO/IEC 25062:2006: Common Industry 

Format modified(CIF) for voting systems (CIF-for-Voting Systems).Usability Test 

Reports [ISO06b].

Discussion

Voting system developers are required to conduct realistic usability tests on their product before 

submitting the system to conformance testing. This is to ensure that the user-centered design 

process required for quality implementation has produced a usable and accessible voting system.

Prior VVSG sources; VVSG 1.1 - 3.3.3.a, 3.3.3.a.i, 3.3.10.a-c, 3.2.7.a.iv

Related requirements: 5.1-D – Accessibility features

2.2-A – User-centered design process

5.1-D – Accessibility features
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8.4 – The voting system is evaluated for usability with election workers.

8.4-A – Usability tests with election workers

The manufacturer must conduct usability tests of the voting system setup, pollingoperation 

during voting, and shutdown as documented by the manufacturer, with representative 

election workers, to demonstrate that election workers can learn, understand, and perform 

these tasks successfully.

The tasks to be covered in the test must include: 

1. Setup and opening for voting, which involves:

a. operation during voting;

b. use of assistive technology or language options that are part of the voting 

system;

c. shutdown at the end of a voting day during a multi-day early voting period, if 

supported by the voting system;

d. shutdown at the end of voting including running any reports;

e. providing ballots in different languages;

f. selecting the correct ballot type (for example, for vote centers)); and

g. setting up the voting system to use different display formats and interaction 

modes.

2. The test participants must include typical election workers representing a range of 

experience.

3. The manufacturer must submit a report of the results of their usability tests, as part 

of the Technical Data Package (TDP) using theISO/IEC 25062:2006: Common Industry 

Format modified(CIF) for voting systems (CIF-for-Voting Systems).Usability Test 

Reports [ISO06b].

Discussion

This requirement coversVoting system manufacturers are required to conduct realistic usability tests 

on their product before submitting the system to conformance testing. This is to ensure that the 

user-centered design process required for quality implementation has produced a usable and 

accessible voting system. This requirement covers the procedures and operations for those aspects 

of system operation normally performed by election workers and other "non-expert" operators. It 

does not address inherently complex operations such as ballot definition or system repair. These 
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"normal" procedures should not require any special expertise. The procedures may require a 

reasonable amount of training, similar to the training generally provided for temporary election 

workers.

Prior VVSG sources: VVSG 1.1 - 3.2.8.1.a, 3.2.8.1.b, 3.2.8.1.b.i

Related requirement: requirements: 2.2-A – User-centered design process

7.3-NO – Instructions for election workers
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2.2-A – User-centered design process

Principle 9

Auditable

The voting system is auditable and enables evidence-based elections. 

9.1 - An error or fault in the voting system software or hardware cannot 

cause an undetectable change in election results. 

9.2 - The voting system produces readily available records that provide 

the ability to check whether the election outcome is correct and, to the 

extent possible, identify the root cause of any irregularities. 

9.3 - Voting system records are resilient in the presence of intentional 

forms of tampering and accidental errors. 

9.4 - The voting system supports efficient audits.
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Principle 9

AUDITABLE

The voting system is auditable and enables evidence-based elections.

The requirements for Principle 9 include ensuring that an error in the voting system cannot 

cause an undetectable change in the election results, that the system produces records that are 

resilient and can be checked, and produces records that enable an efficient compliance audit.

Delivery, return, and non-voting equipment process used for vote-by-mail fall out of the scope 

of the VVSG and is often based on jurisdictional procedure.

The sections in Guideline 9.1 cover:

1 - Software independence requires that the voting system provide proof that the ballots have 

been recorded correctly and are compliant within the Paper-based System Architecture or 

Cryptographic E2E System Architectures. In addition, the manufacturer documents the 

mechanism used to provide software independence. These requirements ensure that failures in 

voting system software can be detected and rectified

2 – Tamper-evident

2 – Tamper-evidence requires the records used to record ballet selections cannot be 

undetectably altered. These records are needed to enable detection of incorrect election 

outcomes. They need to capture the voter’s ballot selection when each ballot is cast.

3 -– Voter verification records need torequires that voting machines allow voters the 

opportunity to verify that the system correctly interpreted their ballot selections and that they 

can , identify errors with their selections, and restart a voting session if a ballot is unacceptable.

Records that protect against software failures only work if voters can verify their selections are 

correct.

4 – Auditable means the voting system generates records that enable external auditors to 

verify that ballots are correctly tabulated, even if the system is compromised or there are faults 

in components. The manufacturer is to provide a procedure to verify that cast records are 

correctly tabulated.

5 -– Paper records covers the requirementrequirements that thepaper-based (not cryptographic 

end-to-end verifiable) voting systemsystems produce a verifiable paper record of the voter’s 

ballot selection and retain a copy of that selection which has a unique identifier. The voter 

needs to be able to understand the recorded ballot selection and it needs to agree with the 

selections made by the voter.
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6 - Cryptographic E2E cryptographyverifiable deals with the protocolcryptographic protocols

used in thecryptographic E2E verifiable (not paper-based) voting systemsystems, requiring that

itthey be publicly available for review for 2 years before it enters thebeing used in a voting 

system. Individuals who vote on a cryptographic E2E verifiable system will get a receipt and be 

able to confirm that the system correctly interpreted their ballot selections. Voters will also be 

able to verify that their ballots are included in the tabulation results.

7 -

In 9.2 – Audit support deals with the requirementrequires that manufacturers identify the types 

of audits supported by a voting system, ensuring the system manufacturer documentscan handle 

audits held by election officials. The manufactures are also required to include any artifacts that

the procedurevoting system produces to determinesupport the number of ballots to be checked 

to reach an election-official-specified margin of error for a given contest, including the possible 

use of random numbers.

In 9.2 – Audit procedures deals with the need to produce readily available records so the 

election outcomes can be checked for correctness, and also help identify the cause of any 

irregularities. Problems need to be identified in a post-election audit both during the audit and 

when completed. The voting systems needs to count and report the number of ballots castaudits.

In 9.3 - Resilient records coversrequires the data protection requirements necessaryunder

Principle 13: Data Protection are followed to ensure that voting system records are resilient in 

the presence of both intentional forms of tampering and accidental errors.

In 9.4 - Efficient audit describesaudits covers requirements that ensure the system that will 

produce the records that assistallow election officials in conducting compliance auditsto

conduct risk-limiting audits. Risk-limiting audits can detect the accuracy of a vote count within 

this specified margin of error.
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Requirements for VVSG 2.0 February 29, 202010, 2021

9.1 - An error or fault in the voting system software or hardware 

cannot cause an undetectable change in election results.

9.1.1 – Software independence 

9.1.1-A – Software independent

The voting system must be software independent.

1. The voting system must meet the requirements within the Paper-based System 

Architectures or Cryptographic E2E Verifiable System Architectures section, or both.

2. The voting system documentation must include the method used to provide 

software independence.

Discussion

Software independence [Rivest06] means that an undetected error or fault in the voting system’s 

software is not capable of causing an undetectable change in election results. All voting systems need 

to be software independent in order to conform to the VVSG. 

There are two essential concepts behind applying software independence:

• it ismust be possible to audit voting systems to verify that ballots are being recorded correctly,

and

• testing software is so difficult that audits of voting system correctness cannot rely on the 

software itself being correct. 

Therefore, voting systems need to be ‘software independent’ so that the audits do not have to trust 

that the voting system’s software is correct. The voting system will provide proof that the ballots 

have been recorded correctly, that is, voting records will be produced in ways in which their accuracy 

does not rely on the correctness of the voting system’s software. 

This is a major change from previous versions of the VVSG, because previous versions permitted 

voting systems that are software dependent, that is, voting systems whose audits rely on the 

correctness of the software. One example of a software dependent voting system is the DRE, which is 

now non-conformant to this version of the VVSG.

There are currently two methods specified in the VVSG for achieving software independence: 

• through the use of independent voter-verifiable paper records, and

• E2E cryptographic E2E verifiable voting systems.

Prior VVSG source: VVSG 2007 - 2.7-A
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Requirements for VVSG 2.0 February 29, 202010, 2021

9.1.1-B – Paper-based orand cryptographic E2E verifiable system

Voting systems must meet the requirements within the Paper-based System Architectures or 

Cryptographic E2E System Architectures section, or both.

Discussion

Both of these architectures are software independent, but they and both can both be used within the 

same voting system. In this case where a voting system is identified as being a combination of both 

architectures, the system would need to be compliant with both sets of requirements. However, a 

system that meets all of the paper-based requirements need not satisfy the E2E-requirements even if 

it incorporates E2E verifiable functionality. 

9.1.1-C –Mechanism documentation

A voting system manufacturer must documentKnowing the specific mechanism used to 

provideachieve software independence.

assists with determiningDiscussion

Without knowing the specific mechanism, it is difficult to determine if the system is truly is software 

independent.

ThisThe documentation should explain how any changes to the election outcome are detectable 

regardless of any fault or error in the voting system software. This may include how the voting 

systems handles a ballot after it is cast by the voter. For example, this documentation may answer 

the following questions:

• Is it able to print on the ballot?

• What information is printed on the ballot? 

• Where is that information printed?

Related requirements can be found under: 9.1.5 – Paper records

9.1.6 – Cryptographic E2E verifiable

9.1.2 – Tamper evidence

9.1.2-A – Tamper-evident records

The voting system must produce tamper-evident records that enable detection of incorrect 

election outcomes, including:

1. capturing the contents of each vote at the time of each ballot’s casting, and

2. recording detected errors in a tamper-evident manner.
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Discussion

Tamper-evident records include paper ballotsCVRs, ballot images and artifacts from ana

cryptographic E2E verifiable voting system. 

The record also ensures that identified issues and other problems cannot be lost or unintentionally 

modified once they are discovered.

Applies to: Voting Device

9.1.2-B – Tamper-evident record creation

APaper records or other tamper-evident recordelectronic records of the voter’s ballot 

selections must be captured when each ballot is cast.

Discussion

Precinct-based voting systems are the only way to meet this requirement. Entirely separate voting 

channels, such as remote vote-by-mail, do not offer this opportunity to the voter.

Voter-facing scanners and other vote-capture devices produce the paper records or other tamper 

evident electronic records. These records can be useful artifacts for post-election audits. 

Applies to: Precinct-based voting systemsVoter-facing scanners and 

electronic ballot markers

9.1.3 – Voter verification

9.1.3-A – Records for voter verification

The voting system must provide individual voters the opportunity to verify that the voting 

system correctly interpreted their ballot selections.

Discussion

Precinct-based voting systems are the only way to meet this requirement. Entirely separate voting 

channels, such as remote postal voting, do not offer this opportunity to the voter.

• Voter-facing scanners and other vote-capture devices can be used to meet this requirement. An 

electronic ballot marker can print a voter’s ballot selections to review before casting. An E2E 

verifiable system can print a receipt that allows a voter to verify their selections are tabulated and 

captured correctly. Principle 7: Marked, Verified, and Cast as Intended includes more requirements 

for voter verification. 
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Applies to: Vote Capture Devices Voter-facing scanners and electronic 

ballot markers

Related requirements: 7.3-G – Full ballot selections review

9.1.3-B – Identification of errors

The voting system must offer voters the opportunity to identify ballot errors before it is cast. 

Applies to: Paper-based system architectures 

Cryptographic E2E system architectures

9.1.3-C – Ballot error correction

The voting system must allow a voter to restartstart a new voting session if a ballot is 

deemed unacceptablethey would like to correct an error found in their ballot selections.

Discussion

If, after printing their ballot, a voter decides they would like to update or change a selection before 

casting, the voter must be able to get a new ballot and start a new voting session to mark their ballot 

as they intend. A voter can contact a poll worker to spoil their current ballot, receive a new ballot, 

and start a new voting session. 

Applies to: Paper-based system architectures 

Related requirements: 7.3-F – Correcting the ballot

9.1.3-DC – Voter reported errors

Voting system documentation must describe a method, either through procedural or 

technical means, for voters to report detected errors or incorrect results. 

Discussion

This can include a voter alerting an election worker or pressing a button on the machine to report 

detected errors or incorrect results. 

9.1.4 – Auditable

9.1.4-A – Auditor verification

Voting systems must generate records that would enable external auditors to verify that cast 

ballots were correctly tabulated. 

Discussion
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Requirements for VVSG 2.0 February 29, 202010, 2021

The voting systems themselves cannot make records available to the public. The manner and decision 

to make these records available is made by a state and or local jurisdiction. This requirement only 

ensures that the records themselves are generated and can be easily accessed without additional 

software or assistance from the voting system manufacturer. This requirement is meant to enable 

external auditors to perform their own count of the election results.

Applies to: Voting Device

Related Requirements: Principle 1 – High Quality Design

9.1.4-B – Auditable with compromised software, firmware, or hardware

The voting system must enable a meaningful audit in the presence of:

1. compromised or malicious software resident on the system 

2. compromised or malicious hardware components

3. faults or errors in software components

4. faults or errors in hardware components

9.1.4-BDiscussion

The production of tamper evidence records protects against this scenario.

9.1.4-C – Documented procedure

The voting system manufacturer must provide a documented procedure to verify that cast 

ballots were correctly tabulated.

Discussion

This documentation includes procedures and technical practices that verify the results post-election. 

and demonstrates software independence. This documentation could be used as a starting point for 

election officials to develop the procedures used to audit an election.

Related requirements: 9.1.1-A – Software independent

9.1.5 – Paper records 

9.1.5-A – Paper record production

The A paper-based voting system must produce an independently a voter-verifiable paper 

record of the voter’s ballot selections. 

Discussion
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Requirements for VVSG 2.0 February 29, 202010, 2021

Voting systems that use independent voter-verifiable records can satisfy the software independence 

requirement and achieve conformance to the VVSG.

Applies to: Paper-based system architectures 

Related requirements: 3.3-C – Bar and other codes

3.3-D – Ballot selection codes

5.1-E – Reading paper ballots

6.1-A – Preserving privacy for voters

6.2-A – Voter independence

9.1.5-C – Paper record intelligibility

9.1.5-D – Matching selections

9.1.5-B – Paper record retention

TheA paper-based voting system must retain a paper record of the voter’s ballot selections. 

Applies to: Paper-based system architectures 

9.1.5-C – Paper record intelligibility 

The recorded ballot selections must be presented in a human-readable format that is

understandable by the voter. 

Discussion

The requirement ensures that a human-readable version of the data is also printed whenever a 

barcode is used to encode ballot selections.

Applies to: Paper-based system architectures 

9.1.5-D – Matching selections 

All representations of a voter’s ballot selections produced by the voting system must agree 

with the selections made by the voter. 

Applies to: Paper-based system architectures

9.1.5-E – Paper record transparency and interoperability

All barcode representations of a voter’s ballot selections must use an open and 

interoperable format. 

Applies to: Paper-based system architectures 

Related requirements: 3.3-C – Bar and other codes

3.3-D – Ballot selection codes
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9.1.5-F – Unique identifier

EachA paper ballot that is counted may contain-based voting system must be capable of 

adding a unique identifier, which can be printed on the after a voter casts their ballot.

Discussion

Although not all jurisdictions may use this feature, voting Discussion

Voting systems are not required to have the capability to add a unique identifier to ballots, but all 

voting systems that are certified with risk-limiting audit (RLA) capabilities need to be able to affix a 

ballot identifier. 

Applies to: Paper-based system architectures

Related requirements: 1.1.5-G – Record audit information

9.4-A – Risk-limiting audit

9.4-B – Efficient risk limitingRandom numbers supporting

audit processes

9.1.1-C –Mechanism documentation

9.1.1-A – Software independent

9.1.5-G – Preserving software independence

After a voter castsverifies their selections on a voted ballot, and submits the ballot for 

casting, a paper-based voting system must not physically be ablecapable of making an 

undetectable change to print in the area where the voter’s ballot selections residepaper 

record.

Discussion

After a voter castsverifies and submits their ballot, a voting system may print on paper ballot to apply 

a unique identifier that is later used for auditing purposes. To preserve software independence the 

voting system should not be able to print over or within the ballot selection area because that would 

cause an undetectable change to the election outcome. Instead the voting system should only be 

able to print outside of the bounds of the ballot selection area and may also create further distinction 

by printing in a different font style or color. 

This printing process should be preserved regardless of software or hardware updates.

Related requirements: 9.1.1-C Mechanism DocumentationA – Software 

independent
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9.1.6 – E2E Cryptography 

9.1.6-A – Cryptographic E2E transparencyverifiable

The cryptographic E2E protocol used in the voting system must be publicly available, without 

an explicit request, for open review for 2 years before it enters the voting system 

certification process. 

Applies to: Cryptographic E2E system architectures 

9.1.6-BA– Verified cryptographic protocol 

The E2E cryptographic protocol used by the cryptographic E2E verifiable voting system must 

be evaluated and approved through a public process established by the EAC.

Discussion

Due to the lack of E2E verifiable voting systems available within the current market, there are no 

verified E2E cryptographic protocols. A standard public process for approval of the E2E cryptographic 

protocols will need to be established outside of the VVSG. Once this process is established, the VVSG 

requirements can point to the approved/verified cryptographic protocols as acceptable for use within 

an E2E verifiable voting system.

9.1.6-C – Public availabilityB – Independent evaluation of E2E cryptographic 

protocol implementation

The implementation of the A cryptographic E2E verifiable voting system must undergo an 

independent evaluation to verify it correctly and securely implements an approved E2E 

cryptographic protocol.

Discussion

asAn independent evaluation can be performed by any entity outside of the voting system 

manufacturer. Example best practices include using guidance from the FIPS 140 series [NIST01, 

NIST19a], NIST SP 800-133 Revision 2, Recommendation for Cryptographic Key Generation [NIST20f],

or NIST SP 800-175B, Guideline for Using Cryptographic Standards in the Federal Government: 

Cryptographic Mechanisms [NIST20g]. The independent evaluation and cryptographic engineering 

best practices used in the voting system must be publicly available, without an explicit request, for 

open review upon the system beingcan be documented and submitted for certification.. 

Discussion
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Requirements for VVSG 2.0 February 29, 202010, 2021

Lessons learned from the analysis of the source code of the Swiss Post system shows the value in 

making this code available for public review. See “How not to prove your election outcome” 

[Lewis19b], and “Ceci n’est pas une preuve” [Lewis19a].

See Lewis, Sarah Jamie, Olivier Pereira, and Vanessa Teague. "How not to prove your election 

outcome." (2019). and Lewis, Sarah Jamie, Olivier Pereira, and Vanessa Teague. "Ceci n’est pas une 

preuve." (2019).

Applies to: Cryptographic E2E system architectures

9.1.6-DC – Cryptographic ballot selection verification by voter

TheA cryptographic E2E verifiable voting system must... :

1. be capable of providing evidence that an individual voter can use to confirm that the 

voting system correctly interpreted their ballot selections, while in the polling place.;

and

2. provide evidence such that if there is an error or flaw in the interpretation of the 

voters’ selections, the evidence can be used for detection of the error or flaw. 

Discussion

This requirement addresses cast-as-intended verification. , which is one of the principal components 

necessary to achieve end-to-end- verifiability [Benaloh14].

Interpretation is the process by which the voting system converts the voter’s contest option 

selections into the format used to store these selections. Therefore, this evidence must sufficiently 

prove the representation of the voter’s contest option selections in digital form matches the voter 

selections as provided to the system.

Giving voters the opportunity to verify the voting system stored their ballot choices correctly is a 

fundamental building block in an end-to-end verifiable voting system. 

See Benaloh, Josh, Ronald Rivest, Peter Y. A. Ryan, Vanessa Teague, and Poorvi Vora. "“End-to-end 

verifiability." (2014) and Kulyk, Oksana, and Melanie Volkamer. "” [Benaloh14] and “Usability is not 

Enough: Lessons Learned from ’Human‘Human Factors in Security’ Research for Verifiability." E-VoteID 2018 (2018): 66" [Kulyk18] for more information on the various implementations of this 

technique.

Applies to: Cryptographic E2E system architectures 

Related requirements: Principle 10 - Ballot Secrecy 

6.2-A – Voter independence

Principle 7 - Marked, Verified, and Cast as Intended
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7.3-G – Full ballot selections review

9.1.6-E – Ballot receipt

10.2.4-A – Voting information in receipts

9.1.6-D – Methods for cryptographic ballot selection verification 

TheA cryptographic E2E verifiable voting system documentation must include...

1. : the method for the voter to use the evidence provided for ballot selection 

verification to verify the correct interpretation of their ballot; and

2. a list of known verification tools, their supplier, and how the verification tools are 

used.

Discussion

Voter intent verification often relies on external verification tools to assist voters in the verification 

step(s). These can be external verifiers, which is either a second device, a website of a trusted 

institution, or software running inside the polling location. The manufacturer must provide 

documentation explaining the verification options available to voters. If the jurisdiction is expected 

to provide the verification tool or service, this must also be documented. 

Applies to: Cryptographic E2E system architectures 

Related requirements: 9.1.6-DC – Cryptographic ballot selection verification by 

votevoter

9.1.6-FE – Ballot receipt 

TheA cryptographic E2E verifiable voting system must provide a voter with a receipt that 

allows them to verify that their ballot has been correctly recorded and tallied by the system. 

These receipts ...

1. domust not display any ballot selections made by the voter;

2. domust not enable the voter to prove their selections on the cast ballot to others;

3. aremust be represented in an open and interoperablea publicly documented format;

4. may contain a unique identifier; and

5. are accessible, verifiable, and preserve voter-privacy.

Discussion
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This evidence should fail to confirm a voter’s ballot has been correctly recorded and tallied by the 

system if the ballot has been removed, tampered with, or its selections altered, added to, or 

removed.

Related requirements: 6.1-A – Preserving privacy for voters

6.2-A – Voter independence

The7.3-G – Full ballot selections review

8.3-A – Usability tests with voters

10.2.4-A – Voting information in receipts should...

• be accessible

be 

9.1.6-F – Disputes involving ballot receipts

• The cryptographic E2E verifiable

• preserve voter-privacy

ensure that voters can mark, verify voting system documentation must provide procedures 

for collecting, investigating, and castadjudicating disputes from voters based on the contents 

of their ballot in an accessible and verifiable manner.receipts. 

Discussion

Applies to: Cryptographic E2E system architectures 

This documentation will include a process to address the scenario where a voter attempts to verify 

with their ballot receipt and believes there is a problem with their ballot receipt

Related requirements: Principle 10 -9.1.6-E – Ballot Secrecy receipt

Principle 4 – Interoperable

6.2-A – Voter independence

Principle 7 - Marked, Verified, and Cast as Intended

9.1.6-G – Evidence export

TheA cryptographic E2E verifiable voting system must...:

1. be capable of exporting all evidence supporting ballot tabulation verification., and

2. provide the export in an open and consumable format. 

Discussion
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Requirements for VVSG 2.0 February 29, 202010, 2021

Most recorded-as-cast verification approaches require the public posting of the evidence at some 

point after all ballots have been aggregated and tallied. As required in the previous requirement, the 

evidence must not reveal how voters voted. The public posting does not have to be provided by the 

voting system, but the voting system must provide the evidence such that it can be published, and 

the verification process made accessible to voters. 

Applies to: Cryptographic E2E system architectures 

Related Requirements: Principle 4 - Interoperable

9.1.6-H– Mandatory ballot availability 

The A cryptographic E2E verifiable voting system must make availablebe capable of 

exporting all encoded ballots for public posting. 

Discussion

The public posting does not have to be provided by the voting system, but the voting 

system must provide the evidence such that it can be 

published, and the verification process made accessible to 

voters. Applies to: Cryptographic E2E system 

architectures

The public posting of these exported encoded ballots is performed by election officials and is an 

essential part of the E2E verifiable process. It allows the public to verify the election results. 

9.1.6-I – Verification of encoded votes documentation

TheA cryptographic E2E verifiable voting system documentation must include...:

1. the expected method by which voters will perform the ballot tabulation verification., 

and

2. how this method provides voters with the opportunity to verify that their ballots are

included within the tabulation results. 

Discussion

For example, a common method is to publish tokensthe evidence to a public bulletin board. The 

manufacturer should document this method or its alternative. The bulletin board, itself, might not be 

included in the scope of the voting system but the voting system must provide an export of the 

tokens/evidence to be published on the bulletin board.

Applies to: Cryptographic E2E system architectures 

9.1.6-J – Verifier reference implementation

TheA cryptographic E2E verifiable voting system documentation must include...:
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1. a free publicly available reference implementation of a tool which can be used:

a. to verify evidence provided to a voter to prove that their ballot choices were 

correctly interpreted, and

b. to verify the evidence reported for voters to perform ballot tabulation 

verification;

1. a free publicly available reference implementation of a tool which can be used to 

verify evidence provided to a voter to prove that their ballot choices were correctly 

interpreted

2. the build instructions for the reference implementation, along with the tool, .

2. licensing to allow for examination, modification, recompilation, and distribution. 

Discussion

For the system to support the cast-as-intended property of end-to-end verifiable systems there must 

be at least one tool available to voters to verify that their ballot selections have been correctly 

interpreted. Additionally, for a cryptographic E2E system be software independent, the voters need 

to have choices about what software use and trust when performing verification. By providing an 

open source reference implementation, voters will have more choices when selecting a tool to verify 

their ballot selections may facilitate development of third-party verification tools.

Applies to: Cryptographic E2E system architectures 

Related requirements: 9.1.6-DC – Cryptographic ballot selection verification by 

voter

9.1.6-K – Privacy preserving, universally verifiable ballot tabulation 

TheA cryptographic E2E verifiable voting system tabulation process must preserve the 

privacy of every voter and provide a method for public verification.

Discussion

To be publicly verifiable, the approach provides a means for any auditor or observer to verify the 

correct decryption and tabulation of the votes (not necessarily in that order) using cryptographic 

proofs that are generated by the process.
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9.1.7 – Audit support

9.1.7-A – Number of ballots to check 

A voting system manufacturer must document the procedure to determine the number of 

ballots which need to be checked to reach an election-official-specified margin of error for a 

given contest.

Discussion

To ensure that the election outcome is correct within a specified margin of error, a minimum number 

of ballots will be checked. This can be performing with paper records in paper-based system 

architectures which are checked by election officials or checks by voters in cryptographic E2E system 

architectures. This is important to understanding how efficient the system is at detecting changes 

due to an error or fault.

9.1.7-B – No fixed margin of error 

The voting system must allow election officials to determine the margin of error used to 

determine the number of ballots to check. 

Discussion

This requires the documentation of the margins to be specified as an equation rather than having 

specific margins built into the system. Additional inputs such as margin of victory, total number of 

voters, number of voters for each candidate, actual ballots, or an audit trail, may be needed to 

determine the number of ballots needed.

9.1.7-C – Random number usage

If a voting system generates random or pseudo-random numbers, the manufacturer must 

document the method used to obtain the numbers and how the random numbers are used 

within the voting system. 

Discussion

Various systems used to implement software independence require random numbers, whether for 

ballot selection for audits or cryptographic purposes. 

This documentation should specify...

• how random numbers are generated 

• what any random numbers are used for
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The method for generating the random numbers should meet the requirement 10.2.2-F Random 

number generation.

Related requirements: 10.2.2-F Random number generation6.1-A – Preserving 

privacy for voters

External reference NIST SP 800-90A Rev 1
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9.2 - The voting system produces readily available records that provide the 

ability to check whether the election outcome is correct and, to the 

extent possible, identify the root cause of any irregularities. 

9.2-A – Compliance audit procedures Audit support documentation

The voting system documentation must specify the election procedures necessary to 

perform a compliance audittypes of audits the voting system supports and the artifacts that 

the voting system provides to support those audits. 

Discussion

A compliance audit ensures that the election audit trail is sufficiently accurate to reconstruct the 

outcome according to how voters cast their ballots. Compliance audits provide assurance that a full 

hand count of the election audit trail shows the outcome according to how the voters really voted. 

External references: Evidence-Based Elections by P.B. Stark and D.A. Wagner

Ballots, CVRs, and ballot images are examples of artifacts that can support a post-election audit. 

Related requirements: 1.1.9-A – Post-election reports

3.1.3-D – Audit procedures

9.2-B – General post-election audit procedures 

The voting system documentation must specify the election procedures necessary to 

perform a post-election audit. 

9.2-C – Generating CVRs

The voting system must be capable of recording and reporting a cast vote record for each 

ballot. 

9.2-D – Reporting intermediate results 

The voting system must be able to report intermediate results as the audit is being 

conducted.

9.2-E – Reporting unusual audit events

The voting system must be capable of reporting problems as they arise (for example, 

matching failures).
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9.2-F – Reporting format 

The voting system manufacturer must document the intermediate and final election audit 

results in an open format.

9.2-G – Ballot count 

Voting systems must count and report the number of ballots cast.

Discussion

This needs to be granular enough to have voting devices and tabulators count and report the number 

of ballots cast.
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9.3 - Voting system records are resilient in the presence of intentional 

forms of tampering and accidental errors.

9.3-A – Data protection requirements for audit records 

All voting systems must meet the requirements listed under PrinciplesGuidelines 13.1 and 

13.2 that are related to protecting audit records.

Related requirements 13.1 and 13.2
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9.4 - The voting system supports efficient audits.

9.4-A – Efficient compliance audit

The voting system must produce records to enable an efficient compliance audit.

Discussion

CVRs and ballot images need sufficient data protection because they are needed for audits.

Related requirements: Voting systems need to provide information that will assist election 

officials in conducting compliance audits, whenever possible. While compliance audits check that 

procedures are followed, voting systems can provide information that aids in conducting this audit. 

For example, inspection of event logs is much more efficient if the logs are available in human 

readable text format. Using event codes in logs, which requires manual decoding, is an example of a 

record which impairs the efficiency of compliance audits.

9.413.1.2-A – Integrity protection for election records

13.2-A – Signing stored election records

13.2-B – Verification of election records
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9.4 - The voting system supports efficient audits.

Efficient9.4-A – Risk-limiting audit

A paper-based voting system must produce paper records that allow election officials to 

conduct an efficienta risk-limiting audit.

Discussion

Voting systems contain information which enables election officials to conduct risk-limiting audits.

For example, batch subtotal reporting by the voting system, may make the process of ballot sampling 

more efficient.

efficient An evidence-based election requires convenient access to ballot sheets, ballot sheet images,

and cast vote records for efficient and trustworthy public tabulation audits. Vendors should 

demonstrate how an election system provides all the information necessary for an independent RiskLimiting Audit (RLA).

Some example features/paper records that may be produced to support risk-limiting audits. For 

example, batch subtotal reporting by the voting system, may make the process of ballot sampling 

more efficient.

include the following: 

• the ability to associate electronic cast vote records (CVRs) with corresponding paper records 

while also preserving ballot secrecy;

• the ability to export of CVRs in an open and interoperable format;

• the ability to create a ballot manifest that allows users to identify the physical location of 

ballots (e.g., scanner name or number, batch number, and ballot sequence number); and

• supporting multi-sheet ballots, including association of each sheet with its corresponding 

CVR.

Related requirements: 4.1-C – Exchange of cast vote records (CVRs)

9.1.5 – Paper records

9.2-A – Audit support documentation 

9.4-C – Unique ballot identifiers

9.4-D – Multipage ballots
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9.4-B – Random numbers supporting audit processes

Voting systems that generate or rely on random or pseudo-random numbers for auditing 

purposes must document the method used to obtain the numbers and how the random 

numbers are used within the voting system. 

Discussion

Various systems used to implement software independence require random numbers, whether for 

ballot selection for audits. 

This documentation should specify:

• how random numbers are generated, and

• what any random numbers are used for.

One common use for random numbers is to create unique identifiers associated with ballots to assist 

in supporting audits. 

The method for generating the pseudo-random numbers should meet the requirement 10.2.2-E

Randomly generated identifiers.

For additional information, see NIST SP 800-90A, Recommendation for Random Number Generation 

Using Deterministic Random Bit Generators [NIST15a].

Related requirements: 9.4-C – Unique ballot identifiers

10.2.2-E – Randomly generated identifiers

9.4-C – Unique ballot identifiers 

The voting system must enable election auditors to uniquely address individual ballots. 

Discussion

This capability is needed to support RLAs. Although the voting system has this capability, this does 

not require jurisdictions to use this feature if it conflicts with state laws. In order to conduct a ballotcomparison risk-limiting audit, paper ballot records must either be stored in the order in which they 

were scanned or contain a unique ballot identifier. A unique ballot identifier is a unique ID that 

provides information about the device it was scanned on and the batch in which it is stored. One 

example of a unique ballot identifier is: scanner ID, batch ID, and ballot card number. The unique 

ballot identifier must not tie a ballot to an individual voter

Applies to: Auditing system
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9.4-D – Multipage ballots9.4-D – Multipage ballots

The voting system must be able to appropriately manageaccount for multipage ballots

during an audit. . 
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Applies to: Auditing system 

Principle 10

Ballot Secrecy

The voting system protects the secrecy of voters’ ballot selections. 

10.1 - Ballot secrecy is maintained throughout the voting process. 

10.2 - The voting system does not contain nor produce records, 

notifications, information about the voter or other election artifacts 

that can be used to associate the voter’s identity with the voter’s 

intent, choices, or selections.
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Principle 10

Ballot Secrecy

The voting system protects the secrecy of voters’ ballot selections. 

The requirements for Principle 10 include ensuring ballot secrecy and ensuring that nothing is 

produced that would associate the voter’s identity with their votes. A related topic, Principle 6: 

Voter Privacy, covers voter privacy during voting.

10.1 - Use of voter information covers the requirement that ballot secrecy is maintained 

throughout the voting process.

10.2 - No association of the voter’s choices with the voter’s identity. The sections in 

Guideline 10.2 cover:

1 – Voter associations requires that there be no direct or indirect association between the 

voter’s identity and their ballot, with the exception of certain instances when used in 

cryptographic end-to-end (E2E) verifiable voting systems. It covers how election workers 

canmust select the indirect association option and how these ballots are to be stored separately 

from cast ballots. It also requires encryption of ballots not yet cast that contain an indirect 

association.

2 – Identification in vote records covers the use of identifiers for tying cast vote records (CVRs)

and ballot images to paper ballots and the need for them to be distinct from identifiers used for 

indirect associations. The voting system cannot allow for any information that could be used to 

determine the order in which votes are cast or include any information identifying a voter. 

Aggregate and final totals must also will not allow identification of a voter. The goal is to 

ensure that a voter cannot be identified from the format of the ballot or method of voting. Best 

practices in polling places are also critical to ensuring that there are enough BMD-printed 

ballots to preserve ballot secrecy.

3 – Access to cast vote records (CVRs) covers the need to limit information about and access to 

the storage location for CVRs, ballot images and ballot selections. Any such access needs to be 

authorized and logged in.

4 – Voter information in other devices and artifacts explainsrequires that receipts produced by 

a voting system cannot contain voter information. At the same time, the voting system needs to 

ensure and must not violate ballot secrecy for any receipts it does issue. No part of the audit trail 

can. Logs cannot contain individual or aggregate selections and, nor can activation devices 

create or retain information that can be used to identify a voter’s ballot. It should not be 
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possible for any part of the voting system to be used to violate ballot secrecy, including in the 

absence of a ballot

10.1 - Ballot secrecy is maintained throughout the voting process.

10.1-A – System use of voter information 

The voting system must be incapable of accepting, processing, storing, and reporting 

identifying information about a specific voter, with the exception of blank ballot distribution 

and online ballot marking systems..

Discussion

Examples include first name, last name, address, driver’s license, and voter registration number. and 

other personally identifiable information (PII). This requirement applies to the voting system itself, as

the voting system cannot prevent a voter from self-identifying within write-in fields or other areas of 

the ballot.

Related requirements: 11.1-B – Voter information in log files

10.2 - The voting system does not contain nor produce records, 

notifications, information about the voter, or other election 

artifacts that can be used to associate the voter’s identity with the 

voter’s intent, choices, or selections. 

10.2.1 – Voter associations

10.2.1-A – Direct voter associations

The voting system must not create or store direct associations between a voter’s identity 

and their ballot. 

Discussion

A direct voter association would be the voting system storing that John Smith voted for George 

Washington. Other examples of a direct association would include tying ballot selections to a social 

security number, voter identification number, or driver’s license number. (This is not an exhaustive 

list of direct voter association examples.) 
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10.2.1-B – Indirect voter associations 

Only paperless systems may use indirectIndirect voter associations; other systems must 

notonly be used to associate a voter with their encrypted ballot selections.

Discussion

Discussion

Certain channels of voting require indirect associations so that ineligible ballots can be removed 

before the ballot is read and counted. Some reasons include signature mismatch or death of a voter.

Once a ballot is read and counted, the ballot is permanently stripped of its identifier. The most 

common example of indirect association would be a randomly generated number. Ballots withBest 

practice would ensure that indirect voter associations are not considered read or counted until the 

association is removed.only available to authorized election personnel.

This requirement only applies to paperless voting systems that also meet the requirements under 

Guideline 9.1, which statestates that the voting system must be software independent. During the 

writing of these requirements, cryptographic E2E verifiable voting systems are a potential paperless 

and software independent system that could be applicable for this requirement.

Applies to: Cryptographic E2E verifiable voting system architectures 

10.2.1-C – Use of indirect voter associations 

The voting system must only use indirect voter associations when the option is selected at 

the beginning of a voting session for situations when a voter needs to fill out a ballot before 

their eligibility is determined.

Discussion

Certain channels of voting require indirect associations so that ballots can be removed before casting 

for a variety of reasons including signature mismatch or death of a voter. The act of casting the ballot 

permanently strips it of an identifierThese types of ballots are often considered provisional or 

recallable ballots. 

The most common example of indirect association would be a randomly generated number. Ballots 

with indirect associations are not considered cast until the association is removed. Best practice 

would ensure that indirect voter associations are only available to authorized election personnel. 

Applies to: Cryptographic E2E verifiable voting system architectures 
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10.2.1-D – Election worker selection of indirect associations 

When the use of an indirect association is needed, an election worker must select the option 

for using an indirect association at the beginning of each new voting session.

Applies to: E2E voting system architectures 

10.2.1-E10.2.1-D – Isolated storage location 

Ballots that are not cast and contain an indirect association must be stored in separate 

storage locationsseparated from cast ballots.

Discussion

Ballots that contain an indirect association are not considered cast. Cast ballots and ballots having 

their eligibility considered need to be kept separate from each other. Although not the only way of 

meeting this requirement, one example would be storing cast ballots in a different directory from 

ballots not yet cast. 

Applies to: Cryptographic E2E verifiable voting system architectures 

10.2.1-F – Confidentiality forE – Removal of indirect voter associations 

The voting system must be capable of removing the indirect voter association between a 

ballot and a voter once that voter is determined to be eligible.

Discussion

Provisional or recallable ballots may require indirect associations so that ballots can be removed 

before casting. After a voter’s eligibility is determined the indirect voter association can be removed 

and the ballot can be added to collection of cast ballots. In the case of electronic E2E systems, 

whatever data record provides this association must be removed from the system.

Ballots with indirect associations are not considered cast until the association is removed. Best 

practice would ensure that indirect voter associations are only available to authorized election 

personnel. 

Ballots that are not cast and contain an

Applies to: Cryptographic E2E verifiable voting architectures

10.2.1-F – Confidentiality for ballots with indirect voter associations

The voting system must only be capable of decrypting a ballot after any indirect voter 

association must be encryptedto it has been removed.
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Discussion

Encryption of the ballot preserves the confidentiality of the voter’s ballot selections while the ballot 

is tied to an indirect association to the voter. The indirect voter association is not encrypted with the 

ballot.

The voting system must not be capable of decrypting a ballot that still has an indirect association to a 

voter. A possible approach to implement this is by requiring that a decryption key (or set of keys) be 

entered to decrypt ballots but disallowing input until after all indirect associations have been 

removed. If the key is present on the system at the same time as indirect associations, it may be 

possible for malicious software to decrypt ballots and associate selections with voters.

Applies to: Cryptographic E2E verifiable voting system architectures

Related requirements: Data Protection 

10.2.2 – Identification in vote records

10.2.2-A – Identifiers used for audits 

Identifiers used for tying a cast vote record (CVR) and ballot images to physical paper ballots 

must be distinct from identifiers used for indirect associations. 

Discussion

For the purpose of these requirements, associations between physical ballots and CVRs are not 

considered direct or indirect identifiers. 

Related requirements: Auditability 9.1.5-F – Unique identifier

10.2.2-B – No voter record order information

The voting system must not contain data or metadata associated with the CVR and ballot 

image files that can be used to determine the order in which ballots votes are cast.

Discussion

No data or metadata is allowed whether in CVRs and ballot images or elsewhere if that metadata can 

be used to associate a voter with a record of voter intent. Otherwise, metadata can be useful for 

verification. For instance, date of creation of record in the voter-facing device might reveal the order 

of voting. Most other metadata won’t be a problem.

10.2.2-C – Identifying information in voter record file names 

CVR and ballot image file names must not include any information identifying a voter.
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Discussion

This helps to ensure that information that could accidently be used to reference a voter is not used 

within a file name.

10.2.2-D – Non-memorable identifiers and associations

Unique identifiers and associations must not be displayed in a way that is easily remembered 

by the voter. 

Discussion

Unique identifiers on the paper record are displayed or formatted in such a way that 

they are not easily remembered by voters, such as by 

obscuring them in other characters. 

Related requirements: 9.4 Efficiency 

10.2.2-E – Aggregating and ordering

Aggregated and final totals:

1. must not contain voter specificidentifying information, and 

2. must not be able to recreate the order in which the ballots were cast.

Discussion

Voter identifying information includes social security number, voter identification number, or driver’s 

license number.

10.2.2-F – Random number generationE – Randomly generated identifiers

A voting systemRandomly generated identifiers used for audits must generateuse random 

numbers using guidance frombit generators specified in the latest revision of NIST SP 800-

90A rev. 1, Recommendation for Random Number Generation Using Deterministic90 series 

on random bit generators.

Discussion

This requirement is important to ensure the use of a cryptographically secure pseudo-random 

number generator (CSPRNG) and also to ensure any random numbers, such as unique identifiers on a 

ballot, cannot be used to recreate the order in which a ballot was cast. Recreating the order of cast 

ballots can cause ballot secrecy issues if a voter’s ballot can be identified.

To ensure voting system vendors are following the random number generation recommendations in 

the 800-90A revision 190 series, they will need to submit to the Cryptographic Module Validation 
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Program (CMVP) and the Cryptographic Algorithm Validation Program (CAVP) for conformance 

testing.

For additional information, see NIST SP 800-90A Rev 1 -, Recommendation for Random Number 

Generation Using Deterministic Random Bit Generators. [NIST15a] and NIST SP 800-90B,

Recommendation for the Entropy Sources Used for Random Bit Generation [NIST18a].

Related requirements: 9.1.7-C4-B – Random number usagenumbers supporting 

audit processes

10.2.2-ED – Aggregating and ordering

External reference NIST SP 800-90A Rev 1

10.2.3 – Access to cast vote records (CVR)

10.2.3-A – Least privilege Restrict access to store records of voter intent

The voting system must require administrator-level authorization to access the directory or 

storage location of CVRs, ballot images, and ballot selections on the voting system must be 

subject to the principle of least privilege.

Discussion 

NIST SP 800-12 defines “least privilege” as, “The security objective of granting users only those 

accesses they need to perform their official duties.” 

Nieles, Dempsey, and Pilliteri, Special Publication (SP) 800-12 Revision 1, An Introduction to 

Information Security, National Institute of Standards & Technology (NIST), Gaithersburg, Maryland, 

June, 2017. 

https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-12r1.pdf

External references: NIS SP800-12 Revision 1

Related requirements Access Control 

10.2.3-B – Limited access

Permission to access the directory or storage location for CVRsCast vote records, ballot 

images, and ballot selections mustshould be assignedsubject to as few entities as possible.

Discussion

Entities include people and applications or processes runningspecial restrictions on the voting 

system. 

Related requirements Access Control 
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10.2.3-C – Authorized access. Permissions to access the directory or storage location for CVRs,these 

storage locations are limited only to those users who need to access the location. This may be 

especially essential during voting to protect ballot images, and ballot selections must be validated 

and explicitly authorized before access is givensecrecy and avoid any exposure of results until polls 

are closed.

Discussion

Modern operating systems often have sufficient mechanisms in place to accomplish this, but these 

security capabilities need to be configured and enforced. 

Related requirements Access Control: 11.3.1-B – Multi-factor 

authentication for critical operations

11.3.1-C – Multi-factor authentication for administrators

11.4-A – Least privilege for access policies

11.4-B – Separation of duties

10.2.3-DB – Digital voter record access log

The voting system must log all access to the directory or storage location for CVRs, ballot 

images, and ballot selections in addition to logging access to all actions occurring within the 

system.

Discussion

This ensures that any person, process, or other entity reading, writing, or performing other actions to 

the electronic audit trail is properly logged. 

This requirement does not apply when the CVR, ballot images, and ballot selections are stored on 

removable media and removed from the vote-capture device.

Related requirements Access Control, Auditing 

10.2.4 – Voter information in other devices and artifacts

10.2.4: 11.1-A – Voting information in receiptsLogging activities 

and resource access 
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10.2.4 – Voter information in other devices and artifacts

10.2.4-A – Voting information in receipts

Receipts produced by acryptographic E2E verifiable voting systemsystems must not contain 

voter information. 

Discussion

10.2.4-B – Ballot secrecy for receipts 

The voting system must not issue a receipt to the voter that would provide proof to another of how 

the voter voted.

Applies to: E2E voting system architectures 

Prior VVSG source: VVSG 2007 - Vol 1: 3.2.3.1-A.4

10.2.4-CB – Logging of ballot selections 

Logs and other portions of the audit trail must not contain individual or aggregate ballot 

selections.

Discussion

The voting system needs to be constructed so that the security of the system does not rely upon the 

secrecy of the event logs. It will be considered routine for event logs to be made available to election 

officials, and possibly even to the public, if election officials so desire. The system will be designed to 

permit the election officials to access event logs without fear of negative consequences to the 

security and integrity of the election. For example, cryptographic secret keys or passwords will not be 

logged in event log records.

10.2.4-DC – Activation device records

Ballot activation devices must not create or retain information that can be used to identify a 

voter’s ballot, including the order and time at which a voter uses the voting system. 

Discussion

Information such as the time the voter arrived at the polls or the specific vote-capture device used by 

the voter may be used to link a voter with their specific ballot and violates the principle of ballot 

secrecy.
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Principle 11

Access Control

The voting system authenticates administrators, users, devices, and 

services before granting access to sensitive functions. 

11.1 - The voting system enables logging, monitoring, reviewing, and 

modifying of access privileges, accounts, activities, and authorizations. 

11.2 - The voting system limits the access of users, roles, and processes 

to the specific functions and data to which each entity holds authorized 

access. 

11.3 - The voting system supports strong, configurable authentication 

mechanisms to verify the identities of authorized users and includes 

multi-factor authentication mechanisms for critical operations. 

11.4 - The voting system’s default access control policies enforce the 

principles of least privilege and separation of duties. 

11.5 - Logical access to voting system assets are revoked when no 

longer required.
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Principle 11

Access Control

The voting system authenticates administrators, users, devices, and 

services before granting access to sensitive functions. 

The requirements for Principle 11 coverscover how the voting system secures and limits access 

to only those who are authorized.

11.1 – Access privileges, accounts, activities and authorizations are logged, monitored, and 

reviewed and modified as needed ensures there are records in case there are errors or 

incidents that need to be accounted for. The system also prevents logging any voter ID 

information and prevents the logging capability from becoming disabled or the log entries from 

being modified. The system provides administrators access to logs, allowing for continuous 

monitoring and periodic review.

11.2 – Voting system limits the access of users and processes to the specific functions and 

data to which each entity holds authorized access

The sections in Guideline 11.2 cover:

1 – Authorized access ensures that only authorized users can access the voting system,. All 

voting systems will have an administrator role and only administrators can create or modify 

authorized users, configure permissions, and create or assign groups or roles. Control 

mechanisms distinguish at least four voting stages: Pre-voting, Activated, Suspended, and PostVoting. Differentiating theses stages helps limit access to the voting system to only those 

individuals strictly necessary at any given time. 

2 – Role-based access control standard relatescovers to the requirement that voting systems 

that implement role-based access control support the ANSI Core Role Based Access Control 

(RBAC) recommendations. Systems that implement RBAC define groups or roles. Voting 

systems use the groups and stages described above to assign minimum permissions to 

authorized users, limiting each person’s access within the system.

11.3 – Voting system supports strong, configurable authentication mechanisms

The sections in Guideline 11.3 cover:

1 – Access control mechanisms either permit authorized access or prevent unauthorized access 

to the voting system. This includes the capability to useof using multi-factor authentication to 

verify a user’s authorized access to perform critical operations. It also authenticates the 

administrator with a multi-factor authentication mechanism. Multi-factor authentication 

provides additional security beyond the use of a single password.
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2 – User name and passwordAuthentication Credentials covers the requirement that only the 

administrator can specify and enforce password strength, histories, and expiration, when that 

authentication method is used. The system will also compare all passwords against a 

manufacturer-specified list of well-known weak words, and will ensure that the username is not 

used in the password. The voting system will securely store passwords and other authentication 

credentials (such as multi-factor authentication codes).

11.4 – Default access control policies enforce the principles of leaseleast privilege, minimizing 

access within the system to only what is strictly necessary, and separation of duties, narrowing 

roles so that access isn’t granted too broadly for any group of users.

11.5 – Logical access to voting system assets are revoked when no longer 

requiredrestrictions. The voting system only allows users access within the time period 

specified by the administrator. The system locks out roles or individuals after a specified 

number of consecutive failed attempts, and it allows only an administrator to define the 

lockout duration. This can help prevent unauthorized use if a system is left unattended.
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11.1 - The voting system enables logging, monitoring, reviewing, and 

modifying of access privileges, accounts, activities, and authorizations. 

11.1-A – Logging activities and resource access 

The voting system must log any access to, and activities performed on, the voting system, 

including:

1. timestamps for all log entries;

2. all failed and successful attempts to access the voting system; and

3. all events which change the access control system including policies, privileges, 

accounts, users, groups or roles, and authentication methods.

Discussion

In the event of an error or incident, the user access log can assist in narrowing down the reason for 

the incident or error.

• Timestamped log entries will allow for easy auditing and review of access to the voting system.

• Access control logging supports accountability of actions by identifying and authenticating users.

• Groups are a collection of users that are assigned a specific set of permissions. Roles are an 

identity that is given specific permissions and can be assigned to a user. Any changes to the 

permissions assigned to groups and roles should be logged to identify updates to a user’s 

privileges.

Prior VVSG source: VVSG 2007 - 4.2.1-A

11.1-B – Voter information in log files 

The voting system must prevent the logging of not log any voter identifying information.

Discussion

The logging and storing of voter identifying information after a ballot is cast potentially violates voter 

privacy and ballot secrecy. Examples of voter identifying information include first name, last name, 

address, driver’s license, and voter registration number.

Related requirements: 10.1-A – System use of voter information

10.2.4-CB – Logging of ballot selections

11.1-C – Preserving log integrity

The voting system must prevent:
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1. the logging capability from being disabled, and;

2. the log entries from being modified. in an undetectable manner; and 

3. The deletion of logs; with the exception of log rotation.

Discussion

This requirement promotes the integrity of the information logged by ensuring all activities are 

logged. Additionally, it prevents these abilities from being an option within the user interface. 

This requirement promotes the integrity of the information logged by ensuring all activities are not 

modifiable. 

The removal of logs is only appropriate for log rotation, which is when the stored logs are rotated out 

to create more space for continuous logging. The voting system should be capable of rotating the 

event log data to manage log file growth. Log file rotation may involve regular (e.g., hourly, nightly, or 

weekly) moving of an existing log file to some other file name and/or location and starting fresh with 

an empty log file. Jurisdictions should ensure that the log rotation procedure includes a labeling 

method to identify the type of log, the system that created the logs, and the date of the 

logsPreserved log files may be compressed to save storage space.

11.1-D – On-demand access to logs 

The voting system must provide administrators access to logs on demand, allowing for 

continuous monitoring and periodic review.

Discussion

Enabling administrators to export and review the logs is a useful feature. Continuous monitoring and 

review of access control logs gives the administrator the opportunity to analyze and make changes to 

permissions and privileges, and quickly identify issues.

Prior VVSG source: VVSG 2007 - 4.2.1-A
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11.2 - The voting system limits the access of users, roles, and processes 

to the specific functions and data to which each entity holds authorized 

access.

11.2.1 – Authorized access

11.2.1-A – Ensuring authorized access 

The voting system must allow only authorized users to access the voting system.

Discussion

Authorized users include voters, election officials, and election workers. 

11.2.1-B – Modifying authorized user lists 

The voting system must allow only an administrator to create or modify the list of authorized 

users.

Discussion

This requirement assists with ensuring only authorized users are given access to the voting system.

11.2.1-C – Access control by voting stage

The voting system access control mechanisms must distinguish at least the following voting 

stages from Table 11-1: 

1. Pre-voting

2. Activated

3. Suspended

4. Post-voting

 Table 11-1 – Voting stage descriptions 

Stage Description

Pre-voting Powering-on, Loading, and configuring device software, 

maintenance, loading election-specific files, preparing for election 

day usage

Activated Activating the ballot, printing, casting, spoiling the ballot

Suspended Occurring when an election official suspends voting
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Post-voting Closing polls, tabulating votes, printing records, powering-off

Discussion

The groups or roles in 11.2-H (Table 11- 2) will be given specific permissions which can be affected by 

the voting stage (Table 11-1). 

Prior VVSG source: VVSG 1.0 - I.7.2.1, I.7.2.1.1

11.2.1-D – Access control configuration 

The voting system must allow only an administrator to configure the permissions and 

functionality for each identity, group or role, or process to include account and group or role 

creation, modification, disablement, and deletion.

Discussion

For vote-capture devices, it is possible for each group or role to have (or not have) permissions for 

every voting stage. Additionally, the permissions that a group or role has for a voting stage can be 

restricted to certain functions. Table 3 shows an example matrix of group/role to system to voting 

state access rights; the table is not meant to include all activities. This requirement extends 

[VVSG2005] I.7.2.1.1-a by allowing configuration flexibility for permissions and functionality for each 

identity or group/role.

Privileged accounts include any accounts within the operating system, voting device software, or 

other third-party software with elevated privileges such as administrator, root, and maintenance 

accounts. This requirement extends [VVSG2005] I.7.2.1.2 by allowing the creation and disabling of 

privileged accounts.

TheAn administrator is the only user authorized to make major changes within a voting system. 

Administrators are given this group or role to ensure all other users have proper access to the 

information necessary to perform their duties.

11.2.1-E – Administrator modified permissions

The voting system must allow only an administrator to create or modify permissions 

assigned to specific groups or roles.

Discussion

The administrator’s authority to create or modify permissions restricts users from gaining 

unauthorized permissions.
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11.2.1-F – Authorized assigning groups or roles

The voting system must allow only an administrator to create or assign the groups or roles.

Discussion

Table 2 is a list of groups or roles that need to be included within the voting system. 

Related requirements: 11.2.2-B – Minimum groups or roles

11.2.2 – Role-based access control

11.2.2-A – Role-based access control standard

Voting systems that implement role-based access control must support the 

recommendations for Core Role Based Access Control (RBAC) in the ANSI INCITS 359-2004

American National Standard for Information Technology – Role Based Access Control

[ANSI04] document.

Discussion

This requirement extends [VVSG2005] I. 7.2.1.1-a by requiring role-based methods to follow ANSI 

INCITS 359-2004. [ANSI04].

External references: ANSI INCIS 359-2004

Prior VVSG source: VVSG 1.0 - I.7.2.1.1

11.2.2-B – Minimum groups or roles

At minimum, voting systems that implement RBAC must define the following groups or roles

with the role descriptions within Table 11-2.

Table 11-2 – Minimum voting system groups or roles for RBAC

Group or role Role description

Administrator Can update and configure the voting devices and troubleshoots 

system problems.

Voter A restricted process in the vote-capture device. It allows the votecapture device to enter the activated state for voting activities.

Election JudgeWorker Has the ability to open the polls, close the polls, recover from errors, 

and generate reports.; Checks in voters and activates the ballot style; 

Loads ballot definition files.

Election Worker Checks in voters and activates the ballot style. 
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Central Election Official Loads ballot definition files.

Discussion

Table 11-2 is a baseline list of groups or roles to be included in the voting system. 

11.2.2-C – Minimum group or role permissions

At minimum, the voting system must use the groups or roles from Table 11-2 – Minimum 

voting system groups or roles for RBAC and the voting stages from Table 11-1 – Voting stage 

descriptions, to assign the minimum permissions in Table 11-3.

Discussion

Table 11-3 – Minimum permissions for each group or role defines the minimum functions according 

to user, voting stage, and system. Other capabilities can be defined as needed by jurisdiction.

Table 11-3 - Minimum permissions for each group or role

Group/Role System Pre-Voting Activated Suspended PostVoting

Administrator

EMS Full Access Full Access Full Access Full Access

BMD/Electronic

BMD Full Access Full Access Full Access Full Access

PCOSVoter-Facing 

Scanner Full Access Full Access Full Access Full Access

Voter

EMS --- --- --- ---

BMD/Electronic

BMD --- Vote and 

cast ballots --- ---

PCOSVoter-Facing 

Scanner --- Ballot 

Submission --- ---

Election 

Judge/Precinct 

CaptainWorker

EMS

---Define and 

load election 

programming

--- ---

---Reconcile 

provisional

or 

challenged 

ballots, 

write-ins, 

generate 

reports 
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11.2.2-D – Applying permissions

The voting system must be capable of applying assigned groups or roles and permissions to 

authorized users. 

Discussion

Once the user is assigned a group or role, the voting system needs to be capable of making the 

necessary changes to the user’s permissions. The permissions are changed based on the assigned 

group or role.

BMD/Electronic

BMD Open polls, L&A

Close or 

suspend 

polls, 

Recover 

from errors, 

Activate 

ballot and 

cancel

unvoted

ballots

Exit 

suspended 

state

Generate 

reports

PCOSVoter-Facing 

Scanner Open polls, L&A Recover 

from errors

Exit 

suspended 

state

Generate 

reports

Election Worker

EMS --- --- --- ---

BMD/Electronic ---

Activate 

ballot and 

cancel 

ballots

--- ---

PCOS --- --- --- ---

Central Election 

Official

EMS Define and load 

ballot --- ---

Reconcile 

provisionalchallenged 

ballots, 

write-ins, 

generate 

reports

BMD/Electronic --- --- --- ---

PCOS --- --- --- ---
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11.3 - The voting system supports strong, configurable authentication 

mechanisms to verify the identities of authorized users and includes 

multi-factor authentication mechanisms for critical operations. 

11.3.1 – Access control mechanismmechanisms

11.3.1-A – Access control mechanism application

The voting system must use access control mechanisms to permit authorized access or 

prevent unauthorized access to the voting system.

Discussion

Access controls support the following concepts:

• limiting the actions of users, groups or roles, and processes to those that are authorized.;

• limiting entities to the functions for which they are authorized.;

• limiting entities to the data for which they are authorized.; and

• accountability of actions by identifying and authenticating users.

Most modern operating systems natively provide configurable access control mechanisms that the 

voting system application can use. 

Prior VVSG source: VVSG 1.1 - I.7.2.1.2-1, I.7.2.1.2-2 

11.3.1-B – Multi-factor authentication for critical operations 

At a minimum, the voting system must be capable of using multi-factor authentication to 

verify a user has authorized access to perform critical operations, including: 

1. runtime software updates to the certified voting system;

2. aggregation and tabulation;

3. enabling network functions;

4. changing device states, including opening and closing the polls;

5. deleting or modifying the audit trailCVRs and ballot images; and

6. modifying authentication mechanisms.

Discussion

NIST SP 800-63-3, Digital Identity Guidelines [NIST17c] provides additional information useful in 

meeting this requirement. NIST SP 800-63-3 defines multi-factor authentication (MFA) as follows:
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“An authentication system that requires more than one distinct authentication factor for successful 

authentication. Multi-factor authentication can be performed using a multi-factor authenticator or by 

a combination of authenticators that provide different factors. 

The three authentication factors are something you know, something you have, and something you 

are.

Multifactor authenticators include, but are not limited to the following:

• Username & password

• Smartcard (for example, voter access card)

• iButton

• Biometric authentication (for example, fingerprint)

Multi-factor authenticators can be tested for usability to ensure an appropriate balance of security, 

usability, and functionality. A significant impact to usability may require revision of the multi-factor 

authenticator implementation.

Related requirements:External reference: NIST SP 800-63-3 Digital Identity Guidelines

8.4-A – Usability testing with election workers

11.3.1-C – Multi-factor authentication for administrators 

The voting system must authenticate the administrator with a multi-factor authentication 

mechanism.

Discussion

This requirement extends [VVSG2005] I.7.2.1.2-e by requiring multi-factor authentication for the 

voting system administrator group or role.

Prior VVSG source: VVSG 1.1 - I.7.2.1.2-e

11.3.2 – Username and passwordUser authentication credentials

11.3.2-A – Username and password management

If the voting system uses a username and password authentication method, the voting 

system must allow only the administrator to enforce password strength, histories, and 

expiration.

Discussion
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This requirement extends [VVSG2005] I.7.2.1.2-e by requiring strong passwords, password histories, 

and password expiration.

Prior VVSG source: VVSG 1.1 - I.7.2.1.2-1

11.3.2-B – Password complexity 

The voting system must, at minimum, meet the password lengthcomplexity requirements 

within the latest version of NIST SP 800-63B Digital Identity Guidelines standards.

Discussion

NIST SP 800-63B [NIST17d] does not specify any additional password complexity requirements 

besides password length. TheAt the time of this writing, the only recommended password complexity 

requirement is a minimum password length isof 8 characters. NIST SP 800-63B also recommends that 

if a password is provided to the user it may be 6 characters and all numeric. NIST’s password 

complexity recommendations are meant to make it easier for users to memorize their passwords, 

while decreasing user frustration.

11.3.2-C – Specify password complexitySecure storage of authentication data

The voting system must allow only the administrator to specify password strength for all 

accountsstore authentication data in a way that ensures confidentiality and integrity are 

preserved.

Discussion

This requirement extends [VVSG2005] I.7.2.1.2-e by allowing the administrator flexibility in 

configuring password strength. It also requires the use of NIST 800-63B standards.

Prior VVSG source: VVSG 1.1 I.7.2.1.2-1

Ensuring the confidentiality of stored authentication data (such as passwords) may involve the use of 

cryptography. The best practice at the time of this writing is to store a salted, one-way hash of 

passwords. Additional guidance for protecting authentication data can be found in NIST SP 800-63B, 

Digital Identity Guidelines [NIST17d]. 

11.3.2-D – Password blacklistdisallow list

The voting system must compare all passwords against a manufacturer-specified list of wellknown weak passwords. and disallow the use of these weak passwords. 

Discussion

Examples of common weak passwords include 0000, 1111, 1234.

Prior VVSG source: VVSG 1.1 - I.7.2.1.2-1
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11.3.2-E – Usernames within passwords

The voting system must ensure that the username is not used in the password. 

Discussion

This requirement extends [VVSG2005] I.7.2.1.2-e by restricting the use of usernames and related 

information in passwords.

Prior VVSG source: VVSG 1.1 - I.7.2.1.2-e
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11.4 - The voting system’s default access control policies enforce the 

principles of least privilege and separation of duties. 

11.4-A – Least privilege for access policies

By default, the voting system must implement the principle of least privilege including 

denying access to functions and data unless explicitly permitted.

Discussion

This requirement extends [VVSG2005] I.7.2.1.2-a by requiring explicit authorization of subjects based 

on access control policies.

Prior VVSG source: VVSG 1.1 - I.7.2.1.2-1

At the time of this writing, NIST SP 800-12 [NIST17e] defines “least privilege” as “the principle that a 

security architecture should be designed so that each entity is granted the minimum system 

resources and authorizations that the entity needs to perform its function.”

Network access will also follow the principle of least privilege to ensure that devices only receive as 

much access as is necessary to perform the desired function.

11.4-B – Separation of duties

Voting system documentation must include suggested practices for dispersing critical 

operations across multiple groups or roles.

Discussion

Guidance for implementing separation of duties within the voting system is imperative to implement 

the separation of duties principle. Separation of duties is meant to divide user functions and roles so 

that there is no conflict of interest. 

11.5 - Logical access to voting system assets are revoked when no longer required.

11.5 - Logical access to voting system assets are revoked when no longer 

required.

11.5-A – AccessSession time period limits

The voting system must enable an administrator the ability to do the following:

1. set the maximum time limit for a user’s session, and
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2. set the maximum time limit for user inactivity.

Discussion

NIST SP 800-63B [NIST17d] recommends a max session time of 12 hours regardless of inactivity and a 

max inactivity time of 30 minutes. Elections consist of temporary employees and user access may 

only allow usersbe required during an election. A user’s access may expire and terminate 

automatically at the end of an election. 

Related requirements: 11.5-B – Reauthentication

11.5-B – Reauthentication

The voting system must require reauthentication of an authorized access within a time 

period user after the administrator-specified by the administrator.time limit for the user’s 

session or for user inactivity. 

Discussion

After authentication, a user’s access to a voting system will time-out after a specified period of time. 

This will avoid unauthorized access to the voting system by unauthorized users. Once a user’s access 

has timed-out, the user will have to re-authenticate to continue using the voting system.

For voters, session times are specified under requirement 7.2-O – Inactivity alerts.

For more information, see NIST SP 800-63B [NIST17d].

Related requirements: 7.2-O – Inactivity alerts

11.5-BA – Session time limits

11.5-C – Account lockout 

The voting system must lockout roles or individuals after an administrator-specified number 

of consecutive failed authentications attempts. 

Discussion

This requirement prevents certain classes of password guessing attacks. This requirement can be 

implemented using a technique such as exponential backoff. NIST SP800-63B recommends allowing 

5-10 attempts before starting exponential backoff. Exponential backoff requires that after each 

unsuccessful authentication attempt, the time period before another authentication attempt can be 

made grows exponentially. For instance:

• The wait after 1 unsuccessful authentication attempt is 0 seconds

• The wait after 2 unsuccessful attempts is 2 seconds
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• The wait after 3 unsuccessful attempts is 4 seconds, and so on

Prior VVSG source: VVSG 1.1 - I.7.2.1.2-1

11.5-CD – Lockout time duration

The voting system must allow only an administrator to define the lockout duration. 

Discussion

This requirement extends [VVSG2005] I.7.2.1.2 by allowing the administrator flexibility in configuring 

the account lockout policy. The lockout policy should not lockout voters. 
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Prior VVSG source: VVSG 1.1 - I.7.2.1.2-1

Principle 12

Physical Security

The voting system prevents or detects attempts to tamper with voting 

system hardware. 

12.1 - The voting system supports mechanisms to detect unauthorized 

physical access. 

12.2 - The voting system only exposes physical ports and access points 

that are essential to voting operations.
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Principle 12

Physical Security

The voting system prevents or detects attempts to tamper with voting 

system hardware.

The requirements for Principle 12 cover the mechanisms that will ensureprotect the 

safetyphysical security of the voting system.

12.1 – Mechanisms to detect unauthorized physical access deals with the requirement that 

unauthorized physical access leave physical evidence, including access to containers holding 

voting system records. Devices need to produce an alarmalert if access to a restricted voting 

device component is detected or if a connected component is physically disconnected during 

the activated state. The voting system needs to log when a device or component is connected 

or disconnected during an activated state and log the status of physical access points when the 

system is booted. 

Locks installed in voting devices for security willmust be evaluatedtested and meet certain 

requirements along with beingbe designed with countermeasures to indicate unauthorized 

attempts have been made to gain access to the voting device. Locking systems will be flexible 

enough to support different keying schemes. Backup power for power-reliant countermeasures 

is also required.

12.2 – Physical ports and access points essential to voting operations covers the requirement 

that voting devices have or expose only those physical ports and access points that are essential 

to voting operation, testing, and auditing. If a physical connection between components is 

broken during an activated or suspended state, the affected voting device port will be 

automatically disabled. The voting system will restrict physical access to any port that 

accommodates removable media, except for ports that activate a voting session. Devices need 

to allow authorized administrators to put physical ports into a disabled state. An event entry log 

that identifies the name of the affected device will be generated when physical ports are 

enable or disabled.
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12.1 - The voting system supports mechanisms to detect unauthorized 

physical access. 

12.1-A – Unauthorized physical access

Any unauthorized physical access to voting systems must leave physical evidence that an 

unauthorized event has taken place. 

Discussion

Access points such as covers and panels need to be secured by locks or other mechanisms that leave 

physical evidence in case of tampering or unauthorized access. Manufacturers can provide for and 

recommend a combination of procedures and physical measures that allow election officials to 

differentiate authorized from unauthorized access during all modes of operation, such as a system

that relies on tamper evident tape, seals, or tags coded with consecutive serial numbers. Other 

systems might use seals incorporating radio frequency identification devices with physically 

unclonable functions or other technology in the future. 

This requirement extends [VVSG2005] I.7.3.1 by requiring that any tampering with a device leave 

physical evidence. [VVSG2005] I.7.3.1 states that any tampering should be detectable using 

manufacturer-specified procedures and measures.

Prior VVSG source: VVSG 1.0 - 7.3.1

12.1-B – Unauthorized physical access alarmalert

Voting devicesVoter-facing scanners and electronic BMDs must produce an alarmalert if 

access to a restricted voting device component is detected during the activated statevoting 

stage. 

Discussion

This alarmalert is meant to call attention to election workers in the polling place. 

More information about the activated stage is defined in Table 11-1.

Related requirements: 11.2.1-C – Access control by voting stage

12.1-C – Disconnecting a physical device

The voting deviceVoter-facing scanners and electronic BMDs must produce an alarmalert if a 

connected component is physically disconnected during the activated statevoting stage. 

Discussion
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An alert can be provided in the form of an alarm to provide an audible and/or visual alert. Examples 

of connected components include printers, removable storage devices, and mechanisms used for 

networking. If a token is necessary for normal operation, such as a memory card or other device 

granting a voter access to the voting system, it is not necessary to trigger the alarm.alert.

More information on the activated stage is defined in Table 11-1.

12.1-D – Logging of physical connections and disconnections 

The voting system must log when a voting device orvoter-facing scanner, electronic BMD, or 

other component is connected or disconnected during the activated statevoting stage. 

Discussion

Logging of the devices is vital for determining cause and providing incident information if a physical 

security event occurs.

Related requirement: Aligns with requirements: 11.2.1-C – Access control by 

voting stage

15.1, Detection and Monitoring-D – Logging event types

12.1-E – Logging door cover and panel status

The voting system must log the status (for example, open, closed) of physical access points, 

such as covers and panels, upon boot of the system.

Discussion

This ensures system owners can monitor access to voting device components whenever they are 

being used on election day. The status of the open physical access points can be externally monitored 

and communicated to the voting device itself.

Related requirement: Aligns with 15.1, Detection and Monitoring

12.1-F – Secure containers

Unauthorized physical access to a container holdingthat stores or transports voting system 

records must result in physical evidence that an unauthorized event has taken place. 

Discussion

The goal is to ensure that election workers or observers would easily notice if someone has tampered 

with the container. This requirement can be achieved through locks or seals as a part of tamper 

evidence and tamper resistance countermeasures described by the use procedures and supplied by 

the manufacturer. 
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Additionally, to support the auditable principlerequirements in Principle 9-Auditable, containers 

which hold either paper or electronic voting system records needed for audits need to be secure 

against physical access. An example of a physical container includes ballot boxes integrated and sold 

as part of the voting system.

Applies to: Voter-facing scanners, BMDs

12.1-GF – Secure physical locks

Locks installed in voting devices for security purposes must be: 

evaluated and meet or exceed requirements of UL 437 for door locks and 

locking cylinders. systems

1. designed with countermeasures that give a physical indication that unauthorized 

attempts have been made to defeat the lock and gain access to the voting device. 

If the voting system uses locks itDiscussion

See [UL03] for UL listing requirements.

External source: UL 437

12.1-H – Secure locking system key

The voting system must support locking systems for securing voting devices that are flexible 

enough to support different keying schemes, including a scheme that can make use of keys 

that are unique to each owner. 

Discussion

A lock used on the voting system can be evaluated against UL437 door locks and locking cylinders

requirements. See [UL13] for UL listing for door locks and locking cylinders within the standard to 

review requirements for lockpicking and the attack resistance tests.

The use of a single key used to unlock thousands of precinct-based voting devices makes for a 

challenging security situation, as copies of this single key design are distributed to a large number of 

individuals. This creates a situation in which the key can be easily lost or stolen, and subsequently 

copied. At the same time, this situation does make key management significantly easier for election 

officials. To alleviate this situation, election officials might want keying schemes that are more or less 

restrictive in accordance with their election management practices and needs. This system can make 

use of replicable locks or cylinders, mechanisms which allow for rekeying of locks, or other 

technologies. The requirement does not mandate a unique key for each piece of voting equipment,

but requires manufacturers to be able to provide unique keys for the voting equipment if requested 
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by election officials. System owners need to establish procedures for issues such as key reproduction, 

use, and storage.

12.1-IG – Backup power for power-reliant countermeasures 

AnyIf the voting system uses a powered physical security countermeasure, that 

requiresphysical countermeasure must maintain its state when power is removed and must 

have a backup power supply. In addition, switching from primary power supply to backup 

power supply:

1. produces an alarm, andalert;

2. happens automatically when primary power is unavailable; and

2.3. generates an event log entry, if possible.

Discussion

This ensures that the countermeasure isn’t disabled or intentionally circumvented by a power failure. 

Switching to the backup power supply triggers an alarm that alerts an election worker to the issue so 

that any problem can be further diagnosed and eventually resolved. The alarm can be visible and 

audible. Once primary power is unavailable, the switch to back up power should be automatic to 

avoid any gaps in functionality if the switch must be done manually.

If the physical countermeasure leverages the voting system’s operating system, it can create an event 

log entry when it is switched to backup power. The log entry information is security relevant, 

especially once a security incident has occurred, and would be useful when determining cause. 

Alternatively, the voting system should log when there is a switch from backup power to the primary 

power supply. 

Applies to: Voting Device, EMS 

Prior VVSG source: VVSG 2007 - 5.8.9-A, 5.8.9-B

Related requirement: Aligns with 15.1, Detection and Monitoring
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12.2 - The voting system only exposes physical ports and access points 

that are essential to voting operations. 

12.2-A – Physical port and access least functionality

The voting devicesystem must only haveexpose physical ports and access points that are 

essential to voting operations, testing, and auditing. 

Discussion

Examples of ports are USB and RJ45 physical network interfaces. Examples of access points are doors, 

and panels, and vents. Voting operations include voting device upgrades and maintenance.

Prior VVSG source: VVSG 2007 - 5.6.3-C

12.2-B – Physical port auto-disable 

If a physical connection that supports digital communication between voting system 

components is broken during an activated or suspended state, the affected voting

devicesystem port must be automatically disabled.

Discussion

Automatically disabling will require an election worker’s attention to re-enable and re-attach any 

network or power cabling. Under ideal circumstances,cabling. This remediation is required for 

continuity and to address any tampering. An added feature could be that the specific election worker 

performing maintenance is uniquely identified within the logs, but this is not required. This 

requirement does not include power cabling with a backup power supply or analog accessibility 

device ports that are used during the activated voting stage.

12.2-C - Physical port restriction

Voting systems must restrict physical access to voting machinesystem ports that 

accommodate removable media, with the exception of ports used to activate a voting 

session. 

Discussion

Physical port access needs to be restricted when not in use. This requirement is not meant to impede 

the use of accessible technology. This requirement assists in restricting adversaries from adding 

wireless adapters or other malicious adapters to the voting system.

Discussion

Although voting systems can have ports dedicated to voting operations outside of election day 

activities, those ports need not be exposed while balloting is in progress. Removable media (such as 
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Floppy, CD or DVD drives, thumb drives, and memory cards) might be essential to voting operations 

during pre-voting and post-voting phases of the voting cycle, such as machine upgrade, maintenance, 

and testing. Therefore, all removable media should be accessible only to authorized personnel. They 

should not be accessible to voters during activated and suspended phases of the voting cycle. It is 

essential that any removable drives, whether or not they are used by the system, are not accessed 

without detection. 

Related requirements: Aligns with 14.2, System Integrity

12.2-D – Disabling ports 

Voting devicessystems must allow authorized administrators to be able tologically put 

physical ports into a disabled state.

Discussion

Logically disabling ports prevents unused ports from being used as a staging point for an attack on 

the voting system. 

Applies to: Voting Device, EMS 

Related requirements: Aligns with 14.2, System integrity 

12.2-E – Logging enabled and disabled ports

An event log entry that identifies the name of the affected device must be generated when 

physical ports are enabled or disabled. 

Discussion

Whether a port is disabled or not is security relevant, especially once a security incident has 

occurred, and this information would be useful when determining cause. 12.2-DC – Physical port 

restriction applies to physical restrictions, whereas 12.2-FD – Disabling ports discusses logical 

disabling of ports. 

Applies to: Voting Device, EMS 

Related requirements: Aligns with 9.3, Access Control and 15.1, Detection and 

Monitoring-D – Logging event types 
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Principle 13

Data Protection

The voting system protects data from unauthorized access, 

modification, or deletion. 

13.1 –The voting system prevents unauthorized access to or 

manipulation of configuration data, cast vote records, transmitted data, 

or audit records. 

13.2 - The source and integrity of electronic tabulation reports are 

verifiable. 

13.3 - All cryptographic algorithms are public, well-vetted, and 

standardized. 

13.4 - The voting system protects the integrity, authenticity, and 

confidentiality of sensitive data transmitted over all networks.
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Principle 13

Data Protection 

The voting system protects data from unauthorized access, 

modification, or deletion. 

The requirements for Principle 13 include ensuring that the voting system prevents 

unauthorized access to or manipulation of data and records and that the source and integrity of 

electronic tabulation reports are verifiable. It details cryptographic standards and ensure that 

the system protects sensitive data that is transmitted over all networks. 

The sections in Guideline 13.1 cover:include:

1 – Configuration file which deals with the requirement that the system allow only 

authenticated system administrators to access and modify voting device configuration files. In 

addition, the election management system (EMS) will uniquely authenticate individuals 

associated with the role of system administrator before they can access and modify EMS 

configuration files. Network appliances will uniquely authenticate individuals before allowing 

them to access and modify configuration files. Configuration files contain important settings, 

including security settings, and altering them could impact the overall system

2 – Elections records deals with the need for the vote-capture and tabulation system and the 

EMS to integrity protect the integrity of the cast vote record (CVRrecords (CVRs) and ballot 

images when they are stored in the voting device. These protections should prevent 

undetectable changes to CVRs and ballot images.

13.2 – Source and integrity of electronic tabulation reports are verifiableelection records

covers the requirement that cast vote recordsCVRs and ballot images be digitally signed both 

when stored and before being transmitted. The EMS needs to be able to cryptographically 

certify all electronic voting records. Digital signatures are a form of integrity protection that can 

also help trace the source of any updates or alterations to election records.

13.3 – Cryptographic algorithms are public, well-vetted, and standardized deals with the 

requirements that cryptographic functionality be implemented in a FIPS 140-2 validated 

cryptographic module operating in FIPS mode.validated against Federal Information Processing 

Standard (FIPS) 140 [NIST01]. In addition, cryptographic functions specific to E2E cryptographic 

voting protocols must adhere to requirements set by the certification authorityEAC and are 

omitted from FIPS 140-2 validation. Devices using cryptography need to employ NIST approved 

algorithms, and the key used with Message Authentication Codes needs to have a specific 
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security strength. Voting system documentation describes how key management is to be 

performed by election officials.

13.4 – Protecting sensitive data transmitted over all networkstransmission deals with the 

requirement that data be transmitted by a mutually authenticated connection. Voting systems 

transmitting data need to cryptographically protect the confidentiality and integrity of data sent 

over a network. A receiving voting system receiving data will adhere to requirements on 

verifying and logging data received and presenting any verification errors immediately.
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13.1 - The voting system prevents unauthorized access to or 

manipulation of configuration data, cast vote records, transmitted 

data, or audit records. 

13.1.1 – Configuration file

13.1.1-A – Authentication to access configuration file

The voting system must allow only authenticated system administrators to access and 

modify voting device configuration files. 

Discussion

Voting system configuration files can include operating system and voting system application 

configuration files. These files can have a large impact on how the voting system functions and what 

election logic is being used. Therefore, accidental or malicious modification can have a large impact 

on the system and access to these files should be restricted to authorized individuals. 

Prior VVSG source: VVSG 2007 - 5.3-H

Related requirements: 13.2-A, 13.2-B

Applies to: Vote-capture and tabulation system

Related requirements: 11.2.1-A – Ensuring authorized access

13.1.1-B – Authentication to access configuration file on EMS

The EMS must uniquely authenticate individuals associated with the role of system 

administrator before allowing them to access and modify EMS configuration files. 

Discussion

EMS configuration files can include operating system and voting system application configuration 

files. These files can have a large impact on how an EMS tabulates and reports election results. 

Therefore, accidental or malicious modification can have a large impact on the system and access to 

these files should be restricted to authorized individuals. 

Prior VVSG source: VVSG 2007 - 5.3-H.1

Related requirements: Access Control 

Applies to: EMS workstation 

Related requirements: 11.3.1-C – Multi-factor authentication for administrators

15.1-E – Configuration file access log
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13.1.1-C – Authentication to access configuration file for network appliances

Network appliances must uniquely authenticate individuals before allowing them to access 

and modify configuration files. 

Discussion

Network appliances, such as firewalls, routers, switches, and VPN gateways are generally 

configurable. Individually authenticating users to the device, in lieu of using a shared password, is a 

standard practice for restricting access to these devices. 

Applies to: Network appliance

Related requirements: 11.3.1-A – Access control mechanism application

Applies to: Network appliance

13.1.2 – Election records

13.1.2-A – Integrity protection for election records 

The vote capture and tabulationvoting system must integrity protect the CVRprevent 

modification of CVRs and ballot images when they are stored inanywhere within the voting 

devicesystem. 

Discussion

13.1.2-B – EMSApplying access control can help prevent any unauthorized modifications to CVRs and 

ballot images.

Applying integrity protection for election records 

The EMS must integrity protect the CVRensures that any unauthorized modifications to CVRs and 

ballot images when they are stored in the devicecan be detected.

For example, ballot images can be integrity protected using a private key maintained in a Hardware 

Security Module and a cryptographic signature of the image.

Related requirements: 13.2-A – Signing stored election records

13.2-B – Verification of election records
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13.2 – The source and integrity of electronic tabulation reports are 

verifiable. 

13.2-A – Signing stored electronic votingelection records 

Cast vote records and ballot images must be digitally signed when stored. and before being 

transmitted.

Discussion

Digital signatures address the threat that the records might be tampered with when stored. or 

transmitted. Cryptographic hashes do not sufficiently mitigate this threat, as election records could 

be altered and then re-hashed. Digital signatures also allow verification of the source of any created 

or modified records. Additional information can be found in FIPS 186-4 Digital Signature Standard

[NIST13c].

Prior VVSG source: VVSG 2007 - 4.3.1-C

13.2-B – Signing electronic voting records prior to transmission 

Cast vote records and ballot images must be digitally signed before being transmitted. 

Discussion

Digital signatures address the threat that the records might be tampered with 

when transmitted. Cryptographic hashes do not sufficiently mitigate this 

threat, as hashed Verification of election records could be altered and then 

the hash could be recomputed. 

Prior VVSG source: VVSG 2007 - 4.3.1-C

13.2-C – Cryptographic verification of electronicA voting records 

The EMSsystem must be able to :

cryptographically verify all electronic voting records.

Discussion

1. Verifying the integrity and authenticity of all election data received;

2. immediately log any verification error of received election results;

3. immediately present on-screen any verification errors; and

4. not tabulate or aggregate any data that fails verification.
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Discussion

and integrity record can mitigate attacks that could modify the ballot in transit and allow 

unauthorized ballots to be counted. This does not solely apply to transmitted records. 

Applies to: Vote capture and tabulation system, EMS

This process of verifying election data and results is a defense in depth measure against accidental 

errors or a malicious incident regarding modified or false election records. For example, checking the 

cryptographic integrity of received election results prevents modified election results from being 

maliciously modified and reported on election night. 
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13.3 - All cryptographic algorithms are public, well-vetted, and 

standardized.

13.3-A – Cryptographic module validation

Cryptographic functionality must be implemented in a cryptographic module that meets or 

exceedscurrent FIPS 140-2 validation, operating in FIPS mode. 

This applies to:

1. A software cryptographic modulemodules, and 

2. A hardware cryptographic modulemodules.

Discussion

Use of validated cryptographic modules validated at level 1 or above ensures that the cryptographic 

algorithms used are secure and their correct implementation has been validated. It also ensures that 

the security module security requirements have been validated to a specified security level.correctly

implemented. The current version of FIPS 140[NIST01, NIST19a] and information about the NIST 

Cryptographic Module VerificationValidation Program are available at: 

http://csrc.nist.gov/cryptval/.under [NIST20e] in Appendix C: References. Note that a voting device 

can use more than one cryptographic module, and quite commonly can use a software module for 

some functions and a hardware module for other functions. This only applies to the software module

– the underlying hardware platform is omitted from this requirement. 

External references: FIPS 140

NIST Cryptographic Module Verification Program 

Prior VVSG source: VVSG 2007 - 5.1.1-A

Applies to: Cryptographic modules 

13.3-B – E2E cryptographic voting protocols

Cryptographic functions specific to E2E cryptographic voting protocols must adhere to 

requirements set by the certification authorityEAC and are omitted from FIPS 140-2 

validation. 

Discussion

CommonplaceDiscussion

The cryptographic E2E verifiable voting protocol used by the voting system is subject to the 

evaluation in requirement 9.1.6-B – Verified Cryptographic Protocol. Common place
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cryptographic operations used within E2E systems, such as encryption, decryption, and 

hashing, are not subject to the FIPS 140-2 [NIST01, NIST19a] validation requirement.

These new types of systems might need additional requirements to be deployed in a secure manner. 

External references: FIPS 140-2

Prior VVSG source: VVSG 2007 - 5.1.1-A

Applies to: Cryptographic E2E verifiable voting systems 

Related requirements: 9.1.6-A – Verified cryptographic protocol

13.3-C – Cryptographic strength

Devices using cryptography must employ NIST approved algorithms with a security strength 

of at least 112-bits.

Discussion

At the time of this writing, NIST specifies the security strength of algorithms in SP 800- 57, Part 1 

<http://csrc.nist.gov/publications/nistpubs/index.html>.[NIST20a]. This NIST recommendation will 

be revised or updated as new algorithms are added, and if cryptographic analysis indicates that some 

algorithms are weaker than presently believed. The security strengths of SP 800-57 are based on 

estimates of the amount of computation required to successfully attack the particular algorithm. The 

specified strength should be sufficient for several decades. 

This requirement is not intended to forbid all incidental use of non-approved algorithms by OS 

software or standardized network security protocols.

External references: SP 800-57, Part 1

Prior VVSG source: VVSG 2007 - 5.1.1-B

13.3-D – MAC cryptographic strength

The key used with Message Authentication Codes must also have a security strength of at 

least 112 bits and use a 96-bit tag length. 

Discussion

Message authentication codes of 96-bits are conventional in standardized secure 

communications protocols, and acceptable to protect voting records and systems. 

Prior VVSG source: VVSG 2007 - 5.1.1-B
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13.3-E – Cryptographic key management documentation

The voting system documentation must describe how key management is to be performed. 

Discussion

This document provides procedural steps that can be taken to ease the burden of key management 

and safely perform these operations. 
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13.4 - The voting system protects the integrity, authenticity, and 

confidentiality of sensitive data transmitted over all networks.

13.4-A – Mutual authenticationConfidentiality and integrity protection of 

endpoints 

Data must only be transmitted by a mutually authenticated connection. data

The voting system must:

1. mutually authenticate all network connections;

2. cryptographically protect the confidentiality of all data sent over a network; and

3. cryptographically protect the integrity of all election data sent over the network.

Discussion

Mutual authentication provides assurance that each electronic device is legitimate. Mutual 

authentication can be performed using various protocols, such as IPsec and SSL/TLS. Only wired local 

area network (LAN) communication, such as ethernet, is possible for VVSG 2.0 voting systems. This 

requirement includes network appliances such as switches, firewalls, and routers within its scope.

Prior VVSG source: VVSG 2007 - 5.6.3-B

Related requirements: Access Control, Detection & Monitoring

Applies to: Voting systems with networking capabilities 

13.4-B – Confidentiality protection for transmitted data

A voting system transmitting data must cryptographically protect the confidentiality of all 

data sent over a network at the transport layer or higher.

Discussion

This does not prevent the use of “double encrypted” connections employing cryptography at multiple 

layers of the network stack. Data, such as ballot images, must be encrypted before transmission.

13.4-C – Integrity protection for transmitted data

1. A voting system transmitting data must cryptographically protect the integrity of all 

election data sent over the network.

Discussion
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Integrity protection ensures that any inadvertent or intentional alterations to data are detected by 

the recipient. Integrity protection for data in transit can be provided through the use of various 

protocols, such as IPsec VPNs and SSL/TLS. For more information about TLS implementations, see 

NIST SP 800-52 rev. 2, Guidelines for the Selection, Configuration, and Use of Transport Layer Security 

(TLS) Implementations [NIST19b].

Applies to: EMS, Vote capture and tabulation system 

13.4-D – Verification of election data 

A receiving voting system must... 

1. Cryptographically verify the integrity and authenticity of all election data received.

1. Immediately log onscreen any verification error of received election results.

2. Immediately present on-screen any verification errors.

3. Not tabulating or aggregating any data that fails verification.

Discussion

This information is a first line of defense against accidental errors or a malicious incident regarding 

modified or false election records. 

This prevents the use of election results that did not pass cryptographic verification. 

Applies to: EMS, Vote capture and tabulation system

Principle 14

System Integrity
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The voting system performs its intended function in an unimpaired 

manner, free from unauthorized manipulation of the system, whether 

intentional or accidental. 

14.1 - The voting system uses multiple layers of controls to provide 

resiliency against security failures or vulnerabilities. 

14.2 - The voting system is designed to limit its attack surface by 

avoiding unnecessary code, data paths, connectivity, and physical ports, 

and by using other technical controls. 

14.3 - The voting system maintains and verifies the integrity of 

software, firmware, and other critical components. 

14.4 - Voting system software updates are authorized by an 

administrator prior to installation.

Principle 14

System Integrity

The voting system performs its intended function in an unimpaired 

manner, free from unauthorized manipulation of the system, whether 

intentional or accidental. 
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The requirements for Principle 14 include ensuring that the voting system provides redundancy 

against security failures, limits its attack surface, maintains and verifies the integrity of all 

critical components, and authorizes all software updates before they are installed.

14.1 – Voting system provides redundancyDocumented resiliency against security failures or 

vulnerabilities covers the requirement that the system’s documentation contains a risk 

assessment which provides technical controls or a notation showing the acceptable risk for 

each documented threat to system integrity. This document will describe how all controls work 

together to prevent, mitigate, and respond to attacks on the system. The system will also 

document necessary processes that need to occurmust be carried out by election officials or 

others to ensure the integrity of the system.

14.2 – Voting system is Designed to limit its attack surface by meeting the following 

requirements.requires that the system will prevent extraneous processes and services from 

being installed or executed, and will disable networking and non-essential features. The voting 

system should not be capable of wireless networking or connecting to external networks. The 

system will visually show an indicator when networking functionality is enabled and disabled 

and will follow a secure configuration guide for all underlying operating systems and other 

voting system components.

The system documentation will include the guidance used to ensure the system is securely 

configured. The system application will not contain unused or dead code. The system’s 

underlying platform will provide and make use of modern exploit mitigation technologies.

The system application will not import entire software libraries where individual functions are 

more practical. The voting system will have the capability to restrictof restricting access to 

physical ports that are to be used solely by election judges and administrators.

The underlying system platform generally needs to be free of well-known vulnerabilities before 

certification, unless the certification authority allows it. In that case, a list of these 

vulnerabilities will be provided to the certification authorities before it is certified. 

14.3 – Voting system maintains and verifies the integrity of all critical components Supply 

chain covers the requirement that a voting system’s documentation contain:

• a supply chain risk management strategy,

• a list of critical components defined by criticality analysis, and

• hardware and software information for the critical components defined in 14.3-B.

The sections in Guideline 14.3 include:

1 – Boot integrity deals with the requirement that the voting system cryptographically verifies 

system integrity before the operating system is loaded into memory. If the system fails boot 

validation, it will not boot, will provide an onscreenon-screen alert, and may log this failure 

along with any information necessary to understand the failure.
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2 – Software integrity states that the voting system will only allow digitally signed software and 

firmware to be installed. The system cryptographically verifies the digital signature before 

installation and whitelists all application running in userspace. against an allowlist that identifies 

all approved and properly installed applications. It will also protect the integrity and 

authenticity of the whitelistallowlist configuration files.

14.4 – Authorized software updates are authorized prior to installation covers the 

requirement that the voting system authenticates administrators:

• before an operating system update,

• before a software update to the system application and related hardware, and

• before a firmware or driver update.
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14.1 - The voting system uses multiple layers of controls to provide 

resiliency against security failures or vulnerabilities. 

14.1-A – Risk assessment documentation

The voting system’s documentation must contain a risk assessment 

Discussion

Risk assessments are a foundation of effective risk management. Additionally, they help to facilitate 

decision making at the organization, business process, and information system levels. Some decisions 

may include prioritizing the mitigation or prevention of high risks that are likely to have a high impact 

an election. Many methods of conducting risk assessments exist, including NIST SP 800-30-1: Guide 

for Conducting Risk Assessments [NIST12] or ISO/IEC 27005:2011 Information technology --- Security 

techniques --- Information security risk management. [ISO18d].

External references: NIST SP 800-30-1: Guide for Conducting Risk Assessments 

ISO/IEC 27005:2011 Information technology -- Security 

techniques -- Information security risk management

Related requirements: 3.1.3-E – Risk Analysis

14.1-B – Addressing and accepting risk 

The voting system’s risk assessment documentation must provide technical controls or a 

notation showing the acceptance of risk for each documented threat to voting system 

integrity. 

Discussion

Assigning controls or accepting risk is a key part of the risk assessment process. This requirement 

assists in providing the evidence that a manufacturer has gone through the risk determination 

process. NIST SP 800-53 revision 5 Security and Privacy Controls for Information Systems and 

Organizations [NIST20h] can be useful to identify controls that can assist with addressing any 

identified threats.

Related requirements: 3.1.3-E – Risk Analysis

14.1-C – System security architecture description 

The voting system’s risk assessment documentation must describe how physical, technical, 

and operational controls work together to prevent, mitigate, and respond to attacks on the 

voting system. This includes the use of: 

1. cryptography,

2. malware protection,
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3. firewall access control lists, rules, and configurations, and 

4. system configurations.

Discussion

Risk assessments can be large, complicated documents. This requirement ensures that a single 

narrative exists to explain to election officials and other system owners how the overall security 

operates for the voting system. 

Related requirements: 3.1.3-C – Physical security

14.1-D – Procedural and operational security 

The voting system must document necessary procedural and operational processes that 

need to occur to ensure integrity of the system.

Discussion

Procedural and operational security processes play a key role in overall system security. If any of 

these procedures are necessary to ensure system integrity or system security, these practices need to 

be well documented and explained. 
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14.2 - The voting system limits its attack surface by avoiding 

unnecessary code, data paths, connectivity, and physical ports, 

and by using other technical controls. 

14.2-A – Extraneous processes and services

The voting system must prevent extraneous processes and services from being installed or 

executed. 

Discussion

Attack surface mitigation limits the voting system’s exposure to malicious 

activity. The presence of Non-essential programs or network services severely 

increases attack surface. This can include network services, superfluous 

userspace processes, integrated development environment, and 

compilers.networking interfaces

14.2-B – Non-essential features

The voting system must disable networking and other features that are non-essential to the 

function of the voting system by default. 

Discussion

When the voting system is booted, networking and other functions are prohibited from running. For 

instance, networking interfaces such as eth, wlan,Wi-Fi and hciBluetooth should be offdisabled. 

By disabling features that are non-essential to the voting system, this decreases the attack surface by 

limiting the functionality and decreasing the entry points that may be accessed by unauthorized 

users.

14.2-CB – Network status indicator

If a voting system has network functionality, the voting system application must visually 

show an indicator within the management interface when networking functionality is 

enabled and disabled. 

Discussion

This helps to ensure that network functionality is not enabled by accident. 
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14.2-DC – Wireless communication restrictions

Voting systems must not be capable of establishing wireless connections. as provided in this 

section. 

Discussion

Wireless connections can expand the attack surface of the voting system by opening it up to overthe-air attacks. Over-the-air access can allow for adversaries to attack remotely without physical 

access to the voting system. By disallowing wireless capabilities in the voting system, this limits the 

attack surface and restricts any network connections to be hardwired. Examples of how wireless can 

be disabled may include the following:

• a system configuration process that disables wireless networking devices,

• disconnecting/unplugging wireless device antennas, or

• removing wireless hardware within the voting system.

This requirement does not prohibit wireless hardware within the voting system so long as the 

hardware cannot be used e.g. no wireless drivers present.

This requirement applies solely to voting systems that are within the scope of the VVSG. It is not a 

prohibition on wireless technology within election systems overall. This requirement does not impact 

or restrict the use of assistive technology (AT) within the polling place. Voters with wireless AT may 

have to use an adapter that leverages the 3.5 mm headphone jack.

Related requirements: 15.4-C – Documentation for disabled wireless

8.1-E – Standard audio connectors

15.4-C – Documentation for disabled wireless

Applies to: Voting System

14.2-ED – Wireless network status indicator

If a voting system has network functionality, the voting system application must visually 

show an indicator within the management interface when to confirm that wireless 

networking functionality is enabled and disabled.

Discussion

Note that this is in addition to the networking identifier. 

Wireless is a significant avenue for system compromise. This indicator ensures that wireless 

functionality is not enabled by accident.

14.2-FE – External network restrictions

A voting system must not be capable of...configured to:

1. establishingestablish a connection to an external network, or
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2. connectingconnect to any device that is capable of establishing a connection to an 

external networkto the voting system.

Discussion

The basic instructions provided by a vendor should clearly indicate that the intended use and 

installation of voting systems does not involve any connections to the internet.implements an air gap 

between the voting system and external networks or external devices. This requirement is intended 

to limit the voting systems attack surface and disallow connections of the voting system to 

technologies such as,:

• e-pollbooks,

• public switched telephone networks (PSTNs), orand

• cellular modems.

Internet capabilities within the voting system expandsIn particular, connections to the internet 

expand the attack surface even further than other wireless technologies because the data traverses 

over the internet, which touchesreaches all over the world. This type of access allows a malicious 

actor to attack from various distances, meaning they do not have to be in close proximity of a polling 

place or near a specific jurisdiction. Exposure to the internet could allow nation-state attackers to 

gain remote access to the voting system. With remote access an attacker may be able to view all files 

within a voting system and make modificationmodifications to files within the voting system. These 

files may include, election results and ballot records.

This type of exposure could also make voting systems vulnerable to ransomware. Ransomware is a 

type of malware that could deny access to election data or functionality, usually by encrypting the 

data with a key known only to the hacker who deployed the malware. Ultimately an attacker, could 

render a voting system non-operational, until a ransom is paid. 

Related requirements: 15.4-B – Secure configuration documentation

Applies to: Voting system

14.2-GF – Secure configuration and hardening documentation

The voting system must follow a secure configuration guide for all underlying operating 

systems and other voting system components, with any deviations from best practicethe 

secure configuration guidance documented and justified.

Discussion

Properly configuring an operating system is a difficult and complex task, with small settings 

potentially causing a large impact. Industry, NIST, and various agencies within the DoD offer guidance 

for specific operating systems, as do OS and component manufacturers. Some examples include 
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Security Technical Implementation Guides (STIGs) [DISA20] and the Center for Internet Security (CIS) 

benchmarks.

Documenting deviations ensures that important settings are not overlooked and decisions to deviate 

are properly considered.

Related requirements: 15.4-B – Secure network configuration documentation

14.2-H – Secure configuration and hardening documentation

14.2-G – Unused code

The voting system documentation must include the guidance used to securely configure the 

voting system

Discussion

Access to the guidance used for secure configuration provides a reference to ensure the 

voting system is securely configured.software

Related requirements: 15.4-B Secure configuration documentation

14.2-I – Unused code

The voting system application must not contain unused, or dead code. 

Discussion

An attacker may be able to take advantage of the unused code and introduce software bugs/exploits 

that can be used to make the voting system vulnerable. 

Dead code is source code that can never be executed in a running program. because the surrounding 

code makes it impossible for a section of code to ever be executed [. See MITRE CWE-561-

https://cwe.mitre.org/data/definitions/561.html]. [MITRE20]. Software with dead code is 

considered poor quality and reduces maintainability.

External references: MITRE CWE-561

Applies to: Voting System Application

This requirement does not restrict the use of defensive code, such as exception handling to prevent 

failures because this code is still traversed to check conditions.
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14.2-J –H – Use of exploit mitigation technologies within platform 

The underlying platform of The voting system must provide modernuse exploit mitigation 

technologies such asincluding data execution prevention (DEP) and address space layout 

randomization (ASLR). ), or equivalent mitigations.

Discussion

DEP and ASLR are commonplace exploit mitigation technologies that can help prevent a variety of 

vulnerability types, including memory corruption errors like buffer overflows. If the voting system 

does not use DEP and ASLR, the equivalent mitigation technologies used must be identified.

14.2-K – Application use of exploit mitigation technologies 

The underlying platform of the voting system must make use of the exploit mitigation 

technologies provided by the underlying system.

Discussion

Applications need to be written and compiled in such a way as to make use of underlying exploit 

mitigation technologies. 

See the OWASP Application Security Verification Standard [OWASP19] for more information about 

exploit mitigation.

14.2-LI – Importing software libraries

The voting system applicationsoftware must not import entire software libraries where 

individual functionsonly library components that are more practicalnecessary. 

Discussion

Importing entire software libraries significantly increases the attack surface of the software. 

Importing only the components of a library, such as modules, functions, or classes needed is a useful 

attack surface minimization strategy. Following the language’s intended import design, such as 

importing only the specific module needed from a more general “standard” library, will also help with 

this goal.

This requirement is not intended to encourage developers to avoid the import process by copying 

code directly to software, which would greatly complicate the update process.

Not all 3rd party libraries are easily modifiable, making this attack surface reduction strategy 

impractical.

Applies to: Voting System Application
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14.2-M – Physical port restrictionJ – Vulnerability management plan

The voting system documentation must haveinclude the capability to restrict access to 

physical ports that are meant to be used solely by election judgesplan for how to address 

vulnerabilities found in the voting system and administrators.at minimum include the 

following:

1. how the voting system design process identifies and addresses well-known

vulnerabilities;

2. disclosure of all known vulnerabilities within the system,

3. a patch management plan; and

4. the method to receive and send reports of vulnerabilities.

Discussion

This requirement informs how a voting system vendor is able to manage verified vulnerabilities to 

their voting system. 

Certain information can also be included for each vulnerability, such as any severity, impact, or 

exploitability scores.Discussion

Physical port access needs to be restricted when not in use. This requirement is not meant to impede 

the use of accessible technology. This requirement assists in restricting adversaries from adding 

wireless adapters or other malicious adapters to the voting system.

Related requirements: Physical Security

Tools like the Common Vulnerability Scoring System (CVSS) can be used to communicate the 

metrics (including the severity) of software vulnerabilities. 

For more information about vulnerability and patch management, see NISTIR 8011 Volume 4,

Automation Support for Security Control Assessments: Software Vulnerability Management [NIST20c]

and NIST SP 800-40, Guide to Enterprise Patch Management Technologies [NIST13b].

14.2-D – Wireless Communication Restrictions

14.2-NK – Known vulnerabilities

The underlying voting system platform must be free of well-known vulnerabilities before 

certification, unless otherwise noted by the certification authorityas identified in the 

vulnerability management plan.

Discussion

Vulnerability scanning tools can be used to identify known vulnerabilities in software and firmware. 

The U.S. National Vulnerability Database (NVD) is one resource that can be useful for identifying 
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known vulnerabilities. Other vulnerability databases also exist and can be leveraged for full 

vulnerability coverage that might not be identified by automated scanning tools.
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14.2-O – List of known vulnerabilities

If the certification authority allows certification of the voting system with known 

vulnerabilities, a list of these vulnerabilities must be provided to the certification authority 

before it is certified.

Discussion

Certain information can also be included for each vulnerability, 

such as any severity, impact, or exploitability scores.14.3 - The 

voting system maintains and verifies the integrity of software, 

firmware, and other critical components. 

14.3-A – Supply chain risk management strategy

The voting system’s documentation must contain a supply chain risk management strategy 

that at minimum includes the following:

1. a reference to the template or standard used, if any, to develop the supply chain 

risk management strategy;

1. Identification and prioritization of the critical systems, components and services

2. the assurance requirements to mitigate supply chain risks;

2.3.the contract language that requires suppliers and partners to provide the 

appropriate information to meet the assurance requirements of the supply chain 

risk management strategy. This includes the products or services acquired from 

the suppliers/partners and any evidence or artifacts that attest to the required 

level of assurance.;

3.4.the plan for reviewing and auditing suppliers and partners; and 

4.5.the response and recovery plan for a supply chain risk incident.

Discussion

Supply chain risks may include insertion of counterfeits, unauthorized production, tampering, theft, 

insertion of malicious software and hardware, as well as poor manufacturing and development 

practices in the technology supply chain. These risks are associated with an organization’s decreased 

visibility into, and understanding of, how the technology that they acquire is developed, integrated, 

and deployed, as well as the processes, procedures, and practices used to assure the integrity, 

security, resilience, and quality of the products and services. These risks can be managed by...

• following Appendix E of NIST SP 800-161 – Supply Chain Risk Management Practices [NIST15b]

for Federal Information Systems and Organizations guidance, (Appendix E provides a supply 

chain management plan(strategy) template.).
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• utilizing the NIST Cybersecurity Framework Version 1.1. [NIST18c] by referencing the Supply 

Chain Risk Management category and subcategory, and

• referencing the relevant security controls for supply chain in NIST SP 800-53 Rev. 5 Security and 

Privacy Controls for Information Systems and Organizations [NIST20b].

External references: NIST SP 800-161 – Supply Chain Risk Management 

Practices for Federal Information Systems and 

Organizations

NIST Cybersecurity Framework Version 1.1

NIST SP 800-53 Rev. 5 

Contract language provided must include the products or services acquired from the 

suppliers/partners and any evidence or artifacts that attest to the required level of assurance.

14.3-B – Criticality analysis

The voting system’s documentation must include a list of critical components and suppliers 

defined by a criticality analysis. and supplier impact analysis

Discussion

Defining the critical components and supplier of the voting system can assist in prioritizing their 

importance to the voting process and identifying the impact to security, privacy and performance for 

failure or compromise. 

This can be supplemented by following NISTIR 8179 Criticality Analysis Process Model - Prioritizing 

Systems and Components. [NIST18b] and NISTIR 8272, Impact Analysis Tool for Interdependent Cyber 

Supply Chain Risks [NIST20d].

External references: NISTIR 8179 – Criticality Analysis Process Model –

Prioritizing Systems and Components

14.3-B.1 –C – Bill of materials 

The voting system’s documentation must include the hardware and software information for 

the critical components defined in the 14.3-B and at minimum list the following information 

for each component:

1. component name;

2. manufacturer;

3. model or version; and
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4. applicable platform for software (e.g., Windows or Linux)).

Discussion

This requirement will use the critical components defined in the critical analysis of 14.3-B. –

Criticality analysis. At minimum the bill of materials for critical components are required, but this 

does not restrict the voting system vendor from listing the bill of materials for other components.

This is a common practice when providing a hardware bill of materials. It is not as common to 

produce a bill of materials for software and as standards/best practices are developed, they should 

be considered for inclusion in the software bill of materials. 

External references: SAFECode -For more information about the risks of third-party components and 

developing software bills of materials, see “Managing Security Risks Inherent in the Use of Third-party 

Components” [SAFECode19] and resources from the National Telecommunications and Information 

Administration about Software Bills of Materials [NTIA19].

14.3.1 – Boot integrity

14.3.1-A – Cryptographic boot verification

The voting system must cryptographically verify systemfirmware and software integrity 

before the operating system is loaded into memory.

Discussion

This requirement does not mandate hardware support. for cryptographic verification. This 

requirement could be met by trusted boot, but other software-based solutions exist. This includes a 

software bootloader cryptographically verifying the OS prior to execution. Verifying the bootloader 

itself is excluded from this requirement, but not prohibited. 

Applies to: Vote-capture and tabulation device, EMS

14.3.1-B – Preventing of boot on error

If the voting system fails boot validation, the voting system must not boot and provide an 

onscreen alert.

Discussion

System users need to be notified when the voting system is either corrupted or has been maliciously 

modified. 

Boot validation prevents unauthorized operating systems and software from being installed or run on 

a system. 
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Applies to: Vote-capture and tabulation device, EMS

14.3.1-C – LoggingNotification of verification boot validation failure

The voting system must log If the voting system does not pass boot validation, it must 

present an on-screen alert and includeprovide any other necessary information to 

understand the failure.

Discussion

Failure of boot validation needs to be loggedprovided to users so these errors can be further 

analyzed when needed. If the voting system is capable of pre-boot logging, failure information could 

be stored in a log for future analysis.

Applies to: Vote-capture and tabulation device, EMS

14.3.2 – Software integrity

14.3.2-A – Installing software

The voting system must only allow digitally signed software and firmware to be installed.

Discussion

Signed software and firmware ensures that it is not modified before installation, and that it is being 

distributed by the proper entity. 

14.3.2-B – Software verification for installation

The voting system must cryptographically verify the digital signature of software and 

firmware before it is installed.

Discussion

The security properties of integrity and authenticity are not achieved unless the digital signature for 

the signed software and firmware is cryptographically verified. 

14.3.2-C – Software whitelistingApplication allowlisting

The voting system must whitelist all only run applications running in userspacethat have 

been verified against an allowlist.

Discussion

This is the principle malware prevention mechanismrequirement helps ensure only authorized 

applications run on the voting system. One method of achieving this is cryptographically verifying the 

digital signatures of all applications before they are run on the voting system. 
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Applies to: Vote-capture device 

14.3.2-D – Integrity protection for software whitelistsallowlists

The voting system must protect the integrity and authenticity of the whitelistallowlist

configuration files.

Discussion

If the whitelistallowlist is improperly modified, the software whitelistingallowlisting mitigation can be 

defeated. The most common way of providing whitelistallowlist configuration file protection could be 

a digital signature.
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Applies to: Vote Capture Device 

14.4 - Voting system software updates are authorized by an 

administrator prior to installation. 

14.4-A – Authenticated operating system updates

The voting system must authenticate administrators before an operating system update is 

performed.

Discussion

Administrators are required to be authenticated before they can update the voting system, 

regardless of whether the updated done by a networked method or performed using physical media.

Related requirements: Access Control11.3.1-B – Multi-factor authentication for 

critical operations

Applies to: Vote Capture Device 

11.3.1-C – Multi-factor authentication for administrators

14.4-B – Authenticated application updates

The voting system must authenticate administrators before a software update to the voting 

system application and related software.

Discussion

Administrators are required to be authenticated before they can update the voting system, whether 

the update is applied by a network method or physical media. 

Related requirements: Access Control11.3.1-B – Multi-factor authentication for 

critical operations

Applies to: Vote capture and tabulation device, Network appliances, 

EMS

11.3.1-C – Multi-factor authentication for administrators

14.4-C – Authenticated firmware updates

The voting system must authenticate administrators before a firmware or driver update.

Discussion

Administrators are required to be authenticated before they can update the voting system, 

regardless if network enabled update is performed or via physical media.
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Related requirements: Access Control11.3.1-B – Multi-factor authentication for 

critical operations

Applies to: Vote Capture Device 

11.3.1-C – Multi-factor authentication for administrators
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Principle 15

Detection and Monitoring

The voting system provides mechanisms to detect anomalous or 

malicious behavior. 

15.1 - Voting system equipment records important activities through 

event logging mechanisms, which are stored in a format suitable for 

automated processing. 

15.2 - The voting system generates, stores, and reports all error 

messages as they occur. 

15.3 - The voting system is designed to protect against malware. 

15.4 - A voting system with networking capabilities employs 

appropriate, well-vetted modern defenses against network-based 

attacks, commensurate with current best practice.
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Principle 15

Detection and Monitoring

The voting system provides mechanisms to detect anomalous or 

malicious behavior. 

The requirements for Principle 15 include ensuring that voting system equipment records 

important activities through event logging, and generates and reports all error messages as 

they occur. The system employs mechanisms to protect against malware. Systems with 

networking capabilities employ defenses against network-based attacks.

15.1 – Voting system equipment records important activities through Event logging

mechanisms covers the requirements that the system be capable of logging events that occur 

in a voting system and of exporting those logs. The system will not log any information 

identifying a specific voter or connecting a voter to a specific ballot. At a minimum, the system 

will log events includingpertaining to:

• general system functions

• networking

• software, and

• voting functions

In addition, when a system administrator is accessing a configuration file, the system needs to 

log identifying information about the individual and group or roleuser accessing that file

including the user’s, group or role.

15.2 – Voting system generates, stores, and reports all Error messages as they occur covers 

the requirement that systems provide immediate notification to the user when an error occurs 

and that system documents include procedures for handling errors, includingas well as logging all 

errors and creating error reports. The system documentation must include procedures for how 

election officials should handle errors.

15.3 – Voting system employs mechanisms to protect against malware deals with the 

requirement that vote capture and tabulation devices verify software using digital signatures or 

application whitelisting. The sections in 15.3.1 cover requirement specific to malware protection 

mechanisms.

1

15.3 – Malware protection mechanisms deals with the need for COTS devices that provide EMS 

functionality to:

• deploy mechanisms to protect against malware,

• promptly notify an election official when malware is detected, and

• provide notification upon the removal or remediation of malware.

The system’s malware protection mechanisms need to be updatable and the documentation 

needs to include the process and procedures for performing the updates. The voting system will 
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log instances when it detects and remediates malware along with malware remediation 

activities.

15.4 – Voting system with networking capabilities employs appropriate defenses

15.4 – Defense against network-based attacks deals with the requirement for system 

documentation to include the network architecture of any internal network used by any portion 

of the voting system., as well as any documentation needed to explain how wireless capabilities 

have been disabled within the system. Documentation also lists security relevant configurations 

and is accompanied by network security best practices. The system includes a firewall or 

intrusion detection system (IDS). Default configurations for the system implement the principle 

of least privilege. In addition, the system needs to be capable of updating rules and policies for 

firewalls and other network appliances., including air-gap procedures to protect sensitive 

systems from external networks like the internet.

15.1 - Voting system equipment records important activities through 

event logging mechanisms, which are stored in a format suitable 

for automated processing. 

15.1-A – Event logging

The voting system must be capable of logging events that occur in a voting system.

Discussion

The ability to log events within a system allows for continuous monitoring of the voting system. 

These logs provide a way for administrators to analyze the voting system’s activities, diagnose issues, 

and perform necessary recovery and remediation actions.

15.1-B – Exporting logs 

The voting system must be capable of exporting logs.

Discussion

Exporting logs offers the opportunity for external review, clearing storage, and a method to compare 

with future logs.

15.1-C – Logging voter information 

The voting system must not log any information:

1. identifying a specific voter, and

2. connecting a voter to a specific ballot.
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Discussion

No voter information is stored anywhere within voting system logs. This would violate voter ballot 

secrecy because it can link a voter to their ballot selections.

Related requirements: 10.1-A – System use of voter information

11.1-B and Ballot secrecy– Voter information in log files 

15.1-D – Logging event types 

At minimum, the voting system must log the events included in Table 15-1.

Discussion

Table 15-1 – System events to log provides a list of events that will be included in the voting system 

event logs. The voting system is not limited to the events in the table.

Related requirements Access Control, System Integrity, Data Protection

Logging system events provides insight into general system metrics, errors, and vulnerabilities. 

Information gathered from logs can be used to improve system performance by preventing future 

errors/issues or automate issue handling.

Table 15-1 – System events to log

Device generated error 

and exception messages

Includes but is not limited to:

• The source and disposition of system 

interrupts resulting in entry into 

exception handling routines.

• Messages generated by exception 

handlers.

Programmed 

device 

System Event Description A

p

p

l

i

e

s 

T

o

General system functions

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• The identification code and number of 

occurrences for each hardware and 

software error or failure.

• Notification of physical violations of 

security.

• Other exception events such as power 

failures, failure of critical hardware 

components, data transmission errors, 

or other types of operating anomalies.

• All faults and the recovery actions 

taken.

Device generated error and exception 

messages such as ordinary timer system 

interrupts and normal I/O system 

interrupts do not need to be logged.

Critical system status 

messages

Critical system status messages other than 

information messages displayed by the 

device during the course of normal 

operations. Includes but is not limited to:

• Diagnostic and status messages upon 

startup

• The “zero totals” check conducted 

before opening the polling place or 

counting a precinct centrally

• For paper-based systems, the 

initiation or termination of scanner 

and communications equipment 

operation

• Printer errors

• Detection or remediation of malware 

or other malicious software

• Cryptographic boot validation 

success/failure

Programmed 

device

Non-critical status 

messages

Non-critical status messages that are 

generated by the device’s data quality 

monitor or by software and hardware 

condition monitors.

Programmed 

device

Events that require 

election official 

intervention

Events that require election official 

intervention, so that each election official 

access can be monitored, and access 

sequence can be constructed.

Programmed 

device

Device shutdown and 

restarts

Both normal and abnormal device 

shutdowns and restarts.

Programmed 

device 
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Changes to system 

configuration settings

Configuration settings include but are not 

limited to registry keys, kernel settings, 

logging settings, and other voting device 

configuration settings.

Programmed 

device

Integrity checks for 

executables, 

configuration files, data, 

and logs.

Integrity checks that can indicate possible 

tampering with files and data.

Programmed 

device with file 

systems

The addition and 

deletion of files.

Files that are added or deleted from the 

voting device.

Programmed 

device with file 

systems

System readiness results Includes but is not limited to:

• System pass or fail of hardware and 

software test for system readiness

• Identification of the software release, 

identification of the election to be 

processed, polling place identification, 

and the results of the software and 

hardware diagnostic tests

• Pass or fail of ballot style compatibility 

and integrity test

• Pass or fail of system test data 

removal

• Zero totals of data paths and memory 

locations for vote recording

Programmed 

device

Removable media events Removable media that is inserted into or 

removed from the voting device.

Programmed 

device

Backup and restore Successful and failed attempts to perform 

backups and restores.

Election 

Management 

Systems

Authentication related 

events

Includes but is not limited to:

• Login/logoff events (both successful 

and failed attempts)

• Account lockout events

• Password changes

Programmed 

device

Access control related 

events

Includes but is not limited to:

• Use of privileges (such as a user 

running a process as an administrator)

• Attempts to exceed privileges

• All access attempts to application and 

underlying system resources

Programmed 

device

Authentication and Access Control

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• Changes to the access control 

configuration of the voting device

User account and role 

(or groups) management 

activity

Includes but is not limited to:

• Addition and deletion of user accounts 

and roles

• User account and role suspension and 

reactivation

• Changes to account or role security 

attributes such as password length, 

access levels, login restrictions, and 

permissions

• Administrator account and role 

password resets

Programmed 

device

Enabling or disabling 

networking functionality 

Includes but is not limited to:

• Wired networking 

• Wireless networking 

Programmed 

device

Installing, upgrading, 

patching, or modifying 

software or firmware

Logging for installation, upgrading, 

patching, or modifying software or 

firmware include logging what was 

installed, upgraded, or modified as well as 

a cryptographic hash or other secure 

identifier of the old and new versions of 

the data.

Programmed 

device

Changes to configuration 

settings

Includes but is not limited to:

• Changes to critical function settings. 

At a minimum, critical function 

settings include location of election 

definition file, contents of the election 

definition file, vote reporting, location 

of logs, and voting device 

configuration settings.

• Changes to device settings including, 

but not limited to, enabling and 

disabling services.

• Starting and stopping processes.

Programmed 

device

Abnormal process exits All abnormal process exits. Programmed 

device

Successful and failed 

database connection 

attempts (if a database is 

used).

All database connection attempts. Programmed 

device with 

database 

capabilities

Networking 

Software

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Cryptographic Functions

Changes to 

cryptographic keys

At a minimum, critical cryptographic 

settings include key addition, key removal, 

and re-keying.

Programmed 

device

Ballot definition and 

modification

During election definition and ballot 

preparation, the device can provide 

logging information for preparing the 

baseline ballot formats and modifications 

to them, including a description of the 

modification and corresponding dates. 

Includes but is not limited to:

• The account name that made the 

modifications.

• A description of what was modified 

including the file name, location, and 

the content changed.

• The date and time of the modification.

Programmed 

device

Voting events Includes:

• Opening and closing polls

• Casting a vote

• Canceling a vote during verification

• Success or failure of log and election 

results exportation

• Note: for paper-based devices, these 

requirements might need to be met 

procedurally

Programmed 

device

15.1-E – Configuration file access log 

When a system administrator is accessing a configuration file, the voting system must log 

identifying information of the individual and group or role accessing that file.

Discussion

A record of who modified a configuration file is important for auditing and accountability. The 

identifying information shouldcould include the username or the name of the user. for improved 

traceability.

Voting Functions

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15.2 - The voting system generates, stores, and reports all error 

messages as they occur. 

15.2-A – Presentation of voting application errors 

The voting system must provide immediate notification to the user when ana voting

application error occurs. 

Discussion

Voting application errors can disrupt a voter’s voting session. Immediate notification of an issue or an 

error allows for prompt recovery and remediation.

Related requirements: 7.3-A – System-related errors

7.3-K – Warnings, alerts, and instructions

15.2-B – DocumentingVoting application error handling documentation

The voting system documentation must include procedures for handling voting application 

errors. 

Discussion

Documentation will assist election officials with steps to properly address errors. 

Related requirements: 7.3-A – System-related errors

7.3-K – Warnings, alerts, and instructions

15.2-A – Presentation of voting application errors

15.2-C – Logging system errors 

The voting system must log allsystem errors.

Discussion

This requirement ensures that any system errors are logged for analysis and remediation. System 

errors do not include user errors, such as undervotes or overvotes. 

Related requirements: 15.1-D – Logging event types

15.2-D – Creating error reports 

The voting system must be capable of creating error reports.
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Discussion

Error reports allow system administrators to easily analyze the errors that occurred within a system. 

15.3 - The voting system is designed to protect against malware. 

15.3-A – Software verification 

Vote capture and tabulation devices must verify software using digital signatures, application 

whitelisting, or some combination of the two.

Discussion

Digital signatures and whitelists assist in ensuring the vote capture and tabulation 

devices are using the correct software. If unauthorized 

software is found on the device, the appropriate malware 

remediation and response procedures will be 

implemented.

Related requirements: System Integrity, Data Protection 

Applies to: Vote capture and tabulation devices 

15.3.1 – Malware protection

15.3.1-A – Malware protection mechanisms 

COTS devicesworkstations providing EMS functionality must deploy mechanisms to protect 

against malware.

Discussion

NIST SP 800-83 Revision 1 Guide to Malware Incident Prevention and Handling for Desktops and 

Laptops [NIST13a] might be useful as supplemental guidance for protecting against malware. 

Malware protection mechanisms are not required for voter-facing scanners and electronic BMDs. 

Alternatively, voter-facing scanners and electronic BMDs are required to use protection mechanisms, 

such as digital signatures and whitelists can also be useful protection mechanisms.allowlists. This 

requirement is focused on EMS COTS workstations and does not include peripherals devices (e.g., 

printers).

External reference: NIST SP 800-83 Revision 1 Guide to Malware Incident 

Prevention and Handling for Desktops and Laptops

Applies to: EMS Workstations 
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15.3.1-B – Updatable malware protection mechanisms 

The voting system’s malware protection mechanisms for COTS devices providing EMS 

functionality must be updatable.

Discussion

Malware protection mechanisms typically use software signatures to identify malware. As new 

malware signatures are received, the malware protection mechanism needs to be updated with the 

new signatures to ensure it is identifying all known malware.

Applies to: EMS Workstations, vote-capture and tabulation devices 

15.3.1-C – Documenting malware protection mechanisms 

The voting system documentation must include the process and procedures for updating 

malware protection mechanisms.

Discussion

Providing documentation of the procedures to configure the malware protection mechanisms assists 

with ensuring the malware protection mechanisms are properly updated to meet 15.3.1-.-BUpdatable malware protection mechanisms.

Applies to: EMS Workstations, vote capture and tabulation devices

15.3.1-D – Notification of malware detection 

COTS devicesworkstations and servers providing EMS functionality must 

promptlyimmediately notify an election official when malware is detected.

Discussion

Malware on an EMS device can disrupt the integrity of the data on the EMS device. Once malware is 

detected, immediate notification of malware detection allows election officials to promptly take the 

proper action to avoid data integrity issues. This requirement is focused on EMS COTS workstations 

and does not include peripheral devices (e.g., printers).

Applies to: EMS Workstations 

15.3.1-E – Logging malware detection

The voting system must log instances of detecting malware. 
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15.3.1-F – Notification of malware remediation 

COTS devicesworkstations and servers providing EMS functionality must provide a 

notification upon the removal or remediation of malware.

Discussion

Once malware it is identified on a device, operations can cease until the malware is remediated. This 

notification allows administrators and officials to know when it is safe to resume normal operations.

This requirement is focused on EMS COTS workstations and does not include peripherals devices 

(e.g., printers)

Applies to: EMS Workstation 

15.3.1-G – Logging malware remediation 

The voting system must log malware remediation activities. 

Discussion

Remediation that requires the reimaging or reinstallation of the OS, may need to be logged external 

to the voting system. Prior to reimaging, the malware detection logs could be downloaded and 

stored on another system to capture the time stamp of the malware event and preserve the malware 

event log for further analysis. 

15.4 - A voting system with networking capabilities employs 

appropriate, well-vetted modern defenses against network-based 

attacks, commensurate with current best practicepractices. 

15.4-A – Internal network architecture documentation

The voting system documentation must include the network architecture of any internal 

network used by any portion of the voting system.

Discussion

Documentation of the internal network architecture can assist with data flow analysis, proper 

network configuration, and architecture to properly support the voting system.

Applies to: Voting systems with networking capabilities 
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15.4-B – Secure network configuration documentation

The voting system documentation must list security relevant configurations and be 

accompanied by network security best practices.

Discussion

This documentation may include how external network services are not included as part of the voting 

system and are handled through a separate air-gapped process. For example, a sneaker-net process 

may be used to manually transfer elections results to another system that uses public 

telecommunications to transmit the unofficial election results to a central count center.

A variety of documentation providing secure configurations for network devices is publicly available 

from the US government.

If outside manufacturers provide guidance and best practices exist, these need to be documented 

and used to the extent practical.

This documentation may also include the use of firewalls and intrusion detection 

systems (IDS). Firewalls and IDSs are typically used to 

control and monitor the boundary between a private 

network and the internet. Although the current 

requirements do not allow for internet connectivity, 

firewalls and IDSs may also be used for internal boundaries 

and monitoring inside a private network.Applies to: 

Voting systems with networking capabilities

15.4-C – Documentation for disabled wireless

Guidance for Intrusion Detection and prevention systems can be found in NIST SP 800-94: Guide to 

Intrusion Detection and Prevention Systems [NIST07].

Related requirements: 14.2-F – Secure configuration and hardening 

documentation

15.4-C – Documentation for disabled wireless

The voting system documentation must include information about how wireless is disabled 

within the voting system.

Discussion

Documentation for how the voting system is configured to disable wireless networking is important 

to meet requirement 14.2-D – Wireless network status indicator, which disallows the use of any 

wireless connections. Example information for how wireless can be disabled may include the 

following:

• a system configuration process that disables wireless networking devices,
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• disconnecting/unplugging wireless device antennas, and

• removing wireless hardware within the voting system.

A variety of documentation providing secure configurations for network devices is publicly available 

from the US government. 

If outside manufacturers provide guidance and best practices exist, these need to be documented 

and used to the extent practical.

Related requirements: 14.2-D Wireless Communication Restrictions

Applies to: Voting systems with networking capabilities

15.4-D – Firewall and IDS

The voting system may include a firewall or intrusion detection system (IDS).

Discussion

This requirement does not include point-to-point networks which do not typically use network 

appliances. Firewalls and IDSs are typically used to control and monitor the boundary between a 

private network and the internet. Although the current requirements do not allow for internet 

connectivity, firewalls and IDSs may also be used for internal boundaries and monitoring inside a 

private network.

Applies to: Voting systems with networking capabilities

15.4-E – Least privilege

Default configurations for the voting system must implement the principle of least privilege.

Discussion

Network access is only as much as is necessary to perform the desired function.

Related requirements Access Control : 14.2-C – Wireless communication 

restrictions

Applies to: Voting systems with networking capabilities 

15.4-FD – Rule and policy updates

The voting system must be capable of regularly updating rules and policies for firewalls and 

other network appliances.

Discussion
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Network appliances and the voting system are constantly receiving improvements and information 

related to current threats. As this information is released, rules and policies might need to be 

modified to adjust to new capabilities. 
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Applies to: Voting systems with networking capabilities 

Appendix A

Glossary of Terms
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Glossary

A:

absentee ballot

Ballot used for absentee voting.

Synonyms: mail ballot, postal ballot

absentee voting

Voting that can occuris typically unsupervised at a location chosen by the voter either before or 

on election day.

Synonyms: all-mail voting, mail voting, postal voting, vote-by-mail

acceptance testing

Examination of a voting system and by the purchasing election jurisdiction to validate: 

• the performance of delivered devices to ensure they meet procurement requirements, 

and

• that the delivered system is, in fact, the certified system purchased. 

This usually happens in a simulated-use environment.

access control

The process of granting or denying specific requests to: 

• obtain and use information and related information processing services; and 

• enter specific physical facilities.

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, mobility, and cognition.

accreditation

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

accreditation body

1. Authoritative body that provides accreditation.
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2. Independent organization responsible for

• assessing the performance of other organizations against a recognized 

standard, and

• formally confirming the status of those that meet the standard.

activation device

Programmed device that creates credentials necessary to begin a voting session using a 

specific ballot style. Examples include electronic poll books and card activators that contain 

credential information necessary to determine the appropriate ballot style for the voter.

active period

Span of time during which a vote-capture device either is ready to begin a voting session or is 

in use during a voting session.

adjudication

Process of resolving flagged cast ballots to reflect voter intent. Common reasons for flagging 

include: 

• write-ins, 

• overvotes, 

• marginal machine-readable mark, 

• having no contest selections marked on the entire ballot, or 

• the ballot being unreadable by a scanner.

adjudication-required ballot

A ballot that contains contest selections that require adjudication.

administrator

A voting system user with the highest level of access.

Synonyms: admin, highest level of authorized user

air gap

A physical separation between systems that requires data to be moved by some external, 

manual procedure.
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alert time

During a voting session, the amount of time that a voting device will wait for detectible voter

activity after issuing an alert, before going into an inactive state requiring election worker

intervention.

alternative format

The ballot or accompanying information is said to be in an alternative format if it is presented 

in non-standard ballot language and format. Examples include, but are not limited to, languages 

other than English, Braille, ASCII text, large print, recorded audio.

appropriate mark

An expected mark made according to the ballot instructions.

approval voting

A vote variation used for elections in which each voter may "approve" of (that is, select) any 

number of candidates. Typically, the winner(s) is the most-approved candidate(s).

Synonyms: equal-and-even cumulative voting, proportional voting

archival media

Storage media that is designed to preserve content for an extended period of time with minimal 

data corruption or loss.

assistive technology

A device that improves or maintains the capabilities of people with disabilities (such as no 

vision, low vision, mobility, or cognitive). These devices include headsets, keypads, software, 

sip-and-puff, and voice synthesizers.

asymmetric cryptography

Encryption system that uses a public and private key pair for cryptographic operation. The 

private key is generally stored in a user's digital certificate and used typically to decrypt or 

digitally sign data. The public key is used typically to encrypt the data or verify its digital 

signatures. The keys could be used interchangeably as needed, that is, a public key can be used 

to decrypt data and the private key can be used to encrypt the data.

audio format

A ballot display format in which contest options and other information areis communicated 

through sound and speech.

Synonyms: audio ballot
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audit

1. 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.

2. Verification of statistical or exact agreement of records from different processes or 

subsystems of a voting system.

3. A review of a system and its controls to determine its operational status and the 

accuracy of its outputs.

audit devicetrail

Voting device dedicated exclusively to independently verifying or assessing the voting system's 

performance.

audit trail

Information recorded during election activities to reconstruct steps followed or to later verify 

actions taken with respect to the voting system. 

authentication

Verifying the identity of a user, process, or device, often as a prerequisite to allowing access to 

resources in an information system. Audit trails may include event logs, paper records, error 

messages, and reports.

authentication

Verifying the identity of a user, process, or device, often as a prerequisite to allowing access to 

resources in an information system. 
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B:

ballot

Presentation of the contest options for a particular voter.

ballot counting logic

The software logic that 

• defines the combinations of contest selections that are valid and invalid on a given 

ballot and, 

• determines how the contest selections are totaled in a given election.

ballot data

A list of contests and associated options that may appear on a ballot for a particular election.

ballot display format

The concrete presentation of the contents of a ballot or other information for the voter or 

election official 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. A ballot image might be a 

transient logical representation of the votes or an archival record (a cast vote record).

Archival digital image (e.g. JPEG, PDF, etc.) captured from one or more sides of a paper ballot 

cast by an individual voter.

ballot instructions

Information provided to the voter that describes the procedure for marking the ballot. This 

information may appear directly on the paper or electronic ballot or may be provided 

separately.

ballot manifest

A catalog prepared by election officials listing all the physical paper ballots and their locations 

in sequence.

ballot marking device

A device that: 
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• permits contest options to be selected and reviewed on an electronic interface, 

• produces a human-readable paper ballot, and 

• does not make any other lasting record of the voter's selections.

Synonyms: BMD, EBM, electronic ballot marker

ballot measure

A question that appears on a ballot with options, usually in the form of an approval or 

rejection.

Synonyms: ballot issue, ballot proposition, ballot question, referendum

ballot measure option

A contest option that specifies a response to a ballot measure.

ballot on demand®

A process that produces a paper ballot of the required ballot style that meets a specific voter's 

needs. The use of this process requires: 

• a system with a printer that can create a tabulatable paper ballot; and

• a device driving the printer that has all the data needed to print each ballot style and 

allows selection of the needed style. 

Note: "ballot on demand" is a registered trademark of ES&S.

Synonyms: BOD

ballot production

Process of generating ballots for presentation to voters, for example, printing paper ballots or 

configuring the ballot presentation for an electronic display.

ballot rotation

The process of varying the order of listed candidates within a contest. This allows each 

candidate to appear first on the list of candidates an approximately equal number of times 

across different ballot styles or election districts.

ballot secrecy

A goal of voting systems to ensure that no contest selections can be associated with a voter.

ballot style

Ballot dataBallot data that has been put into contest order for a particular precinct or precinct 

split and considers a particular set of voter situations. Voter situations include party affiliation 
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(for closed primaries), and age of the voter (in states that permit 17-year-olds to vote in 

primary elections), among others.

that has been put into contest order for a particular precinct and considers a particular set of 

voter situations. Voter situations include party affiliation (for closed primaries), and age of the 

voter (in states that permit 17-year-olds to vote in primary elections), among others.

barcode

An optical, machine-readable representation of data as a sequence of bars andor squares or

spaces that conform to accepted standards. Linear (1d) barcode standards include UPC, EAN 

and 128. QR is an example of a 2D barcode standard.

barcode reader

Device used to scan barcodes and convert the encoded information into a usable format. 

Barcode readers are used to scan codes on a variety of election materials including ballots, 

driver's licenses, voter ID cards, voter information packets, envelopes, and other election 

documents.

baseline voting

A vote variation in which the candidate with the most votes wins. In single-seat contests, the 

voter may only select one contest option. In multi-seat contests for n seats, the voter may 

select up to n contest options.

Synonyms: Plurality voting

batch

A collection of paper ballots or ballot images or cast vote records gathered as a group for 

tabulation or for auditing.

batch-fed scanner

An electronic voting device that typically: 

• accepts stacks of hand-marked or BMD-produced paper ballots and automatically 

processes them until the stack is empty; 

• is usually used at an election jurisdiction's central location; 

• is mostly commonly used to process absentee ballots; 

• usually has input and output hoppers for ballots;

• scans a ballot and rejects it if either unreadable or un-processable; 

• detects, interprets, and validates contest selections; 

• detects and sorts (either digitally or physically) ballots that are unreadable or unprocessable, or that contain undeterminable selections, marking exceptions, or writeins; and 

• tabulates and reports contest results as required. 
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This unit was previously referred to as central count optical scanner or CCOS.

Synonyms: CCOS, central tabulator, central-count optical scanner, high-speed optical scanner

benchmark

Quantitative point of reference to which the measured performance of a system or device may 

be compared.

blank ballot

An issued ballot without any selections made.

Synonyms: unmarked ballot

Bluetooth

A wireless protocol that allows two similarly-equipped devices to communicate with each other 

within a short distance, e.g., 30 ft.
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C:

callable unit

(Of a software program or logical design) Function, method, operation, subroutine, procedure, 

or analogous structural unit that appears within a module.

candidate

Person contending in a contest for office. A candidate may be explicitly presented as one of the 

contest options or may be a write-in candidate.

candidate option

A contest option that is associated with a candidate.

canvass

The process of compiling, reviewing, and validating election returns that forms the basis of the 

official results by a political subdivision.

cast

(v) The final action a voter takes in selecting contest options and irrevocably confirming their 

intent to vote as selected.

cast ballot

Ballot in which the voter has taken final action in selecting contest options and irrevocably 

confirmed their intent to vote as selected.

Synonyms: voted ballot

cast vote record

Archival tabulatable record of a set of contest selections produced by a single voter as 

interpreted by the voting system.

Synonyms: CVR

central reporting device

Electronic voting device that consolidates and reports vote totals from multiple precincts at a 

central location.
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certification testing

TestingTesting of a voting system performed by a testing authority (such as the EAC or a state) 

to ensure that the system meets the requirements defined in the standards being tested 

against in the manner specified in its product documentation.

of a voting system performed by a testing authority (such as the EAC or a state) to ensure that 

the system meets the requirements defined in the standards being tested against in the manner 

specified in its product documentation.

ciphertext

Data or information in its encrypted form.

closed primary

Partisan primary election in which the voter receives a ballot containing only those partyspecific contests pertaining to the political party with which the voter is affiliated, along with 

non-party-specific contests presented at the same election. Unaffiliated voters may be 

permitted to vote only on non-party-specific contests.

combined precinct

Two or more precincts treated as a single precinct for a specific election.

Synonyms: consolidated precinct, super precinct

commercial-off-the-shelf

Hardware or software components that are widely available for purchase and can be 

integrated into special-purpose systems.

Synonyms: COTS

common data format

Standard and practice of creating and storing data in a common, described format that can be 

read by other systems.

Synonyms: CDF

Common Industry Format

Format used for usability test reporting. The format is described in ISO/IEC 25062:2006 

"Common Industry Format (CIF) for Usability Test Reports," one of a group of usability 

standards. CIF is the format required for usability test reporting.

Synonyms: CIF
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component

Element within a larger voting system.

confidentiality

Prevention of unauthorized disclosure of information.

configuration management

A continuous process of recording and maintaining consistent and reliable records pertaining to 

an organization's hardware and software composition, including software version control and 

hardware updates.

conformance

Fulfilling specified requirements by a product, process, or service.

conformance testing

Process of testing device or system of devices 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.

Synonyms: conformity assessment

contest

A single decision or set of associated decisions being put before the voters (for example, the 

option of candidates to fill a particular public office or the approval or disapproval of a 

constitutional amendment). This term encompasses other terms such as "race," "question," and 

"issue" that are sometimes used to refer to specific kinds of contests. It does not refer to the 

legal challenge of an election outcome.

contest option

A votable choice that appears under a contest.

contest option position

A specified area on a ballot where a voter's selection in a particular contest can be indicated.

Synonyms: ballot marking target area, ballot selection position, target, target area

contest option vote

Vote that will be tabulated for a particular contest option. This term was previously referred to 

as valid vote.
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Synonyms: valid vote

contest selection

A selection made on the ballot by a voter with respect to a specific single contest (for example, 

a candidate, the value "Yes" or "Approve").

core logic

Subset of application logic that is responsible for vote recording and tabulation.

corrective action

Action taken to eliminate the causes of an existing deficiency or other undesirable situation in 

order to prevent it from recurring.

counted ballot

A read ballot that has been processed and whose votes are included in the vote totals.

Synonyms: tabulated ballot, tallied ballot

cross-party endorsement

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.

Synonyms: cross filing

cryptographic end-to-end(E2E) verifiable voting systems 

A voting system that uses cryptographic techniques to store an encrypted copy of the voter’s 

ballot selections while maintaining ballot secrecy and allows election outcomes to be 

independently and universally verified by members of the public. These voting systems provide 

voters with a special receipt of their cast ballot—one that allows them to verify their vote was 

included in the outcome but does not reveal to anyone how they voted.

A voting system that supports both voter verification and election verification.

Synonyms: E2EReceipt-based system

cryptographic hash

A cryptographic algorithm that computes a numerical hash value based on a data file or 

electronic message. It should be infeasible in practice to find two distinct data files or messages 

that will result in the same numerical hash value. The numerical value can be considered to be a 

fingerprint of the file or message. Colloquially known as a hash, hash function, or digital 

fingerprint. Hashes provide integrity protection.
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cryptographic key

A numeric value used as input to cryptographic operations, such as decryption, encryption, 

signature generation, or verification of a digital signature.

cryptography

Discipline that embodies the principles, means, and methods for transforming data to hide their 

semantic content, prevent their unauthorized use, prevent their undetected modification, or 

establish their authenticity.

cumulative voting

A vote variation used in multi-seat contests where a voter is permitted to distribute allowed 

selections to 1 or more candidates in whole vote increments.

cybersecurity

Measures taken to protect computer systems and data from attack and unauthorized access or 

use.
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D:

decertification

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

system or any of its components.

decryption

Cryptographic process of transforming encrypted data back into its pre-encryption form.

defense-in-depth

Also called the "Castle" approach. Multiple levels of logical and physical security measures that 

deny a single point of security failure in a system. Examples include the combined use of 

passwords, encryption, lock-and-key access, security seals, and logs.

device

Physical apparatus and any supporting supplies, materials, and logic that together form a 

functional unit that performs assigned tasks as an integrated whole.

digital certificate

A data set used to identify the holder of the certification and to verify, using a PKI, the 

authenticity of the certificate. It typically includes the holder's private key and is used for 

cryptographic operations such as digitally signing or encrypting data.

digital signature

A cryptographic operation where thea private key is used to digitally sign an electronic 

document and the associated public key is used to verify the signature. Digital signatures 

provide data authentication and integrity protection.

direct recording electronicvoter associations 

A voter’s personally identifiable information (PII) created or stored by the voting 

machinesystem that can be used to associate a voter with their ballot selections. Examples 

include first name, last name, address, driver’s license, voter registration number and other PII.

A vote-capture device that allows: 

• electronic presentation of a ballot, 

• electronic selection of valid contest options, and 
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• electronic storage of contest selections as individual records. 

It also provides a summary of these contest selections.

Synonyms: DREPII
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E:

early voting

Voting that occurs prior to election day under the supervision of election workers.

Synonyms: in-person absentee voting

early voting center

Physical location where individuals may cast a ballot before election day under the supervision 

of election workers.

Synonyms: early vote center

elected office

An office that is filled primarily or exclusively via election.

election

A formal process in which qualified voters select candidates to fill seats in one or more offices

and/or vote on one or more proposed ballot measures.

Election Assistance Commission

Election Assistance Commission, created by the Help America Vote ActHelp 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 systemvoting 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 electionselections that includes shared practices, 

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

Synonyms: EAC

election certification

The act of confirming the final official results of a jurisdiction's election. This event occurs after 

results from valid ballots are tallied from all sources (election day, absentee voting, early 

voting, provisional ballots, etc.) and results are validated and approved by those legally 

responsible.

election day

The last day on which voters may cast a ballot. Absentee ballots and early voting ballots may 

be cast in advance of election day.
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election definition

Data used in defining an election, including election districts, contests, candidates, and ballot 

style information.

election definition medium

Programmed memory devicecomponent containing all applicable election definition data 

required by the election system component where the device will be usedan election system 

device.

election district

Administrative area in which voters are entitled to vote in contests that are specific to that 

area.

election jurisdiction

A geographical area to which a practicalan authorized authority has been granted to administer 

electionselections for political or administrative offices.offices. Areas of jurisdiction apply to 

local, state, and federal levels. States, counties, cities, towns,towns, and townshipstownships

are all examples of jurisdictions.

election management system

Set of processing functions and databases within a voting system typically used to: 

• develop and maintain election definition data, 

• perform ballot layout functions, 

• create ballot presentation templates for ballot printers or devices used by voters for 

ballot markup, 

• tabulate votes, 

• consolidate and report results, and 

• maintain audit trails.

Synonyms: EMS

election official

Any person who is involved with administering or conducting an election, including government 

personnel and temporary election workers. This may include any county clerk and recorder, 

election judge, member of a canvassing board, central election official, election day worker, 

member of a board of county commissioners, member or secretary of a board of directors 

authorized to conduct public elections, representative of a governing body, or other person 

engaged in the performance of election duties as required by the election code.
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Synonyms: EO

election programming

Process by which election officials or their designees use voting system software to create the 

election definition and configure all election definition medium for use in a specific election.

Election Results report

A tabulation report produced after the closing of polls for the purpose of publicizing the vote 

counts.

Election Results Reporting System

A system that: 

• aggregates and displays election results across the election jurisdiction, 

• can be real-time or near real-time, 

• can provide a variety of formats for displaying election results, and 

• may provide direct feeds for the media.

Synonyms: ENR, ERR, election night reporting

election system

1. A technology-based system that is used to collect, process, and store data related to 

elections and election administration. In addition to voter registration systems and public 

election websites, election systems include voting systems, vote tabulation systems, 

electronic poll books, election results reporting systems, and auditing devices.

2. Entire array of procedures, people, resources, equipment, and locations associated with 

conducting elections.

election worker

Any person who interacts with those coming to vote. This includes any poll worker, election 

day worker, early voting worker, or other temporary staff engaged in supporting the voting or 

vote counting process.

electronic ballot delivery

The delivery of ballot and voter information packets electronically. The MOVE Act requires 

each state to provide for the electronic delivery (via fax, email, or an Internet-supported 

application) of ballots and related information from the local election office to the registered 

UOCAVA voter.

Synonyms: poll worker
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electronic ballot interface

Subsystem within a voting system which communicates ballot information to a voter in 

videovisual, audio, or other alternative format which allows the voter to select contest options

using vocalization or physical actions.

electronic ballot return

The return of a voted ballot or voter information packet using electronic means. This can be by 

fax, email, or through the use of an Internet supported application. Sometimes referred to as 

"Internet Voting."

electronic device

Device that uses electronic or electromechanical components.

electronic poll book

Device that partially automates the process of checking in voters, assigning them the correct 

ballot style, and marking voters who have been issued a ballot. May be used in place of a 

traditional paper poll book. E-poll books can be stand alone at the precinct with a separate 

copy of the registration list or can be networked into a central voter registration system. They 

can check and update voter records in real time.

Synonyms: EPB, e-poll book

electronic voter interface

Component of an electronic vote-capture device that communicates ballot information to the 

voter and accepts contest selection input from the voter.

eligible voters

The universe of all votersvoters who, if they castcast a ballot,ballot, would have the legal right 

to have eligible contestscontests on that ballot tabulated.tabulated. This would include those 

who do not appear in the list of eligible voters because they live in a same-day registration or 

no registration state and did not or could not register ahead of time.

encryption

Cryptographic process of transforming data (called "plaintext") into a form (called "ciphertext") 

that conceals the data's original meaning to prevent it from being known or used. Encryption 

provides confidentiality protection.
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endorsement

Approval by a political party,political party, for example, as the candidatecandidate that the 

party fields in a particular contestcontest or as the candidate that should receive straight-party 

votes.votes. In some states, more than one party may endorse a candidate or contest 

option.contest option.

enhanced visual format

A display format that is an alternative visual display format supporting personal screen display 

choices such as text size, color contrast, and preferred language.

error correction code

Coding system that allows data being read or transmitted to be checked for errors and, when 

detected, corrects those errors.

error rate

Ratio of the number of errors that occur to the volume of data processed.

escalation of privilege

An attack on a system where the attacker is using some means to bypass security controls in 

order to attain a higher privilege level on the target system.

exhausted ballot

Refers to processing a ranked choice voting contest on a cast ballot, when that ballot becomes 

inactive and cannot be advanced in the tabulation for a contest because there are no further valid 

rankings on the ballot for continuing contest options.

expected mark

Mark that falls wholly or partially inside a contest option position.

eXtensible markup language

A text-based language used to organize and present information on the World Wide Web.

Synonyms: XML

extraneous mark

A mark on a paper ballot that appears to be unrelated to the act of indicating a voter's 

selection. Examples include: a mark made unintentionally by a voter that is obviously not 

related to making a selection; a hesitation mark, a dot within or outside of the contest option 

position made by resting a pen or pencil on the ballot; written notes or identifying information 

not related to indication of the voter's selection; or printing defects.

Synonyms: inadvertent mark, random mark, stray mark
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F:

failure

Looking at voting system reliability, a failure is an event that results in: 

• loss of one or more functions, 

• degradation of performance resulting in a device that is unable to perform its intended 

function for longer than 10 seconds,,

• automatic reset, restart, or reboot of the voting device, operating system or application 

software, requiring an unanticipated intervention by a person in the role of election 

worker or technician before normal operation can continue, or 

• error messages or audit log entries indicating that a failure has occurred.

failure rate

Ratio of the number of failures that occur to the volume of data processed.

fault

Flaw in design or implementation that may result in the qualities or behavior of the voting 

system deviating from the qualities or behavior that are anticipated, including those specified 

in the VVSG or in manufacturer-provided documentation.

fault-tolerant

A system that continues to operate after the failure of a computer or network component.

Federal Information Processing Standards

Standards for federal computer systems developed by NIST. These standardsstandards are 

developed when there are no existing industry standards to address federal requirements for 

system interoperability,interoperability, portability of data and software, and computer 

security.

Synonyms: FIPS

finding

(n) Result of a formal evaluation by a test lab or accredited expert.

Synonyms: verdict
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firewall

A gateway system designed to prevent unauthorized access to a private network or intranet 

that is connected to the internet. A firewall can be implemented in either hardware or 

software, or a combination of both.

firmware

A specific class of software encoded directly into a hardware device that controls its defined 

functions and provides the low-level control for the computer'sdevice’s specific hardware (such 

as the firmware that initially boots an operating system).
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functional configuration audit

Exhaustive verification of every system function and combination of functions cited in the 

manufacturer's documentation. The FCA verifies the accuracy and completeness of the system's 

Voter Manual, Operations Procedures, Maintenance Procedures, and Diagnostic Testing 

Procedures.

Synonyms: FCA

functional test

Test performed to verify or validate the accomplishment of one or more functions.
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G:

general election

Election in which all eligible voters, regardless of party affiliation, are permitted to select 

candidates to fill public office and/or vote on ballot measures.

geographical information system

A system designed to capture, store, manipulate, analyze, manage, and present all types of spatial 

or geographical data. GIS systems are used to validate voting district boundaries and may be 

integrated with the voter registration system.

Synonyms: GIS

geopolitical unit

Describes units of geopolitical geography so that they can be associated with contests, offices, 

ballot styles, and election results.

Synonyms: GpUnit

graceful recovery

Termination of a process that allows the operating system or parent process to regain normal 

control. Does not crash the machine or result in a general protection default (GPF) or blue 

screen. The user is not required to close the application and can continue to use the other 

functionality.
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H:

hardware

The physical, tangible, mechanical, or electromechanical components of a system.

Help America Vote Act

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.

Synonyms: HAVA
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I:

implementation statement

Statement by a manufacturer indicating the capabilities, features, and optional functions as 

well as extensions that have been implemented.

Synonyms: implementation conformance statement

in-person voting

Voting that occurs in an official location under the supervision of election workers.

independently

Without assistance from an election worker or other person.

indirect selectionvoter associations 

The mechanism by which a selection for a specific contest option automatically selects other 

linked contest options. An example is a straight party selection that causes indirect selections for 

all contest options of the identified party.A unique identifier used to associate a voter with their 

ballot selections. Indirect associations do not include PII.

information security

Protecting information and information systems from unauthorized access, use, disclosure, 

disruption, modification, or destruction in order to provide integrity, confidentiality, and 

availability.

Synonyms: IS

inspection

Examination of a product design, product, process, or installation and determination of its 

conformity with specific requirements.

interaction mode

A specific combination of display format and Control or navigation optionsoption that 

enableenables voters to perceiveoperate and interact with the voting system., used in 

conjunction with a display format.
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interoperability

The extent to which systems from different manufacturers and devices with different system 

configurations can communicate with each other.

intrusion detection system

A hardware or software application that detects and reports a suspected security breach, policy 

violation, or other compromise that may adversely affect the network. Synonyms: IDS
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Synonyms: IDS
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K:

key management

Activities involving handling of cryptographic keys and other related security parameters (such 

as passwords) during the entire life cycle of the keys, including their generation, storage, 

establishment, entry and output, zeroization, and revocation.
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L:

life cycle

Systems engineering concept that identifies the phases that a system passes through, from 

concept to retirement. There are different concerns and activities associated with each phase 

of the life cycle.

locality

Generic term used in election contexts to signify a town, village or city contained within an 

election jurisdiction, such as a county.

logic and accuracy testing

Equipment and system readiness teststests whose purpose is to detect malfunctioning 

devicesdevices and improper election-specific setup before the equipment or systems are used

in an election. Election officialselection. Election officials conduct L&A tests prior to the start 

of an election as part of the process of setting up the system and the devices for an election 

according to jurisdiction practices and conforming to any state laws.

Synonyms: L&A, LAT

logic defect

Fault in software, firmware, or hardwired logic.

logical correctness

Condition signifying that, for a given input, a computer program will satisfy the program 

specification and produce the required output.

low/nolimited dexterity mode

An interaction mode with accessibility features for voters with no use of one or both hands or 

low dexterity. This mode includes the tactile mode and the non-manual mode.
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M:

machine-readable mark

Mark in a contest selection position of a paper ballot that meets requirements for detection by 

a scanner.

machine-unreadable mark

Mark in a contest selection position of a paper ballot that cannot be detected as readable or 

marginal by a scanner, and may require human adjudication.

majority voting

A vote variation which requires the winning candidate to receive more than half of the votes

cast. If no candidate wins an outright majority, a runoff election may be held between the top 

two vote-getters.

malware

Software or firmware intended to perform an unauthorized process that will have adverse 

impact on the confidentiality, integrity, or availability of a system. For example, a virus, worm, 

Trojan horse, or other code-based entity that infects a host. Spyware and some forms of 

adware are also examples of malware.

Synonyms: malicious code

manually-marked paper ballot

Paper ballot marked by a voter using a writing utensil. The paper ballot is the independent voter 

verifiable record.

Synonyms: MMPB

manufacturer

Entity with ownership and control over a voting system submitted for testing.

marginally machine-readable mark

An intentional mark in a contest selection position of a paper ballot that does not meet the 

requirements for a reliably detectable selection, and therefore requires human adjudication. A 

marginal mark may be determined to indicate a selection, depending on state law.

Synonyms: marginal markvendor
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marked ballot

Ballot that contains all of a voter'sthe selections. made by a voter.

military voter

A member of a uniformed service in active service, including army, navy, air 

force, marine corps, coast guard and merchant marine, and their spouses and 

dependents.message authentication code

A data authenticator generated from the message, usually through cryptographic techniques, 

that is designed to reveal both accidental errors and intentional modifications of the data. In 

general, a cryptographic key is also required as an input.

Synonyms: MAC

Misfeed rate

Ratio of the misfeed total to the total ballotballot volume.

module

A structural unit of a software program that serves a specific function for the program or that 

serves to make the program modular in structure for the purposes of easier understanding and 

maintenance.

multi-factor authentication

Authentication mechanism requiring two or more of the following: 

• something you know (such as a password), 

• something you have (such as a token), 

• something you are (for example, biometric authentication).

multi-seat contest

Contest in which multiple candidates are elected to fill a specified number of seats.

municipality

Term as used in election contexts to signify a jurisdiction such as city, town, or village that has 

some form of local government for which elections are generally conducted.
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N:

N-of-M voting

Vote variation in which the voter is entitled to allocate a fixed number of votes (N) over a list of 

M contest options or write-in options, with the constraint that at most 1 vote may be allocated 

to a given contest option. This usually occurs when multiple seats are concurrently being filled 

in a governing body such as a city council or school board where candidates contend for atlarge seats. The voter is not obliged to allocate all N votes. 1-of-M is N-of-M voting where N = 1.

national certification test report

Report of the results of independent testing of a voting system by a Voting System Test Lab

(VSTL) delivered to the EAC with a recommendation about granting a certification number.

National Institute of Standards and Technology

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.

Synonyms: NIST

non-manual mode

An interaction mode that use assistive technology, for example, a sip-and-puff switch, to allow 

voters with no use of their hands to operate the voting system. 

non-party-specific contest

Contest where eligibility to vote in that contest is independent of political party affiliation.

non-user-serviceable failure

Functional failure that requires the manufacturer or highly trained personnel to repair.

nonpartisan office

Elected office for which candidates appear on the ballot without political party designation.

nonpartisan primary

Primary election held to narrow the field of candidates in non-party-specific contests.

nonvolatile memory

Memory in which information can be stored indefinitely with no external power applied.
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notice of clarification

Document providing further guidance and explanation on the requirements and procedures of the 

EAC's Voting System Certification or Voting System Testing Lab (VSTL) programs. NOCs 

may be issued in response to a clarification request from a Voting System Test Lab or an EAC 

registered manufacturer. EAC may also issue NOCs when it determines general clarifications 

are necessary.
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O:

observational test

Operational test conducted on voting devices during an election by real voters to establish 

confidence that the voter verifiable paper record is produced correctly when assistive 

technology is used. Devices subjected to observational testing are used for normal collection of 

votes; the votes collected are included in the election tally.

office

A position established by law with certain associated rights and duties.

open primary

Partisan primaryPartisan primary election in which the voter may choose a political party at 

the time of voting and vote in party-specific contests associated with that party, along with 

non-party-specific contests presented at the same election. Some states require voters to 

publicly declare their choice of party at the polling place, after which the election worker

provides or activates the appropriate ballot. Other states allow the voters to make their choice 

of party within the privacy of the voting booth.

election in which the voter may choose a political party at the time of voting and vote in 

party-specific contests associated with that party, along with non-party-specific contests

presented at the same election. Some states require voters to publicly declare their choice of 

party at the polling place, after which the election worker provides or activates the appropriate 

ballot. Other states allow the voters to make their choice of party within the privacy of the voting 

booth.

Synonyms: pick-your-party primary

open source

Computer software with its source code (human readable code) made available with a license 

in which the copyright holder provides the rights to study, change, and distribute the software 

to anyone and for any purpose. Open source software may: 

• be developed in a collaborative public manner; 

• be reviewed by multiple professional and amateur programmers; 

• require a fee and be licensed like other software; or

• be fully open source or may have only a portion of the software open source.

optical scan

Voting system that tabulates votes marked in contest option positions or contained with a 

barcode on the surface of a paper ballot.
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overseas voter

A U.S. citizen who is living outside of the United States and is eligible to vote in their last place 

of residence in the United States.

overvote

Occurs when the number of selections made by a voter in a contest is more than the maximum 

number allowed.

Synonyms: over-vote
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P:

paper ballot

A piece of paper, or multiple sheets of paper, on which all contest options of a given ballot 

style are printed.

paper ballot sheet

A single piece of paper that forms part of a paper ballot. Paper ballots may contain multiple 

sheets.

paper ballot side

The face of a paper ballot sheet. A paper ballot may have two sides.

paper-based voting system 

A voting system that records votes, counts votes, and/or produces a report of the vote count 

from votes cast on paper cards or sheets

partisan office

Elected office for which candidates may appear on the ballot with a political party designation.

partisan primary

Primary election held to narrow the field of candidates in party-specific contests.

party-specific contest

Contest where eligibility to vote in that contest is restricted based on political party affiliation 

or lack of any affiliation. The affiliation might be the registered affiliation of the voter or it 

might be an affiliation declared at the time of voting.

pattern voting

Selecting contest options across multiple contests in a predetermined pattern intending to signal 

one's identity to someone else. The possibility of pattern voting can be an issue for publishing 

Cast Vote Records (CVR) because it may compromise voter privacy if there are enough 

selections in each published CVR to make it likely a selection pattern might be unique.
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penetration testing

An evaluation method that enables researchers to search for vulnerabilities in a system.

Synonyms: Pen Testing

personal assistive device

Assistive technology belonging to voters rather than any supplied with the voting system.

personalpersonally identifiable information

Any information about an individual including: 

• information that can be used to distinguish or trace an individual's identity, such as 

name, social security number, date and place of birth, mother's maiden name, or 

biometric records; and 

• any other information that can be linked to an individual, such as medical, educational, 

financial, and employment information.

Synonyms: PII, voter identifying information, VII

physical configuration audit

Inspection by a voting system test lab (VSTL) that compares the voting system components

submitted for certification testing to the manufacturer's technical documentation and confirms 

that the documentation submitted meets the national certification requirements. Includes 

witnessing the executable system being built to ensure that the certified release is built from the 

tested components.

Synonyms: PCA

plurality voting

A vote variation in which the candidate with the most votes wins, without necessarily receiving 

a majority of votes.

political party

An association of individuals under whose name a candidate may appear on a ballot.

political subdivision

Any unit of government, such as counties, cities, school districts, and water and conservation 

districts having authority to hold elections for public offices or on ballot measures.

polling location

Physical address of a polling place.
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polling place

Location at which voters may cast in-person ballots under the supervision of election workers

during one or more specific time periods.

Synonyms: poll, polling station

post-election tabulation audit

A post-election audit that involves hand-counting a sample of votes on paper records, then 

comparing those counts to the corresponding vote totals originally reported: 

• as a check on the accuracy of election results, and 

• to detect discrepancies using accurate hand counts of the paper records as the 

benchmark.

precinct

Election administration division corresponding to a geographic area that is the basis for 

determining which contests the voters legally residing in that area are eligible to vote on.

Synonyms: polling district, tabulation district, ward

precinct count

Counting ballots in the same precinct in which those ballots have been cast.

precinct split

A subdivision of a precinct which arises when a precinct is split by two or more election 

districts that may require different ballot styles.

Synonyms: split, split precinct, sub-precinct

presentable ballot style

Ballot style that includes all presentational details required to generate a ballot. This may 

include language, ordering of contests and candidates, and structural content such as headers.

presidential primary election

Primary election in which voters choose the delegates to the presidential nominating 

conventions allotted to their states by the national party committees.

primary election

Election held to determine which candidates qualify to appear as contest options in 

subsequent elections.
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privacy (for voters)

A property of a voting systemvoting system that is designed and deployed to enable 

votersvoters to obtain a ballot,ballot, and mark, verify, and castcast it without revealing their 

ballot selections or selections of language, display and interaction modesinteraction modes to 

anyone else. This does not preclude the ability of a voter to request assistance under state law.

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 

confirm it can perform its intended task.

programmed device

Electronic device that includes software. Most electronic voting devices include application 

logic (software) and are, therefore, programmed devices.

proportional voting

A vote variation used in multi-seat contests where the votes allowed in the contest are 

distributed to the selected candidates proportionally depending on the number of selections. 

This may result in candidates receiving fractional votes.

provisional ballot

A failsafe ballotballot provided to a votervoter whose eligibility for a regular ballot cannot be 

immediately determined. The ballot may be countedcounted or further processed depending 

on state law.

Synonyms: affidavit ballot

public key

Public part of an asymmetric key pair that is typically used to verify digital signatures or 

encrypt data.

public key infrastructure

A set of roles, policies, and procedures used to establish greater trust in the authenticity of a 

digital certificate and for use in creating, managing, distributing, using, storing, and revoking 

digital certificates.

Synonyms: PKI
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public test

An abbreviated logic and accuracy test of voting equipment, pre-announced in public media and 

open to public attendance, usually in conformance with specific election calendar timing.
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Q:

quick response code

A 2D, trademarked barcode. An optical, 2-D machine-readable representation of data that 

conformconforms to accepted standards.

Synonyms: QR Code
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R:

range voting

A vote variation for single-seat contests, in which voters give each candidate a score, the 

scores are added (or averaged), and the candidate with the highest total is elected.

Synonyms: score voting

ranked choice voting

A vote variation: 

• which allows each voter to rank contest options in order of the voter's preference, 

• in which votes are counted in rounds using a series of runoff tabulations to defeat 

contest options with the fewest votes, and, 

• which elects a winner with a majority of final round votes in a single-winner contest and 

provides proportional representation in multi-winner contests.

Synonyms: IRV, RCV, instant run-off voting, ranked order

read ballot

Cast ballot that has been successfully accepted and initially processed, e.g., scanned by an 

optical scanner.

Synonyms: scanned ballot

recall issue with options

Vote variation that allows voters to remove elected representatives from office before their 

terms of office expire. 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.

recallable ballot

Recorded ballot that can be individually retrieved and included or excluded from further 

processing.

recertification

Re-examination, and possibly retesting, of a voting system that was modified after being 

previously certified. The object of recertification is to determine if the system as modified still 

conforms to the requirements.
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record

(n) Preserved evidence of activities performed or results achieved (for example, forms, reports, 

test results).

(v) To create a record.

recorded ballot

A ballot for which there is an associated cast vote record.

recount

Repeat tabulation of votes cast in an election, whether manually or electronically, that is used 

to determine the accuracy of an initial count.

report

Self-contained, time-stamped, archival record, such as a printout or analogous electronic file 

that is produced at a specific time and subsequently protected from modification.

report total error rate

Ratio of the report total error to the report total volume.

reporting unit

Geographical area in which reported totals or counts are reported (for example, an election 

jurisdiction, precinct, or election district).

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.

resilience

The ability to recover gracefully from error conditions and unexpected circumstances. For 

example, manually marked paper preserves evidence of exceptions that can advise both 

adjudication and audit to achieve better interpretation of original voter intent.

residual vote

Vote that could not be allocated to a specific contest due to an undervote or overvote.

reviewed ballot

Ballot that has been reviewed (either electronically or by the voter) before it is cast, to 

determine what contest selections it contains.
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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.

risk-limiting tabulation audit

Post-election tabulation audit procedure for checking a sample of ballots (or voter verifiable

records) that is guaranteed to have a large, pre-specified chance of correcting the reported

outcome if the reported outcome is wrong (that is, if a full hand count would reveal an 

outcome different from the reported outcome).

Synonyms: RLA

runoff election

Election to select a winner following a primary election 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 a runoff election.
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S:

seat

An elected office position that a single officeholder may occupy for a term of office.

second chance voting

Feature of a voter-facing scanner that reviews the ballot for possible marking mistakes, informs 

the voter, and presents an opportunity to cast as-is or return the ballot.

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 (that is, safeguards or countermeasures) 

prescribed for an information system to protect the confidentiality, integrity, and availability of 

the system and its information.

security strength

A metric associated with the amount of work (that is, the number of operations) that is 

required to break a cryptographic algorithm or system.

software independence

Quality of a voting system or voting device where a previously undetected change or fault in 

software cannot cause an undetectable change or error in election outcome. In practice, voting 

systems are generally viewed as possessing the quality of software independence when they 

allow for a voter-verifiable paper record of voters’ contest selections to be created and 

compared against vote totals or against an electronic cast vote record used in determining vote 

totals.

Synonyms: SI

source code

Human readable computer instructions that, when compiled or interpreted, define the 

functionality of a programmed device. Source code can be written by humans or by computers.
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spear phishing

A targeted attack by hackers, using bogus emails, that attempts to get the victim to provide login 

information or personal information to the hackers. Spear Phishing attempts may appear to 

originate from legitimate, known sources, such as organizational IT or known vendors.

special election

Primary election or general election that is not regularly scheduled. A special election may be 

combined with a scheduled election.

spoil

(A ballot) To mark or otherwise alter a ballot so it indicates in a human-readable manner that the 

ballot is not to be cast.

spoiled ballot

A ballot that has been issued to a voter but will not be cast, usually because it has been 

incorrectly marked or impaired in some way.

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.

straight-party override

Explicit votervoter selection that overrides or supplements the votevote selections made by a 

straight party votingstraight-party voting option. Straight-party overrides may be subject to 

state election rules forelection regulations regarding how they work or whether they are 

allowed.

straight-party voting

Mechanism that allows voters to cast a single vote to select all candidates on the ballot from a 

single political party.

street segment data

The portion of a street between two consecutive cross streets that can be assigned to a precinct.

support software

Software that aids in developing, maintaining, or using other software, for example, compilers, 

loaders and other utilities.
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symmetricswitch

An assistive technology primarily used by people with motor impairments to access and control 

computers and other devices.

secret key cryptography

Encryption system that uses the same key for encryption and decryption. This key must be kept 

secret.

Synonyms: secret key cryptography

system extent

Administrative unit that is the entire scope within which the voting system is used (for 

example, a county). The system extent corresponds to the top-level reporting context for which 

the system generates reports.
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T:

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.

tabulate

Process of totaling votes.

Synonyms: count

tabulation report

A report containing the counts associated with ballots tabulated for a given election 

district.that have been tabulated.

tactile controls

Tactile controls areA tactile control is a physical control discernable or perceptible by touch 

using hands, feet, or other parts of the body. (Does not include touch screens.) Dual switches 

are a form of tactile controls that can be used by voters with minimal use of their hands.

tactile mode

An interaction mode that uses tactile controls to operate the voting system. 

tamper-evidence

A feature of a physical or digital artifact that provides evidence of unauthorized modification or 

access (e.g., tamper-evident seal).

technical data package

Manufacturer documentation relating to the voting system, which can include manuals, 

description of components, and details of architectural and engineering design.

Synonyms: TDP
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test

Procedure used to determine one or more characteristics of a given product, process, or service 

according to a specified procedure for conformity assessment. A test may be an operational 

test or a non-operating test (for example, an inspection).

test deck

A set of marked ballots with a predetermined outcome. Used for logic and accuracy testing of a 

voting system.

test method

Specified technical procedure for performing a test, procedures by which tests are derived, or a 

combination of these.

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.

test suite

Implementation of a set of operational tests for a particular object (such as a specific voting 

system) or class of objects (such as all voting systems that can interpret the language in which 

the test data are expressed).

third-party logic

Software, firmware, or hardwired logic that is neither application logic nor COTS. This includes, 

for example, general-purpose software developed by a third party that is either customized (for 

example, ported to a new platform, as is Windows Embedded Compact), not widely used, or 

source-code generated by a COTS package.

token

Something a user possesses and controls, typically a key or password, that is used to 

authenticate an identity.

Synonyms: authentication token, cryptographic token

touch mode

Interaction mode that uses a touch screen to operate the voting system. 
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touch screen voting machine

A vote-capture device that utilizes a computer screen to display the ballot and allows the voter

to indicate their selections by touching designated locations on the screen.

town

An urban area that has a name, defined boundaries, and local government, and that is generally 

larger than a village and smaller than a city. Term used in New England, New York, and 

Wisconsin to refer to the equivalent of the civil townshipcivil township in these states.

township

A widely used unit of local government in the United States, subordinate to a county, with 

some form of local government for which it generally conducts elections.

Synonyms: civil township
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U:

undervote

Occurs when the number of voter selections in a contest is less than the maximum number 

allowed for that contest or when no selection is made. The number of undervotes is equal to 

the number of votes lost, for example, if no selection is made in a vote for two contest the 

number of votes lost is two.

Synonyms: under-vote

Uniformed and Overseas Citizens Absentee Voting Act

Act of Congress in 1986 requiring that the states and territories allow certain groups of citizens 

to register and votevote absentee in electionselections for Federal offices.offices.

Synonyms: UOCAVA

UOCAVA voter

An overseas voteroverseas voter or an active-duty member of the U.S. military, either within or 

outside the United States, including any accompanying spouse and family members who are 

eligible to votevote in their last place of residence in the United States. The Uniformed and 

Overseas Citizens Absentee Voting ActThe Uniformed and Overseas Citizens Absentee 

Voting Act is commonly referred to as UOCAVA.

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 contest selections were recorded correctly. It also refers to the usability 

of the setup and operation of voting equipment in the polling place.

usability testing

Testing that 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.

user-serviceable failure

Functional failure that can be remedied by a troubleshooter or election official using only 

knowledge found in voting equipment user documentation.
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V:

valid vote

See contest option vote.

validation

Process of evaluating a system or component during or at the end of the development process 

to determine whether it satisfies specified requirements.

visual format

A display format in which contest options and other information areis displayed on screen or 

paper for perception using sight.

vote

Indication of support for a particular contest option.

vote center

A physical location where voters from multiple precincts may cast their ballots.

vote for N-of-M

A multi-seat contest in which voters are allowed to vote for a specified number ("N") of 

candidates.

vote variation

Voting style or feature, including but not limited to the following: approval voting,approval 

voting, Borda count, cumulative voting, n-of-m voting, plurality voting, proportional voting, 

range voting, ranked choice votingcumulative voting, N-of-M voting, plurality voting, 

proportional voting, range voting, and super majority voting.ranked choice voting.

vote-by-mail

Method of voting by which eligible voters are mailed ballots and information packets by the 

local election jurisdiction. Voters may be able to return their marked ballots by mail, bring 

them to an election office, or drop them off in secure drop boxes.

Synonyms: VBM, all-mail voting, mail voting, postal voting
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vote-capture device

An electronic voting device that is used directly by a voter to make selections on a ballot.

Component of a voting system that captures and/or counts voter selections from paper or 

electronic ballots. Vote-capture devices may or may not be directly voter-facing; voter-facing 

vote-capture devices include ballot marking devices and voter-facing scanners, while non-voter 

facing vote-capture devices include batch-fed scanners.

voter

Person permitted to cast a ballot.

voter intent

A cognitive construct, formed by the voter, that they attempt to express through actions taken 

to mark, verify, and cast the issued ballot.

voter intent standard

A standard for counting ballots that aims to ensure that ballots are counted in accordance with 

the goals of the voter, using written rules for both human processes and machine algorithms to 

ensure that all ballots marked in a similar way are counted in the same way.

voter verifiable

A voting system feature that provides the voter an opportunity to verify that their contest 

selections are being recorded correctly before the ballot is cast.

voter verified paper audit trailrecord

A paper document that the voter can review before officially casting their ballot.

Synonyms: VVPATVVPR

voter-facing scanner

An electronic voting device that: 

• accepts hand-marked or BMD-produced paper ballots one sheet at a time; 

• is usually used for in-person voting; 

• permits election workers to open and close the polls; 

• scans a ballot and rejects it if either unreadable or un-processable; 

• detects, interprets and validates contest selections; 

• notifies the voter of voting exceptions (such as undervotes or overvotes) or unreadable 

marks; 

• stores accepted ballots in a secure container; 
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• sorts or otherwise marks ballots or ballot images that need subsequent human review; 

and 

• tabulates and reports contest results after polls are closed. 

This unit was previously referred to as precinct count optical scanner or PCOS.

Synonyms: PCOS, precinct-count optical scanner

voting device

Device that is part of the voting system.

voting process

Entire array of procedures, people, resources, equipment, and locations associated with 

conducting elections.

voting session

A collection of activities including ballot issuance, voter interaction with the vote-capture 

device, voting, verification, and casting.

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.

voting system

Equipment (including hardware, firmware, and software), materials, and documentation used 

to: 

• define elections and ballot styles, 

• configure voting equipment, 

• identify and validate voting equipment configurations, 

• perform logic and accuracy tests, 

• activate ballots for voters, 

• capture votes cast by voters,

• count votes, 

• label ballots needing special treatment, 

• generate reports, 

• export election data including election results, 

• archive election data, and 

• produce records in support of audits.
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voting system software

The executable code and associated configuration files needed for the proper operation of the 

voting system.

voting system test lab

Privately owned testing laboratories that test voting systemstest voting systems (and other 

election systems)election systems) for conformanceconformance to the Voluntary Voting 

System Guidelines (VVSG) or to other requirements, including individual state requirements. 

VSTLs are periodically reviewed for conformance to National Voluntary Laboratory 

Accreditation Program (NVLAP) administered by the National Institute for Standards and 

Technology (NIST).

Synonyms: VSTL
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W:

white box testing

Testing based on an analysis of the internal structure of the component or system.

Wi-Fi

A wireless networking technology that uses radio waves to provide high-speed Internet network 

connections.

Wide area network

A network that connects computers across metropolitan, regional, and national boundaries. The 

internet is an example of a WAN.

Synonyms: WAN

wireless

Connectivity using electro-magnetic waves instead of wire connections.

write-in option

A type of contest option that allows a voter to specify a candidate, usually not already listed as 

a contest option. Depending on election jurisdiction rules, in some cases only previously 

approved names will be considered as valid write-in contest selections.
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Z:

zero report

A tabulation report produced at the opening of polls to check that there are no stored votes.
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Appendix B

Requirements Listing

Appendix B: Requirements Listing

The VVSG 2.0 - Principles and Guidelines

Principle 1: High Quality Design

Principle 2: High Quality Implementation

Principle 3: Transparent

Principle 4: Interoperable

Principle 5: Equivalent and Consistent Voter 

Access

Principle 6: Voter Privacy

Principle 7: Marked, Verified, and Cast as 

Intended

Principle 8: Robust, Safe, Usable, and Accessible

Principle 9: Auditable

Principle 10: Ballot Secrecy

Principle 11: Access Control

Principle 12: Physical Security

Principle 13: Data Protection

Principle 14: System Integrity

Principle 15: Detection and Monitoring
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Principle 1: High Quality Design

The voting system is designed to accurately, completely, and robustly carry out election 

processes.

1.1 – The voting system is designed using commonly-accepted election process 

specifications.

1.1.1 – Election definition

1.1.1-A – Election definition

1.1.1-B – Election definition details

1.1.1-C – Define political geographies

1.1.1-D – Serve multiple or split precincts and election 

districts

1.1.1-E – IdentifiersC – Multiple identifiers

1.1.1-FD – Definition of parties and contests

1.1.1-GE – Voting methodsvariations

1.1.1-H – Election definition accuracy

1.1.1-I – Voting options accuracy

1.1.1-JF – Confirm recording of election definition

1.1.1-KG – Election definition distribution

1.1.1-L – Define ballot styles

1.1.1-M – Auto-format

1.1.1-N – Include contests

1.1.1-O – Exclude contests

1.1.1-P – Nonpartisan formatting

1.1.1-QH – Jurisdiction-dependent content

1.1.1-RI – Include contests

1.1.1-J – Exclude contests

1.1.1-K – Primary elections, associate contests with 

parties

1.1.1-SL – Ballot rotation, Election definition

1.1.1-TM – Ballot configuration in combined or split 

precincts

1.1.1-U – No advertising

1.1.1-V – Ballot style distribution

1.1.1-WN – Ballot style identification

1.1.1-X – Retaining, modifying, reusing 

definitions

1.1.1-Y – Ballot style protection

1.1.1-Z – Data inputs and outputs

1.1.2 – Equipment setupPre-election testing

1.1.2-A – Equipment setup

1.1.2-B – Built-in self-test and diagnostics

1.1.2-C – Verify proper preparationB –

Installation of ballot styles

1.1.2-D – Verify proper installation of ballot 

styles

1.1.2-E – Verify compatibility between software and 

ballot styles

1.1.2-F –C – Use of test ballots

1.1.2-G – TestD – Testing all ballot positions

1.1.2-H – Test Cast Vote RecordsE – Testing cast vote 

record creation

1.1.2-I – TestF – Testing codes and imagesimage 

creation

1.1.2-JG – Testing equipment calibration

1.1.2-K – Ballot marker readiness

1.1.2-L – L&A testing,H – No side-effects from preelection testing

1.1.2-M –I – Equipment status and readiness reports

1.1.2-N – Pre-electionJ – Ballot style readiness reports

1.1.2-O –K – Precinct-based voting devices readiness 

reports for each polling place

1.1.2-P –L – All vote-capture devices readiness reports

, precinct tabulation

1.1.2-Q – Readiness reports, central tabulation

1.1.2-R – Readiness reports, public network test 

ballots

1.1.3 – Opening the polls

1.1.3-A – Opening the polls

1.1.3-B – Verify L&A performed

1.1.3-C – Prevent opening the polls

1.1.3-D – Non-zero totals

1.1.3-E – Scanners and ballot marking devices -

verify activation

1.1.3-F – Scanners and ballot marking devices -

enter voting mode

1.1.4 - Ballot ActivationCasting

1.1.4-A – Ballot activationVoting and casting the ballot

1.1.4-B – One cast ballot per session

1.1.4-C – Contemporaneous record

1.1.4-D – Control ballot configuration

1.1.5 -4-C – Precinct splits, Casting

1.1.5-A – Voting methods when casting

1.1.5-B – N-of-M voting

1.1.5-C – Yes/no measures and multiple-choice 

measures

1.1.4-D – Ballot rotation, Casting

1.1.4-E – Partisan closed primary ballot

1.1.4-F – Partisan open primary ballot

1.1.5-D4-G – Indicate party affiliations and 

endorsements

1.1.5-E – Closed primaries

1.1.5-F – Open primaries

1.1.5-G4-H – Write-insin contest options

1.1.5-H4-I – Write-in reconciliation

1.1.5-I – Ballot rotation for contest options

1.1.51.1.4-J – N-of-M contest, Casting

1.1.4-K – Straight-party voting, Casting

1.1.5-K – Cross-party endorsement

1.1.54-L – Precinct splits

1.1.5-M – Cumulative voting contest, Casting

1.1.5-N4-M – Ranked choice voting contest, Casting
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1.1.5-O – Recallable ballots

1.1.5-P – Review-required ballots

1.1.61.1.4-N – Party preference contest

1.1.4-O – Top-2 primary contest (blanket primary 

contest)

1.1.4-P – Presidential delegate contest, Casting

1.1.4-Q – Proportional voting contest (equal-and-even 

cumulative voting contest), Casting

1.1.4-R – Group voting contest, Casting

1.1.4-S – Top-2 IRV contest (supplementary or 

contingent vote contest)

1.1.5 – Recording voter choices

1.1.65-A – Casting and recording

1.1.65-B – Secure ballot boxes

1.1.6-C – Prevent counter overflow

1.1.6-D – Ballot orientation

1.1.6-E – Records consistent with feedback to 

voter

1.1.6-F5-C – Record contest selection information

1.1.6-G5-D – Record write-in information

1.1.6-H5-E – Record election and contest information

1.1.6-I5-F – Record ballot selection override information

1.1.6-J – Record detected mark information

1.1.6-K5-G – Record audit information

1.1.75-H – Store and link corresponding image

1.1.6 – Ballot handling for paper ballot 

scannersvote-capture devices

1.1.76-A – Ballot handling functions for scanners

1.1.7-B – Detect and prevent ballot style mismatches

1.1.7-C6-B – Detect and reject ballots that are oriented 

incorrectly

1.1.7-D6-C – Ballot separation when batch feeding

1.1.7-E6-D – Overvotes, undervotes, blank ballots

1.1.7-F6-E – Write-ins, Ballot handling for vote-capture 

devices

1.1.7-G6-F – Ability to clear misfeedmis-fed ballots

1.1.7-H6-G – Scan to manufacturer specifications

1.1.7-I – Ignore unmarked contest option 

positions

1.1.7-J – Accurately detect perfect marks

1.1.7-K6-H – Accurately detect imperfect marks

1.1.7-L – Ignore extraneous marks outside 

contest option position

1.1.7-M – 1.1.6-I – Ignore extraneous marks inside 

voting targets

1.1.7-N – Ignore hesitation marks

1.1.7-O6-J – Marginal marks, nowithout bias

1.1.7-P6-K – Repeatability

1.1.8 – Closing the Polls

1.1.7 – Exiting or suspending voting

1.1.87-A – Closing the pollsExiting or suspending 

election mode

1.1.87-B – No voting when polls are closedvoting is 

stopped

1.1.87-C – Poll closingVoting stop integrity check

1.1.87-D – Report on poll closingvoting stop process

1.1.87-E – Prevent reopening pollsre-entering election 

mode

1.1.98 – Tabulation

1.1.98-A – Voting methods when 

tabulatingTabulation

1.1.98-B – N-of-M voting

1.1.9-C – Yes/no measure and multiple-choice 

measure

1.1.9-D – Recallable ballots

1.1.9-E – Accept or reject recallable ballots 

individually

1.1.9-F – Accept or reject recallable ballots by 

category

1.1.9-G –Partisan primary elections

1.1.9-H8-B.1 – Tabulation of a closed primary ballot

1.1.8-B.2 – Tabulation of an open primary ballot

1.1.8-B.3 – Open primary ballot with party preference 

contest

1.1.8-C – Write-ins, Tabulation

1.1.9-I – Support write-in reconciliation

1.1.9-J8-D – Ballot rotation, Tabulation

1.1.9-K8-E – Straight-party voting, Tabulation

1.1.9-L – Tabulating1.1.8-F – Cross-party 

endorsement with straight party votes

1.1.9-M – Cross-party endorsementvoting

1.1.9-N8-G – Precinct splits, Tabulation

1.1.9-O8-H – N-of-M contest, Tabulation

1.1.8-I – Cumulative voting contest, Tabulation

1.1.9-P8-J – Ranked choice voting contest, Tabulation

1.1.108-K – Group voting contest, Tabulation

1.1.8-L – Presidential delegate contest, Tabulation

1.1.8-M – Recall contest pair

1.1.8-N – Proportional voting contest (equal-and-even 

cumulative voting contest), Tabulation

1.1.9 – Reporting results

1.1.109-A – Post-election reports

1.1.109-B – Reporting device consolidation

1.1.10-C – Reporting is non-destructive

1.1.10-D – Ballot and vote counts

1.1.10-E – Report all votes cast

1.1.10-F – Account for all cast ballots and all 

valid votes

1.1.10-G Discrepancies detectable

1.1.10-H – Reporting combined precincts

1.1.10-I – Precinct reporting devices, no tallies 

before polls close

1.1.10-J – Report categories of cast ballots

1.1.10-K9-C – Report read ballots by partycategories 

of votes

1.1.10-L9-D – Reporting combined or split precincts

1.1.9-E – Report counted ballots by contest

1.1.10-M9-F – Report votes for each contest option

1.1.10-N9-G – Report overvotes for each contest

1.1.10-O – Reporting overvotes, ad hoc queries
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1.1.10-P9-H – Report undervotes for each contest

1.1.10-Q9-I – Ranked choice voting, report results

1.1.10-R – Include all categories of votes

1.1.10-S – Post-election reports in common data 

format

1.1.10-T – CVR export and import in common 

data format

1.1.9-J – Precinct reporting devices, reporting device 

consolidation

1.1.9-K – Precinct reporting devices, no tallies before 

polls close

1.1.9-L – Report read ballots by party

1.1.10-U9-M – Reports are time stamped

1.2 – The voting system is designed to function correctly under real-world operating 

conditions.

1.2-A – Assessment of accuracy

1.2-B – Minimum ballot positions 1.2-C – Ballot position distribution 1.2-D – Mark quality

1.2-EA – Assessment of reliabilityaccuracy

1.2-F – Continuous operation – typical environmental conditions

1.2-G – Continuous operation – varied 

environmental conditions

1.2-H – Failure Modes and Effect Analysis (FEMA)

1.2-I – No single point of failure 1.2-J – Protect against failure of input and storage devices

1.2-K1.2-B – Reliably detectable marks

1.2-L – Misfeed rate benchmark

1.2-C – Minimum ballot positions

1.2-MD – Handle maximum volume

1.2-E – Respond gracefully to stress of system 

limits

1.2-N – Handle realistic volume1.2-F – No single 

point of failure

1.2-G – Misfeed rate benchmark

1.2-H – Protect against failure of input and 

storage devices

1.2-I – FCC Part 15 Class A and B conformance

1.2-J – Power supply from energy service 

provider

1.2-K – Power port connection to the facility 

power supply

1.2-L – Leakage from grounding port

1.3 – Voting system design supports evaluation methods enabling testers to clearly 

distinguish systems that correctly implement specified properties from those that do not.

1.3-A – IdentifiabilityReporting of basic and 

compound system 

componentsmanufacturer-performed tests

1.3-B – Comprehensible processes that form 

system configurations 1.3-C – Observable configurations via plausible observation methods

1.3-D – Identifiable resolution limits for 

observation methods

1.3-E – DescriptionCoverage of observational 

noise and consequences for observational 

methods

1.3-F – Explicitly-stated performance criteria 1.3-G – Creation and execution of evaluation 

methods

 
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manufacturer-performed tests

Principle 2: High Quality Implementation

The voting system is implemented using high quality best practices.

2.1 - The voting system and its software are implemented using trustworthy materials and 

best practices in software development.

2.1 – Software quality

2.1-A – Acceptable programming languages

2.1-B – COTS language extensions are 

acceptable

2.1-C – Acceptable coding conventions

2.1-D – Records last at least 22 months

2.1.1 – Workmanship

2.1.1-A – General build quality

2.1.1-B – High quality productsDurability 

estimation

2.1.1-C – High quality parts

2.1.1-D – Suitability of COTS components 2.1.1-E – Durability

2.1.1-F – Durability of paper

2.1.1-D – Ensure compatibility of specified 

paper and ink

2.1.2 – Maintainability

2.1.2-A – Electronic device maintainability

2.1.2-B – System maintainability

2.1.2-C – Nameplate and labels

2.2 – The voting system is implemented using best practice user-centered design methods 

that consider a wide range of representative voters, including those with and without 

disabilities, and election workers.

2.2 – Design and implementation process

2.2-A – User-centered design process

2.3 - Voting system logic is clear, meaningful, and well-structured.

2.3 – Voting system logic

2.3-A – Block-structured exception handling

2.3-B – Legacy library units

2.3-C – Separation of code and data

2.3-D – Hard-coded passwords and keys

2.3.1 – Software flow

2.3.1-A – Unstructured control flow

2.3.1-B – Goto

2.3.1-C – Intentional exceptions

2.3.1-D – Unstructured exception handling

2.4 - Voting system structure is modular, scalable, and robust.

2.4 – Modularity

2.4-A – Modularity

2.4-B – Module testability

2.4-C – Module size and identification

2.4-D – Lookup tablesLarge data structures

in separate files

2.5 - The voting system supports system processes and data with integrity.

2.5 – System processes and data

2.5-A – Self-modifying code

2.5-B – Unsafe concurrency

2.5.1 – Code integrity

2.5.1-A – COTS compilers

2.5.1-B – Interpreted code, specific COTS 

interpreter

2.5.1-C – Prevent tampering with code

2.5.1-D – Prevent tampering with data

2.5.2 – Input/output errors

2.5.2-A – Monitoring and defending for I/O errors

2.5.2-B – Validate- Input validation and 

filter inputerror defense

2.5.2-C – Detect garbage input 2.5.2-D – Defend against garbage input

2.5.3 – Output protection

2.5.3-A – Escaping and encoding output

2.5.3-B – Sanitize output

2.5.3-C – Stored injection

2.5.4 – Error handling

2.5.4-A – Mandatory internal error checking

2.5.4-B – Array overflows

2.5.4-C – Buffer overflows
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2.5.4-D – CPU traps

2.5.4-E – Garbage input parameters

2.5.4-F – Numeric overflows

2.5.4-G – Uncontrolled format strings

2.5.4-H – Recommended internal error 

checking

2.5.4-I – Pointers

2.5.4-J – Memory mismanagement

2.5.4-K – Nullify freed pointers

2.5.4-L – React to errors detected

2.5.4-M – Election integrity monitoring

2.5.4-N – SQL injection

2.5.4-O – Parameterized queries

2.6 - The voting system handles errors robustly and gracefully recovers from failure.

2.6 – Graceful recovery

2.6-A – Surviving device failure

2.6-B – No compromising voting or audit 

data

2.6-C – Surviving component failure 2.6-D – Controlled recovery 2.6-E – Nested error conditions

2.6-F – Reset CPU error states

2.6-G – Coherent checkpoints 

2.7 - The voting system performs reliably in anticipated physical environments.

2.7 – Physical environments

2.7-A – Assessment of reliability

2.7-B – Continuous operation – typical 

environmental conditions

2.7-C – Continuous operation – varied 

environmental conditions

2.7-D – Ability to support maintenance and 

repair physical environment conditions –

non-operating

2.7-BE – Ability to support transport and 

storage physical environment conditions –

non-operating

2.7-CF – Ability to support storage 

temperatures in physical environment –

non-operating

2.7-D – Ability to support storage humidity levels in physical environment – non-operating

2.7-E – Ability to operate as intended at low and 

high temperatures - operating 2.7-F – Ability to operate as intended at specified humidity conditions - operating

2.7.1 – Ability to withstand 2.7-G –

Electrical disturbances

2.7.1-A – Electrical disturbances

2.7.1-B – FCC Part 15 Class A and B conformance

2.7.1-C-H – Power supply from energy service provider

2.7.1-D – Power port connection to the facility power supply

2.7.1-E – Leakage from grounding port

2.7.1-F – outages, sags, and swells

2.7.1-G-I – Withstand conducted electrical 

disturbances

2.7.1-H-J – Emissions from other connected 

equipment

2.7.1-I-K – Electrostatic discharge immunity 
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2.7.1-J – Radiated radio frequency emissions

 
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Principle 3: Transparent

The voting system and voting processes are designed to provide transparency.

3.1 – The documentation describing the voting system design, operation, accessibility 

features, security measures, and other aspects of the voting system can be read and 

understood.

3.1.1 – System overview documentation

3.1.1-A – System overview documentation

3.1.1-B – System overview, functional 

diagram

3.1.1-C – System description

3.1.1-D – Identify software and firmware by 

origin

3.1.1-E – Traceability of procured software

3.1.2 – System performance

documentation

3.1.2-A – System performance

documentation

3.1.2-B – Maximum tabulation rate

3.1.2-C – Reliably detectable marks

3.1.2-D – Processing capabilities

3.1.3 – System security documentation

3.1.3-A – System security documentation

3.1.3-B – Access control implementation

3.1.3-C – Physical security

3.1.3-D – Audit procedures

3.1.3-E – Risk Analysis

3.1.4 – Software installation

documentation

3.1.4-A – Software installation

documentation

3.1.4-B – Software information

3.1.4-C – Software location information

3.1.4-D – Election specific software 

identification

3.1.4-E – Installation software and 

hardware

3.1.4-F – Software installation 

procedureprocedures

3.1.4-G – Compiler installation prohibited

3.1.4-H – Baseline binary image creation

3.1.4-IH – Programmed device 

configuration replication

3.1.4-JI – Software installation record 

creation

3.1.4-KJ – Procurement of voting system 

software

3.1.4-LK – Open market procurement of 

COTS software

3.1.4-ML – Erasable storage media 

preparation

3.1.4-N – UnalterableM – Trusted storage 

media

3.1.5 – System operations documentation

3.1.5-A – Operations manualSystem 

operations documentation

3.1.5-B – Support training

3.1.5-C – Functions and modes

3.1.5-D – Roles

3.1.5-E – Conditional actions

3.1.5-F – References

3.1.5-F – References

3.1.5-G – Operational environment

3.1.5-H – Readiness testing

3.1.5-I – Features

3.1.5-J – Operating proceduresSupport

3.1.5-K – Support

3.1.5-L – Transportation and storage

3.1.6 – System maintenance

documentation

3.1.6-A – System maintenance 

manualdocumentation

3.1.6-B – General contents

3.1.6-C – Maintenance viewpoint

3.1.6-D – Equipment overview details

3.1.6-E – Maintenance procedures

3.1.6-F – Preventive maintenance 

procedures

3.1.6-G – Troubleshooting procedures

3.1.6-H – Troubleshooting procedure 

details

3.1.6-IH – Special equipment

3.1.6-JI – Parts and materials

3.1.6-KJ – Approved parts list

3.1.6-LK – Marking devices

3.1.6-ML – Approved manufacturers

3.1.6-M – Ballot stock specification

3.1.6-N – Ballot stock specification criteria

3.1.6-O – Ballot stock specification criteria

3.1.6-P – Printer paper specification

3.1.6-P – System maintenance, 

maintenance environment

3.1.6-Q – System maintenance, maintenance 

environment
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Requirements for VVSG 2.0 February 29, 202010, 2021

3.1.6-R – System maintenance, maintenance 

support and spares

3.1.7 – Training materialdocumentation

3.1.7-A – Training 

requirementsdocumentation

3.1.7-B – Personnel

3.1.7-C – User functions versus 

manufacturer functions

3.1.7-D – Training requirements

3.2 – The processes and transactions, both physical and digital, associated with the voting 

system are readily available for inspection.

3.2 – Setup inspection documentation

3.2-A – Setup inspection process

3.2-B – Minimum properties included in the 

setup inspection process

3.2-C – Setup inspection record generation

3.2-D – Installed software identification 

procedure

3.2-E – Software integrity verification 

procedure

3.2-F – Election information value

3.2-G – Maximum and minimum values of 

election information storage locations

3.2-H – Variable value inspection procedure

3.2-I – Backup power operational range

3.2-J – Backup power inspection procedure

3.2-K – Cabling connectivity inspection 

procedure

3.2-L – Communications operational status 

inspection procedure

3.2-M – Communications on/off status 

inspection procedure

3.2-N – Quantity of voting equipment

3.2-O – Consumable inspection procedure

3.2-P – Calibration of voting device 

components

3.2-Q – Checklist of properties to be 

inspected

3.3 – The public can understand and verify the operations of the voting system throughout 

the entirety of the election.

3.3 – Public documentation

3.3-A – System security, system event 

logging

3.3-B – Specification of common data 

format usage

3.3-C – Bar and other codes

3.3-D Encodings 3.3-E Audit

 
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Requirements for VVSG 2.0 February 29, 202010, 2021

– Ballot selection codes 

Principle 4: Interoperable

The voting system is designed to support interoperability in its interfaces to external systems, 

its interfaces to internal components, its data, and its peripherals.

4.1 – Voting system data that is imported, exported, or otherwise reported, is in an 

interoperable format.

4.1 – Interoperable formats

4.1-A – Data export and exchange format

4.1-B – Election programming data input 

and output

4.1-CB – Tabulator report data

4.1-DC – Exchange of cast vote records 

(CVRs)

4.1-ED – Exchange of voting device election 

event logs

4.1-FE – Voting device event code 

documentation

4.1-GF – Specification of common format 

usage

4.2 - Standard, publicly -available formats for other types of data not addressed by NIST 

CDF specifications are used.

4.2 – Standard formats

4.2-A – Standard formats

4.2-B – Public documented manufacturer 

formats

4.3 - Widely-used hardware interfaces and communications protocols are used.

4.3 – Interfaces and communication protocols

4.3-A – Standard device interfaces
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Requirements for VVSG 2.0 February 29, 202010, 2021

4.4 - Commercial-off-the-shelf (COTS) devices can be used if they meet all applicable VVSG 

requirements.

4.4 – COTS

4.4-A – COTS devices meet applicable requirements

Principle 5: Equivalent and Consistent

All voters can access and use the voting system regardless of their abilities.

5.1 – Voters have a consistent experience throughout the voting process within any method 

of voting.

5.1 – Consistent experience

5.1-A – Voting methods and interaction 

modes

5.1-B – Languages

5.1-C – Vote records

5.1-D – Accessibility features

5.1-E – Reading paper ballots

5.1-F – Accessibility documentation

5.2 – Voters receive equivalent information and options in all modes of voting.

5.2.5.2 – Equivalent information

5.2-A – No bias

5.2-B – Presenting content in all languages

5.2-C – Information in all modes

5.2-D – Audio synchronized

5.2-E – Sound cues

5.2-F – Preserving votes

Principle 6: Voter Privacy

Voters can mark, verify, and cast their ballot privately and independently.

6.1 - The voting process preserves the privacy of the voter’s interaction with the ballot, 

modes of voting, and vote selections.

6.1 – Privacy of interaction

6.1-A – Preserving privacy for voters

6.1-B – Warnings

6.1-C – Enabling or disabling output

6.1.D – Audio privacy

6.2 - Voters can mark, verify, and cast their ballot or other associated cast vote record 

without assistance from others.

6.2-A - Voter independence

Principle 7: Marked, Verified, and Cast as Intended

Ballots and vote selections are presented in a perceivable, operable, and understandable way 

and can be marked, verified, and cast by all voters.

7.1 – The default voting system settings present a ballot usable for the widest range of 

voters, and voters can adjust settings and preferences to meet their needs.

7.1 – Default settings

7.1-A – Reset to default settings

7.1-B – Reset by voter

7.1-C – Default contrast

7.1-D – Contrast options

7.1-E – Color conventions

7.1-F – Using color

7.1-G – Text size (electronic display)

7.1-H – Scaling and zooming (electronic 

display)

7.1-I – Text size (paper)

7.1-J – Sans-serif font

7.1-K – Audio settings

7.1-L – Speech frequencies

7.1-M – Audio comprehension

7.1-N – Tactile keys

7.1-O – Toggle keys

7.1-P – Identifying controls
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Requirements for VVSG 2.0 February 29, 202010, 2021

7.2 – Voters and election workers can use all controls accurately, and voters have direct 

control of all ballot changes.

7.2 – Controls

7.2-A – Display and interaction options

7.2-B – Navigation between contests

7.2-C – Voter control

7.2-D – Scrolling

7.2-E – TouchscreenTouch screen gestures

7.2-F – Voter speech

7.2.G – Voter control of audio

7.2-H – Accidental activation

7.2.-I – Touch area size

7.2-J – Paper ballot target areas

7.2-K – Key operability

7.2-L – Bodily contact

7.2-M – No repetitive activation

7.2-N – System response time

7.2-O – Inactivity alerts

7.2-P – Floor space

7.2-Q – Physical dimensions

7.2-R – Control labels visible

7.3 – Voters can understand all information as it is presented, including instructions, 

messages from the system, and error messages.

7.3 – Understandable information

7.3-A – System-related errors

7.3-B – No split contests

7.3-C – Contest information

7.3-D – Consistent relationship

7.3-E – Feedback

7.3-F – Correcting the ballot

7.3-G – Full ballot selections review

7.3-H – Overvotes

7.3-I – Undervotes

7.3-J – Notification of casting

7.3-K – Warnings, alerts, and instructions

7.3-L – Icon labels

7.3-M – Identifying languages

7.3-N – Instructions for voters

7.3-O – Instructions for election workers

7.3-P – Plain language

Principle 8: Robust, Safe, Usable, and Accessible

The voting system and voting processes provide a robust, safe, usable, and accessible 

experience.

8.1 – The voting system’s hardware, software, and accessories are robust and do not expose 

users to harmful conditions.

8.1 – Protect from harmful conditions

8.1-A – Electronic display screens

8.1-B – Flashing

8.1-C – Personal Assistive Technology (PAT)

8.1-D – Secondary ID and biometrics

8.1-E – Standard audio connectors

8.1-F – Discernable audio jacks

8.1-G – Telephone style handset

8.1-H – Sanitized headphones

8.1-I – Standard PAT jacks

8.1-J – Hearing aids

8.1-K – Eliminating hazards

8.2 – The voting system meets currently accepted federal standards for accessibility.

8.2-A – Federal standards for accessibility

8.3 – The voting system is evaluated for usability with a wide range of representative voters, 

including those with and without disabilities.

8.3-A – Usability tests with voters

8.4 – The voting system is evaluated for usability with election workers.

8.4-A – Usability tests with election workers
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Requirements for VVSG 2.0 February 29, 202010, 2021

Principle 9: Auditable

The voting system is auditable and enables evidence-based elections.

9.1 - An error or fault in the voting system software or hardware cannot cause an 

undetectable change in election results.

9.1.1 – Software independence

9.1.1-A – Software independent

9.1.1-B – Paper-based or cryptographic E2E 

system

9.1.1-C –Mechanism documentation

9.1.2 – Tamper-evidence

9.1.2-A – Tamper-evident records

9.1.2-B – Tamper-evident record creation

9.1.3 – Voter verification

9.1.3-A – Records for voter verification

9.1.3-B – Identification of errors

9.1.3-C – Ballot error correction

9.1.3-DC – Voter reported errors

9.1.4 – Auditable

9.1.4-A – Auditor verification

9.1.4-B – Auditable with compromised software, firmware, or hardware

9.1.4-C – Documented procedure

9.1.5 – Paper records

9.1.5-A – Paper record production

9.1.5-B – Paper record retention

9.1.5-C – Paper record intelligibility

9.1.5-D – Matching selections

9.1.5-E – Paper record transparency and 

interoperability

9.1.5-F – Unique identifier

9.1.5-G –Preserving software independence

9.1.6 – Cryptographic E2E 

Cryptographyverifiable

9.1.6-A – Cryptographic E2E transparency

9.1.6-B – Verified cryptographic protocol

9.1.6-C – Public availabilityB –

Independent evaluation of E2E 

cryptographic protocol implementation

9.1.6-DC – Cryptographic ballot selection 

verification by voter

9.1.6-ED – Methods for cryptographic ballot 

selection verification

9.1.6-FE – Ballot receipt

9.1.6-F – Disputes involving ballot receipts

9.1.6-G – Evidence export

9.1.6-H– Mandatory ballot availability

9.1.6-I – Verification of encoded votes 

documentation

9.1.6-J – Verifier reference implementation

9.1.6-K – Privacy preserving, universally 

verifiable ballot tabulation

9.1.7 – Audit support

9.1.7-A – Number of ballots to check

9.1.7-B – No fixed margin of error 9.1.7-C – Random number usage

9.2 - The voting system produces readily available records that provide the ability to check 

whether the election outcome is correct and, to the extent possible, identify the root cause 

of any irregularities.

9.2-A – Compliance audit procedures 9.2-B – General post-election audit procedures 9.2-C – Generating CVRs 9.2-D – Reporting intermediate results 9.2-E – Reporting unusual audit events 9.2-F – Reporting format

9.2-G – Ballot countAudit support documentation

9.3 - Voting system records are resilient in the presence of intentional forms of tampering 

and accidental errors.

9.3-A – Data protection requirements for audit records

9.4 - The voting system supports efficient audits.

9.4-A – Efficient compliance auditaudits

9.4-B – EfficientA – Risk-limiting audit

9.4-B – Random numbers supporting audit 

processes

9.4-C – Unique ballot identifiers

9.4-D – Multipage ballots
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Requirements for VVSG 2.0 February 29, 202010, 2021

Principle 10: Ballot Secrecy

The voting system protects the secrecy of voters’ ballot selections.

10.1 - Ballot secrecy is maintained throughout the voting process.

10.1-A – System use of voter information

10.2 - The voting system does not contain nor produce records, notifications, information 

about the voter, or other election artifacts that can be used to associate the voter’s identity 

with the voter’s intent, choices, or selections. 10.2.1 – Voter associations

10.2.1-A – Direct voter associations

10.2.1-B – Indirect voter associations

10.2.1-C – Use of indirect voter associations 10.2.1-D – Election worker selection of indirect 

associations

10.2.1-E – Isolated storage location

10.2.1-E – Removal of indirect voter associations

10.2.1-F – Confidentiality for ballots with indirect 

associationvoter associations

10.2.2 – Identification in vote records

10.2.2-A – Identifiers used for audits

10.2.2-B – No voter record order information

10.2.2-C – Identifying information in voter record 

file names 10.2.2-D – Non-memorable identifiers and 

associations

10.2.2-E – Aggregating and ordering

10.2.2-F – Random number generationE –

Randomly generated identifiers

10.2.3 – Access to cast vote records (CVR)

10.2.3-A – Least privilegeRestrict access to 

storerecords of voter intent

10.2.3-B – Limited access

10.2.3-C – Authorized access

10.2.3-D – Digital voter record access log

10.2.4 – Voter information in 

other devices and artifacts

10.2.4-A – Voting information in 

receipts

10.2.4 – Voter information in other devices and 

artifacts

10.2.4-A – Voting information in receipts

10.2.4-B – Ballot secrecy for receipts

10.2.4-C – Logging of ballot selections

10.2.4-DC – Activation device records

Principle 11: Access Control

The voting system authenticates administrators, users, devices, and services before granting 

access to sensitive functions.

11.1 - The voting system enables logging, monitoring, reviewing, and modifying of access 

privileges, accounts, activities, and authorizations.

11.1 – Access privileges

11.1-A – Logging activities and resource 

access

11.1-B – Voter information in log files

11.1-C – Preserving log integrity

11.1-D – On-demand access to logs

11.2 - The voting system limits the access of users, roles, and processes to the specific 

functions and data to which each entity holds authorized access.

11.2.1 – Authorized access

11.2.1-A – Ensuring authorized access

11.2.1-B – Modifying authorized user lists

11.2.1-C – Access control by voting stage

11.2.1-D – Access control configuration

11.2.1-E – Administrator modified 

permissions

11.2.1-F – Authorized assigning groups or 

roles

11.2.2 – Role-based access control

11.2.2-A – Role-based access control standard

11.2.2-B – Minimum groups or roles

11.2.2-C – Minimum group or role 

permissions

11.2.2-D – Applying permissions
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Requirements for VVSG 2.0 February 29, 202010, 2021

11.3 - The voting system supports strong, configurable authentication mechanisms to verify 

the identities of authorized users and includes multi-factor authentication mechanisms for 

critical operations.

11.3.1 – Access control 

mechanismmechanisms

11.3.1-A – Access control mechanism 

application

11.3.1-B – Multi-factor authentication for 

critical operations

11.3.1-C – Multi-factor authentication for 

administrators

11.3.2 – Username and passwordUser 

authentication credentials

11.3.2-A – Username and password 

management

11.3.2-B – Password complexity

11.3.2-C – Specify password 

complexitySecure storage of authentication

data

11.3.2-D – Password blacklistdisallow list

11.3.2-E – Usernames within passwords

11.4 - The voting system’s default access control policies enforce the principles of least 

privilege and separation of duties.

11.4 – Default access control policies

11.4-A – Least privilege for access policies

11.4-B – Separation of duties

11.5 - Logical access to voting system 

assets are revoked when no longer 

required.

11.4-A – Least privilege for access policies

11.4-B – Separation of duties

11.5 - Logical access to voting system assets are revoked when no longer 

required.

11.5 – Logical access restrictions

11.5-A – AccessSession time periodlimits

11.5-B – Reauthentication

11.5-C – Account lockout

11.5-CD – Lockout time duration

Principle 12: Physical Security

The voting system prevents or detects attempts to tamper with voting system hardware.

12.1 - The voting system supports mechanisms to detect unauthorized physical access.

12.1 – Mechanisms to detect unauthorized 

physical access

12.1-A – Unauthorized physical access

12.1-B – Unauthorized physical access 

alarmalert

12.1-C – Disconnecting a physical device

12.1-D – Logging of physical connections 

and disconnections

12.1-E – Logging door cover and panel 

statusSecure containers

12.1-F – Secure containerslocking systems

12.1-G – Secure physical locks 12.1-H – Secure locking system key

12.1-I – Backup power for power-reliant 

countermeasures

12.2 - The voting system only exposes physical ports and access points that are essential to 

voting operations.

12.2 – Physical ports and access points 

essential to voting

12.2-A – Physical port and access least 

functionality

12.2-B – Physical port auto-disable

12.2-C - Physical port restriction

12.2-D – Disabling ports

12.2-E – Logging enabled and disabled ports

Principle 13: Data Protection

The voting system protects data from unauthorized access, modification, or deletion.
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Requirements for VVSG 2.0 February 29, 202010, 2021

13.1 - The voting system prevents unauthorized access to or manipulation of configuration 

data, cast vote records, transmitted data, or audit records.

13.1.1 – Configuration file

13.1.1-A – Authentication to access 

configuration file

13.1.1-B – Authentication to access 

configuration file on EMS

13.1.1-C – Authentication to access 

configuration file for network appliances

13.1.2 – Election records

13.1.2-A – Integrity protection for election 

records

13.1.2-B – EMS integrity protection for election records

13.2 – The source and integrity of electronic tabulation reports are verifiable.

13.2 – Source and integrity of election records

13.2-A – Signing stored electronic voting election records

13.2-B – Signing electronic voting records prior to transmission

13.2-C – Cryptographic Verification of electronic votingelection records

13.3 - All cryptographic algorithms are public, well-vetted, and standardized.

13.3 – Cryptographic algorithms

13.3-A – Cryptographic module validation

13.3-B – E2E cryptographic voting protocols

13.3-C – Cryptographic strength

13.3-D – MAC cryptographic strength

13.3-E – Cryptographic key management 

documentation

13.4 - The voting system protects the integrity, authenticity, and confidentiality of sensitive 

data transmitted over all networks. 13.4-A – Mutual authentication of endpoints

13.4-B – Confidentiality and integrity protection forof transmitted data

13.4-C – Integrity protection for transmitted data

13.4-D – Verification of election data

 
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Requirements for VVSG 2.0 February 29, 202010, 2021

Principle 14: System Integrity

The voting system performs its intended function in an unimpaired manner, free from 

unauthorized manipulation of the system, whether intentional or accidental.

14.1 - The voting system uses multiple layers of controls to provide resiliency against 

security failures or vulnerabilities.

14.1 – Documented resiliency against 

security failures and vulnerabilities

14.1-A – Risk assessment documentation

14.1-B – Addressing and accepting risk

14.1-C – System security architecture 

description

14.1-D – Procedural and operational 

security

14.2 - The voting system is designed to limit its attack surface by avoiding unnecessary code, 

data paths, connectivity, and physical ports, and by using other technical controls.

14.2 – Designed to limit attack surface

14.2-A – Extraneous processes and services

14.2-B – Non-essential featuresnetworking 

interfaces

14.2-CB – Network status indicator

14.2-DC – Wireless communication 

restrictions

14.2-ED – Wireless network status indicator

14.2-FE – External network restrictions

14.2-G – Secure configuration and hardening

14.2-HF – Secure configuration and 

hardening documentation

14.2-IG – Unused code

14.2-J – Exploit mitigation technologies within platform

14.2-K – Application 14.2-H – Use of 

exploit mitigation technologies

14.2-LI – Importing software libraries

14.2-M – Physical port restrictionJ –

Vulnerability management plan

14.2-NK – Known vulnerabilities

14.2-O – List of known vulnerabilities

14.3 - The voting system maintains and verifies the integrity of software, firmware, and 

other critical components.

14.3 – Supply chain

14.3-A – Supply chain risk management 

strategy

14.3-B – Criticality analysis

14.3-B.1 –C – Bill of materials

14.3.1 – Boot integrity

14.3.1-A – Cryptographic boot verification

14.3.1-B – Preventing of boot on error

14.3.1-C – LoggingNotification of 

verificationboot validation failure

14.3.2 – Software integrity

14.3.2-A – Installing software

14.3.2-B – Software verification for 

installation

14.3.2-C – Software whitelistingApplication 

allowlisting

14.3.2-D – Integrity protection for software whitelists

allowlists

14.4 - Voting system software updates are authorized by an administrator prior to 

installation.

14.4 – Authorized software updates

14.4-A – Authenticated operating system 

updates

14.4-B – Authenticated application updates

14.4-C – Authenticated firmware updates

Principle 15: Detection and Monitoring 

The voting system provides mechanisms to detect anomalous or malicious behavior.

15.1 - Voting system equipment records important activities through event logging 

mechanisms, which are stored in a format suitable for automated processing.

15.1 – Event logging 15.1-A – Event logging
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Requirements for VVSG 2.0 February 29, 202010, 2021

15.1-B – Exporting logs

15.1-C – Logging voter information

15.1-D – Logging event types

15.1-E – Configuration file access log

15.2 - The voting system generates, stores, and reports all error messages as they occur.

15.1-A – Event logging

15.1-B – Exporting logs

15.1-C – Logging voter information

15.1-D – Logging event types

15.1-E – Configuration file access log

15.2 - The voting system generates, stores, and reports all error messages as they occur.

15.2 – Error messages

15.2-A – Presentation of voting application 

errors

15.2-B – DocumentingVoting application

error handling documentation

15.2-C – Logging system errors 15.2-D – Creating error reports

15.3 - The voting system is designed to protect against malware.

15.3 - The voting system is designed to protect against malware.

15.3-A – Software verification

15.3.1 – Malware protection

15.3.1-A – Malware protection 

mechanisms

15.3.115.3-A – Malware protection 

mechanisms

15.3-B – Updatable malware protection 

mechanisms

15.3.1-C – Documenting malware 

protection mechanisms

15.3.1-D – Notification of malware 

detection

15.3.1-E – Logging malware detection

15.3.1-F – Notification of malware 

remediation

15.3.1-G – Logging malware remediation

15.4 - A voting system with networking capabilities employs appropriate, well-vetted 

modern defenses against network-based attacks, commensurate with current best 

practicepractices.

15.4 – Defense against network-based 

attacks

15.4-A – Internal network architecture 

documentation

15.4-B – Secure network configuration 

documentation

15.4-C – Documentation for disabled 

wireless

15.4-D – Firewall and IDS

15.4-E – Least privilege

15.4-F – Rule and policy updates
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Requirements for VVSG 2.0 February 29, 202010, 2021

Appendix C

References
418

Requirements for VVSG 2.0 February 29, 202010, 2021

Appendix C: References

Reference Citation

ADA10: The Americans with Disabilities Act of 1990. Available from 

https://www.ada.gov/2010_regs.htm, October 2019.

ANSI10ANSI0

4: ANSI/TIA-968-A: 2010, Technical Requirements for Connection of Terminal Equipment to the Telephone Network. International Committee for 

Information Technology Standards, American National Standard for 

Information Technology – Role Based Access Control (ANSI INCITS 359-

2004), February 2004.

ANSI11ANSI1

9:

American National Standard for Methods of Measurement of Compatibility 

between Wireless Communication Devices and Hearing Aids, ANSI C63.19-

2011.2019.

ANSI15a: CISPR 22 Ed. 5.2 b: 2015 RLV, Information technology equipment - Radio 

disturbance characteristics - Limits and methods of measurement. 

ANSI15b: CISPR 24:2010+A1:2015, Information technology equipment - Immunity 

characteristics - Limits and methods of measurement. 

ANSI16: ANSI C84.1:2016, Electric Power Systems and Equipment—Voltage Ratings 

(60 Hertz). 

ANSI93: ANSI C63.16:1993, American National Standard Guide for Electrostatic 

Discharge Test – Methodology and Criteria for Electronic Equipment. 

Bishop88Bena

loh14:

F. J. Redmill, Ed., Dependability of Critical Computer Systems 1, Elsevier 

Applied Science, London and New York, 1988.

Bishop, Peter, Dependability of Critical Computer Systems 1, Elsevier 

Applied Science, London and New York, 1988. Available from 

https://www.researchgate.net/publication/234774011_Dependability_of_Cr

itical_Computer_Systems_v_3_Techniques_Directory. September 2019. 

Benaloh et al., End-to-end verifiability, February 2014. 

CA06: California Volume Reliability Testing Protocol rev. January 31, 2006-01-31. 

Available from https://www.sos.ca.gov/ .

CERT19a: CERT® Coordination Center, Secure Coding homepage, 

https://www.sei.cmu.edu/research-capabilities/all- work/display.cfm?customel_datapageid_4050=21274 . September 2019.

CERT19bCIS2

0:

Department of Homeland Security, Build Security In, https://www.us- cert.gov/bsi . September 2019.Center for Internet Security, CIS 

Benchmarks, 2020. 

Dandekar03C

VR_CDF:

Wack et al. Cast Vote Records Common Data Format Specification (NIST SP 

1500-103), Version 1.0. February 2019. Dandekar, K., Mandayam, B. R. 

Srinivasan, A. (2003) Human Fingertips to Investigate the Mechanics of 

Tactile Sense. MIT Touch Lab, Retrieved from 

http://touchlab.mit.edu/publications/2003_009.pdf. October 2019. 
419

Requirements for VVSG 2.0 February 29, 202010, 2021

DISA20: Defense Information Systems Agency, Security Technical Implementation 

Guides (STIGs), 2020. 

EAC19NIST16: U.SWack et al. Election Assistance Commission, Testing and Certification 

Program Manual,Results Common Data Format Specification (NIST SP 

1500-100), Version 2.0, September 2019. Available from 

https://www.eac.gov/voting-equipment/manuals-and-forms/.

Epstein55: Benjamin Epstein and Milton Sobel, "Sequential Life Tests in the 

Exponential Case," Annals of Mathematical Statistics, v. 26, n. 1, March 

1955, pp. 82-93.

FCC18: FCC regulations for hearing aids, 47 CFR Parts 20 and 68: Hearing Aid 

Standard, includes useful information about how to test audio volume and 

quality. Retrieved from https://ecfr.io/Title-47/pt47.2.20 and 

https://www.govinfo.gov/content/pkg/CFR-2018-title47-vol3/xml/CFR-2018- title47-vol3-part68.xml , October 2019.

FCC19a: Title 47, Part 15, Rules and Regulations of the Federal Communications 

Commission, Radio Frequency Devices. Available from 

https://www.govinfo.gov/content/pkg/CFR-2015-title47-vol1/pdf/CFR-2015-

title47-vol1-part15.pdf , September 2019.

FCC19b: Title 47, Part 68, Rules and Regulations of the Federal Communications 

Commission, Connection of Terminal Equipment to the Telephone 

Network: 2019. Available from https://www.ecfr.gov/cgi-bin/textidx?SID=674178ad8816c4dc572668e8aa3e874e&mc=true&node=pt47.3.68

&rgn=div5 , September 2019.

GPO19: Government Paper Specification Standards No. 13, May 2019. Available 

from https://www.gpo.gov/docs/default-source/forms-and-standards-filesfor-vendors/vol_13.pdf . September 2019. 

Grebe96: T.E. Grebe, “Application of Distribution Systems Capacitor Banks and their 

Impact on Power Quality," IEEE Transactions IA-32, May-June 1996. 

Available from IEEE. http://www.ieee.org/. 

HAVA02: The Help America Vote Act of 2002, Public Law 107-252. Available from 

https://www.govinfo.gov/app/details/PLAW-107publ252 . September 2019.

HFP07: Human Factors and Privacy Subcommittee of the TGDC, “Usability 

Performance Benchmarks for the VVSG,” August 2007. Available from 

http://vote.nist.gov/meeting-08172007/Usability-Benchmarks-081707.pdf. 

Hoare69: C. A. R. Hoare, "An Axiomatic Basis for Computer Programming," 

Communications of the ACM, v. 12, n. 10, October 1969, pp. 576-580, 583.

IEC08: IEC 61000-4-2:2008, Electromagnetic compatibility (EMC) - Part 4-2: Testing 

and measurement techniques - Electrostatic discharge immunity test. 

Available from https://webstore.iec.ch/publication/4189 . September 2019.

IEC10: IEC 61000-4-3:2006+AMD1:2007+AMD2:2010 CSV 

Consolidated version. Electromagnetic compatibility (EMC) - Part 4-3: 

Testing and measurement techniques - Radiated, radio-frequency, 

electromagnetic field immunity test. Published 2010. Available from 

https://webstore.iec.ch/publication/4212 . September 2019.
420

Requirements for VVSG 2.0 February 29, 202010, 2021

IEC11: IEC 61000-4-21:2011. Electromagnetic compatibility (EMC) - Part 4-21: 

Testing and measurement techniques - Reverberation chamber test 

methods. Available from https://webstore.iec.ch/publication/4191 . 

September 2019.

IEC15: IEC 61000-4-6:2013/COR1:2015 Corrigendum 1 - Electromagnetic 

compatibility (EMC) - Part 4-6: Testing and measurement techniques -

Immunity to conducted disturbances, induced by radio-frequency fields. 

Published 2015. Available from https://webstore.iec.ch/publication/22665 . 

September 2019.

IEC17: IEC 61000-4-12:2017 RLV Redline version. Electromagnetic Compatibility 

(EMC) - Part 4-12: Testing and measurement techniques - Ring wave 

immunity test. Published 2017. Available from 

https://webstore.iec.ch/publication/61074 . September 2019.

IEEE00: IEEE 100:2000 The Authoritative Dictionary of IEEE Standard Terms, 

Seventh Edition. 

IEEE02: IEEE Std. C62.41.1TM:2002 IEEE Guide on the Surge Environment in LowVoltage (1000 V and less) AC Power Circuits. Available from 

https://standards.ieee.org/standard/C62_41_1-2002.html . September 

2019.

IEEE02a: IEEE Std. C62.45TM:2002 IEEE Recommended Practice on Surge Testing for 

Equipment Connected to Low-Voltage (1000V and Less) AC Power Circuits. 

Available from 

https://pdfs.semanticscholar.org/8e20/820e88d2a90452251eefd2b463c9f7

2fce93.pdf . September 2019.

IEEE02b: IEEE Std. C62.45TM:2002 Recommended Practice for Surge Voltages in LowVoltage AC Power Circuits. Available from 

https://ieeexplore.ieee.org/stamp/stamp.jsp?tp=&arnumber=1196925 . September 2019.

IEEE05: IEEE Std. 1100TM:2005 IEEE Recommended Practice for Powering and 

Grounding Electronic Equipment. Available from 

https://ieeexplore.ieee.org/stamp/stamp.jsp?tp=&arnumber=6046056&tag=

1 . September 2019.

IEEE12: IEEE Std. C62.41.2TM:2002/Core 1-2012 IEEE Recommended Practice on 

Characterization of Surges in Low-Voltage (1000V and Less) AC Power 

Circuits. Available from https://standards.ieee.org/standard/C62_41_2- 2002-Cor1-2012.html . September 2019.

IEEE13: IEEE 29119-3-2013 - ISO/IEC/IEEE International Standard - Software and 

systems engineering — Software testing —Part 3: Test documentation. 

Available from https://standards.ieee.org/standard/29119-3-2013.html . 

September 2019.

IEEE14: IEEE Std. 519TM:2014 519-2014 IEEE Recommended Practices and 

Requirements for Harmonic Control in Electrical Power Systems. Available from https://ieeexplore.ieee.org/document/6826459 . September 2019.

IEEE19: IEEE 15289-2019 - ISO/IEC/IEEE International Standard -- Systems and 

software engineering - Content of life-cycle information items 
421

Requirements for VVSG 2.0 February 29, 202010, 2021

(documentation). Available from 

https://standards.ieee.org/standard/15289-2019.html . September 2019.

ISO00: ISO/IEC TR 15942:2000, Information technology—Programming 

languages—Guide for the use of the Ada programming language in high 

integrity systems. Available from 

https://www.iso.org/standard/29575.html . September 2019.

ISO04a: ISO 17000:2004, Conformity assessment—Vocabulary and general 

principles. Available from https://www.iso.org/standard/29316.html . September 2019.

ISO04b: IEC 61000-4-4:2012 Electromagnetic compatibility (EMC) - Part 4-4: Testing 

and measurement techniques - Electrical fast transient/burst immunity 

test. Available from https://webstore.iec.ch/publication/4222 . September 

2019.

ISO05: ISO 9000:2015 QUALITY MANAGEMENT SYSTEMS -- FUNDAMENTALS AND 

VOCABULARY. Available from https://www.iso.org/standard/45481.html . 

September 2019.

ISO06a: ISO/IEC 23270:2006, Information technology—Programming languages— C#. 

ISO06b: ISO/IEC 25062:2006 Software engineering —Software product Quality 

Requirements and Evaluation (SQuaRE) —Common Industry Format (CIF) for 

Usability Test Reports. Available from 

https://www.iso.org/standard/43046.html . September 2019.

ISO08: ISO 18921:2008, Imaging materials—Compact discs (CD-ROM)—Method for 

estimating the life expectancy based on the effects of temperature and 

relative humidity. Available from https://www.iso.org/standard/51327.html

. September 2019.

ISO10: ISO/IEC TR 25060:2010

Systems and software engineering — Systems and software product 

Quality Requirements and Evaluation (SQuaRE) — Common Industry 

Format (CIF) for usability: General framework for usability-related 

information. Available from https://www.iso.org/standard/35786.html, October 2019.

ISO12: ISO/IEC 8652:2012, Information technology—Programming languages—

Ada. Available from https://www.iso.org/standard/61507.html . September 

2019.

ISO13a: ISO/IEC TR 24772:2013

INFORMATION TECHNOLOGY -- PROGRAMMING LANGUAGES -- GUIDANCE 

TO AVOIDING VULNERABILITIES IN PROGRAMMING LANGUAGES 

THROUGH LANGUAGE SELECTION AND USE. Available from 

https://www.iso.org/standard/61457.html . September 2019.

ISO13b: ISO/IEC 25064:2013

Systems and software engineering — Software product Quality 

Requirements and Evaluation (SQuaRE) — Common Industry Format (CIF) 
422

Requirements for VVSG 2.0 February 29, 202010, 2021

for usability: User needs report. Available from 

https://www.iso.org/standard/35790.html, October 2019.

ISO14: ISO/IEC 25063:2014

Systems and software engineering — Systems and software product 

Quality Requirements and Evaluation (SQuaRE) — Common Industry 

Format (CIF) for usability: Context of use description. Available from 

https://www.iso.org/standard/35789.html , October 2019.

ISO15ISO16: ISO 9001:2015, Quality management systems – Requirements. Available 

from https://www.iso.org/standard/62085.html. September 2019.ISO/IEC 

25066:2016 Software engineering —Software product Quality Requirements and 

Evaluation (SQuaRE) —Evaluation report

ISO17: ISO 10007:2017, Quality management systems – Guidelines for 

configuration management. Available from 

https://www.iso.org/standard/70400.html . September 2019.

ISO17a: ISO/IEC 14882:2017, Programming languages—C++. Available from 

https://www.iso.org/standard/68564.html . September 2019.

ISO17b: IEC TR 61000-2-5:2017 RLV Redline version. Electromagnetic compatibility 

(EMC) - Part 2-5: Environment - Description and classification of 

electromagnetic environments. Available from 

https://webstore.iec.ch/publication/59812 . September 2019.

ISO18: ISO/IEC/IEEE 90003:2018

SOFTWARE ENGINEERING -- GUIDELINES FOR THE APPLICATION OF ISO 

9001:2015 TO COMPUTER SOFTWARE. Available from 

https://www.iso.org/standard/74348.html . September 2019.

ISO18aISO18d

:

ISO/IEC 2327027005:2018, Information technology—C# language 

specification. Available from https://www.iso.org/standard/75178.html . 

September 2019. - Security techniques - Information security risk 

management, July 2017. 

ISO18b: ISO/IEC 9899:2018, Programming languages—C. Available from

https://www.iso.org/standard/74528.html . September 2019.

ISO18c: ISO 9241-11:2018. ERGONOMICS OF HUMAN-SYSTEM INTERACTION --

PART 11: USABILITY: DEFINITIONS AND CONCEPTS. Available from 

https://www.iso.org/standard/63500.html . September 2019.

ISO19: ISO 35.060 - LANGUAGES USED IN INFORMATION TECHNOLOGY. 

https://www.iso.org/ics/35.060/x/ . September 2019.

ISO19a: ISO/IEC PRF TR 24772-1

PROGRAMMING LANGUAGES -- GUIDANCE TO AVOIDING VULNERABILITIES 

IN PROGRAMMING LANGUAGES -- PART 1: LANGUAGE INDEPENDENT. 

Available from https://www.iso.org/standard/71091.html . September 

2019.

ISO94ISO19b: ISO 9706:1994, Information and documentation—Paper for documents—

Requirements for permanence. Available from 

https://www.iso.org/standard/17562.html . September 2019.ISO/IEC 9294-

210:2019 Ergonomics of human-system interaction — Part 210: Human-
423

Requirements for VVSG 2.0 February 29, 202010, 2021

centred design for interactive systems. 

ITIC00:ISO860

1

ITI (CBEMA) Curve, Information Technology Industry Council (ITI):2000. 

Available from http://www.itic.org/resources/Oct2000Curve-UPDATED.doc . September 2019.ISO/IEC 8601-1:2019 Date and Time Format. 

ITU19: International Telecommunications Union (ITU) (nd) Rec. ITU-T P.50 

Appendix I Retrieved from: http://www.itu.int/net/itu- t/sigdb/genaudio/AudioForm-g.aspx?val=1000050. October 2019.

Java18Kulyk1

8:

The Java Language Specification, Java SE 11 Edition, 2018. Available from 

https://docs.oracle.com/javase/specs/ . September 2019.Oksana Kulyk, 

Melanie Volkamer, Usability is not Enough: Lessons Learned from ‘Human 

Factors in Security’ Research for Verifiability, October 2018. 

Java19Lewis1

9a:

The Java Language Specification, Java SE 12 Edition. Published 2019. 

Available from https://docs.oracle.com/javase/specs/ . September 2019. 

Sarah Jamie Lewis, Olivier Pereira, Vanessa Teague, Ceci n’est pas une 

preuve, March 2019. 

Key94: T.S. Key and F.D. Martzloff, “Surging the Upside-Down House: Looking into 

Upsetting Reference Voltages,” PQA’94 Conference, Amsterdam, 

Netherlands, 1994. Accessible on-line at the NIST-hosted SPD Anthology –

Part 5, 

https://www.nist.gov/sites/default/files/documents/pml/div684/Upsdown_

surging.pdf . September 2019.

KS05: Request for Proposal #08455, Kansas, 2005-05-16. Available from 

http://www.kssos.org/elections/05elec/Voting_Equipment_RFP.pdf . 

September 2019.

McC76: T. McCabe, “A Complexity Measure,” IEEE Transactions on Software 

Engineering Vol. SE-2, No. 4, pp. 308-320 (December 1976). Available from 

https://ieeexplore.ieee.org/stamp/stamp.jsp?tp=&arnumber=1702388&tag=

1 . September 2019.

MIL19Lewis19

b:

MIL-STD-810-H, Department of Defense Test Method Standard: Environmental 

Engineering Considerations and Laboratory Tests, January 2019. Available 

from http://everyspec.com/MIL-STD/MIL-STD-0800-0899/download.php?spec=MILSTD-810H.055998.pdf . October 2019.Sarah Jamie Lewis, Olivier Pereira, 

Vanessa Teague, How not to prove your election outcome, March 2019. 

MIL85: MIL-STD-1521B (USAF) Technical Reviews and Audits for Systems, 

Equipments [sic], and Computer Software, rev. December 19, 1985. 

Available from http://everyspec.com/MIL-STD/MIL-STD-1500- 1599/download.php?spec=MIL_STD_1521B.1503.pdf . September 2019.

MIL96LOG_C

DF:

Wack et al. Election Event Logging Common Data Format Specification 

Draft (NIST SP 1500-101), Version 1.0. September 2017. MIL-HDBK-781A, 

Handbook for Reliability Test Methods, Plans, and Environments for 

Engineering, Development, Qualification, and Production, April 1, 1996. 

Available from http://everyspec.com/MIL-HDBK/MIL-HDBK-0700-

0799/download.php?spec=MIL_HDBK_781A.1933.pdf . September 2019.
424

Requirements for VVSG 2.0 February 29, 202010, 2021

MISRA13MIT

RE20:

MISRA-C:2012: Guidelines for the use of the C language in critical systems, 

MIRA Limited, U.K., March 2013.MITRE Common Weakness Enumeration 

561: Dead Code, August 2020. 

MITRE20a: MITRE Common Weakness Enumeration 259: Use of Hard-coded Password, 

August 2020. 

MITRE20b: MITRE Common Weakness Enumeration 321: Use of Hard-coded 

Cryptographic Key, August 2020. 

MITRE20c: MITRE Common Weakness Enumeration 116: Improper Encoding or 

Escaping of Output, June 2020. 

MITRE20d: MITRE Common Weakness Enumeration 134: Use of Externally-Controlled 

Format String, August 2020. 

MISRA18MIT

RE20e:

Roberto Bagnara, Abramo Bagnara, and Patricia M. Hill, “The MISRA C 

Coding Standard and its Role in

the Development and Analysis of Safety- and

Security-Critical Embedded Software.” Published in 2018. Available from 

https://arxiv.org/pdf/1809.00821.pdf . September 2019.MITRE Common 

Weakness Enumeration 89: Improper Neutralization of Special Elements 

used in an SQL Command (‘SQL Injection’), August 2020. 

MISRA19: MISRA publications and resources. Available from 

https://www.misra.org.uk/Publications/tabid/57/Default.aspx#label-c3 . 

September 2019.

Morris84: F. L. Morris and C. B. Jones, "An Early Program Proof by Alan Turing," IEEE 

Annals of the History of Computing, v. 6, n. 2, April 1984, pp. 139-143. 

Available from https://fi.ort.edu.uy/innovaportal/file/20124/1/09-

turing_checking_a_large_routine_earlyproof.pdf . September 2019.

Moulding89: M. R. Moulding, "Designing for high integrity: the software fault tolerance 

approach," Section 3.4. In C. T. Sennett, ed., High-Integrity Software, 

Plenum Press, New York and London, 1989. Available from https://pageone.springer.com/pdf/preview/10.1007/978-1-4684-5775-9_3 . September 

2019.

MS13: Paul Vick and Lucian Wischik. The Microsoft® Visual Basic® Language 

Specification, Version 11.0, 2013. Available from Microsoft Download 

Center, https://www.microsoft.com/enus/download/details.aspx?displaylang=en&id=15039. September 2019. 

NFPA17: National Electrical Code (NFPA 70):2017. Available from NFPA, 

http://www.nfpa.org/. September 2019.

NGC18: Nevada Gaming Commission and State Gaming Control Board, Technical 

Standards for Gaming Devices and On-Line Slot Systems, Regulation 14, 

2018. Available from https://gaming.nv.gov/index.aspx?page=51.

September 2019. 

NIST03NIST01

:

Fred R. Byers, Care and Handling of CDs and DVDs—A Guide for Librarians 

and Archivists, National Institute of Standards and Technology Special 

Publication 500-252, 2003-10. Available from 

https://www.nist.gov/publications/care-and-handling-preservation-cds-and-
425

Requirements for VVSG 2.0 February 29, 202010, 2021

dvds-guide-librarians-and-archivists and 

http://www.clir.org/pubs/reports/pub121/contents.html. September 

2019.National Institute of Standards and Technology Federal Information 

Processing Standards 140-2: Security Requirements for Cryptographic 

Modules, May 2001. 

NIST07: Karen Scarfone, Peter Mell, National Institute of Standards and Technology 

Special Publication 800-94: Guide to Intrusion Detection and Prevention 

Systems, February 2007. Available from 

https://doi.org/10.6028/NIST.SP.800-94. September 2019. 

NIST07a: David Flater, Philippe A. Martin, and Michelle L. Crane, National Institute 

of Standards and Technology IR 7469, Rendering UML Activity Diagrams as 

Human-Readable Text, November 2007. Available from 

http://purl.org/net/dflater/org/nist/nistir7469.html or pdf. September 

2019.

NIST08: Dana E. Chisnell, Susan C. Becker, Sharon J. Laskowski, Svetlana Z. Lowry, 

National Institute of Standards and Technology IR 7519, Style Guide for 

Voting System Documentation, August 2008. Available from 

https://doi.org/10.6028/NIST.IR.7519 , October 2019.

NIST09: Karen Scarfone and Paul Hoffman, National Institute of Standards and 

Technology Special Publication 800-41, Revision 1: Guidelines on Firewalls 

and Firewall Policy, September 2009. Available from 

https://nvlpubs.nist.gov/nistpubs/Legacy/SP/nistspecialpublication800-

41r1.pdf. September 2019. 

NIST09a: Janice (Ginny) Redish and Sharon J. Laskowski, National Institute of 

Standards and Technology IR 7596, Guidelines for Writing Clear 

Instructions and Messages for Voters and Poll Workers, May 2009. 

NIST13NIST12

:

Recommended Security Controls for Federal Information SystemsJoint Task 

Force Transformation Initiative, National Institute of Standards and 

Technology Special Publication 800-5330, Revision 4, April 2013. Available 

from https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-

53r4.pdf.1: Guide for Conducting Risk Assessments, September 20192012. 

NIST13a: Murugiah Souppaya, Karen Scarfone, National Institute of Standards and 

Technology Special Publication 800-83, Revision 1: Guide to Malware 

Incident Prevention and Handling for Desktops and Laptops, July 2013. 

Available from http://dx.doi.org/10.6028/NIST.SP.800-83r1. September 

2019. 

NIST13b: Murugiah Souppaya, Karen Scarfone, National Institute of Standards and 

Technology Special Publication 800-40, Revision 3: Guide to Enterprise 

Patch Management Technologies, July 2013. 

NIST13c: National Institute of Standards and Technology Federal Information 

Processing Standards 186-4: Digital Signature Standard, July 2013. 

NIST15a: Elaine Barker, John Kelsey, National Institute of Standards and Technology 

Special Publication 800-90A, Revision 1: Recommendation for Random 

Number Generation Using Deterministic Random Bit Generators, June 

2015. 
426

Requirements for VVSG 2.0 February 29, 202010, 2021

NIST15b: Jon Boyens et al., National Institute of Standards and Technology Special 

Publication 800-161: Supply Chain Risk Management Practices for Federal 

Information Systems and Organizations, April 2015

NIST17c: Paul A. Grassi, Michael E. Garcia, James L. Fenton, National Institute of 

Standards and Technology Special Publication 800-63-3: Digital Identity 

Guidelines, June 2017. 

NIST17d: Paul A. Grassi et al., National Institute of Standards and Technology Special 

Publication 800-63B: Digital Identity Guidelines: Authentication and 

Lifecycle Management, June 2017.

NIST17e: Michael Nieles, Kelley Dempsey, Victoria Yan Pillitteri, National Institute of 

Standards and Technology Special Publication 800-12, Revision 1: An 

Introduction to Information Security, June 2017. 

NIST18a: Turan et al. National Institute of Standards and Technology Special 

Publication 800-90B: Recommendation for the Entropy Sources Used for 

Random Bit Generation, January 2018. 

NIST18b: Celia Paulsen, Jon Boyens, Nadya Bartol, Kris Winkler, National Institute of 

Standards and Technology Interagency or Internal Report 8179: Criticality 

Analysis Process Model: Prioritizing Systems and Components, April 2018. 

NIST16NIST18

c:

Wack et al. Election Results Common Data Format Specification (NIST SP 

1500-100), Version 1.0, February 2016. Available from 

https://github.com/usnistgov/ElectionResultsReporting and 

https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.1500-100.pdf. September 2019.National Institute of Standards and Technology, 

Framework for Improving Critical Infrastructure Cybersecurity, Version 1.1, 

April 2018. 

NIST19a: National Institute of Standards and Technology Federal Information 

Processing Standards 140-3: Security Requirements for Cryptographic 

Modules, March 2019. 

NIST19b: Kerry McKay, David Cooper, National Institute of Standards and 

Technology Special Publication 800-52, Revision 2: Guidelines for the 

Selection, Configuration, and Use of Transport Layer Security (TLS) 

Implementations, August 2019. 

NIST20a: Eliane Barker, National Institute of Standards and Technology Special 

Publication 800-57 Part 1, Revision 5: Recommendation for Key 

Management Part 1 – General, May 2020. 

NIST17aNIST2

0b:

Joint Task Force, National Institute of Standards and Technology Special 

Publication 800-53, Revision 5: Security and Privacy Controls for 

Information Systems and Organizations, September 2020. Wack et al. 

Election Event Logging Common Data Format Specification Draft (NIST SP 

1500-101), Version 1.0. September 2017. Available from https://github.com/usnistgov/ElectionEventLogging and 

https://pages.nist.gov/ElectionEventLogging. September 2019.

NIST20c: Kelley Dempsey, Eduardo Takamura, Paul Eavy, George Moore, National 

Institute of Standards and Technology Interagency or Internal Report 8011 
427

Requirements for VVSG 2.0 February 29, 202010, 2021

Volume 4: Automation Support for Security Control Assessments: Software 

Vulnerability Management, April 2020. 

NIST17bNIST2

0d: Celia Paulsen et al., National Institute of Standards and Technology Interagency or Internal Report 8272: Impact Analysis Tool for 

Interdependent Cyber Supply Chain Risks, August 2020Wack et al. Voter 

Records Interchange (VRI) CDF Specification (NIST SP 1500-102), Version 

1.0. August 2017. Available from 

https://github.com/usnistgov/VoterRecordsInterchange and 

https://pages.nist.gov/VoterRecordsInterchange/. September 2019.

NIST19NIST20 e: National Institute of Standards and Technology Cryptographic Module 

Validation Program, October 2020. Wack et al. Cast Vote Records Common 

Data Format Specification (NIST SP 1500-103), Version 1.0. February 2019. 

Available from https://github.com/usnistgov/CastVoteRecords and 

https://pages.nist.gov/CastVoteRecords. September 2019.

NIST20f: Elaine Barker, Allen Roginsky, Richard Davis, National Institute of 

Standards and Technology Special Publication 800-133, Revision 2: 

Recommendation for Cryptographic Key Generation, June 2020. 

NIST75NIST20

g:

Saltman, RoyElaine Barker, National Institute of Standards and Technology 

Special Publication 500-30, Effective Use of Computing Technology 800-

175B, Revision 1: Guideline for Using Cryptographic Standards in VoteTallying, 1975. Available from https://doi.org/10.6028/NBS.SP.500-30. 

September 2019the Federal Government: Cryptographic Mechanisms, 

March 2020. 

NIST20h: Security and Privacy Controls for Information Systems and Organizations, National Institute of Standards and Technology Special Publication 800-53, 

Revision 5, September 2020. 

OED19NTIA19

:

New Shorter Oxford English Dictionary online, Oxford University Press, 

2019. Available from https://www.oed.com/. September 2019. National 

Telecommunications and Information Administration, Software Bill of 

Materials, 2019. 

OMG17OCD- ID: OMG Unified Modeling Language Superstructure Specification, version 

2.5.1, Object Management Group, December 2017. 

https://www.omg.org/spec/UML/. September 2019.Open Civic Data 

Identifiers Specification. 

OWASP19: Open Web Application Security Project, Application Security Verification 

Standard 4.0, March 2019. 

Rivest06: Ronald R. Rivest and John P. Wack, “On the notion of "software 

independence" in voting systems,” July 28, 2006. Available from 

http://people.csail.mit.edu/rivest/pubs/RW06.pdf. A later version is also 

available at http://people.csail.mit.edu/rivest/pubs/Riv08b.pdf. September 

2019. 

SAFECode19: SAFECode, Managing Security Risks Inherent in the Use of Third-party 

Components, May 2019. 

TC04: Trace Center (2004), About Decibels (dB). Retrieved from: 

http://trace.umd.edu/docs/2004-About-dB. October 2019.
428

Requirements for VVSG 2.0 February 29, 202010, 2021

TC19TCnd: Trace Center (nd). EZ Access design is an example of button functions 

distinguishable by both shape and color. Retrieved from: 

https://trace.umd.edu/ez. October 2019.

Telcordia17: Telcordia GR-1089:2017, Issue 07, Electromagnetic Compatibility and 

Electrical Safety - Generic Criteria for Network Telecommunications 

Equipment. Available from Telcordia, http://telecom-info.telcordia.com/. 

September 2019.

TGDC2007: 2007 TGDC Recommended Guidelines, August 31, 200. Available from 

https://www.eac.gov/assets/1/28/TGDC_Draft_Guidelines.2007.pdf (or 

https://www.eac.gov/voting-equipment/voluntary-voting-system- guidelines/). September 2019.

UL07: UL 60950-1:2007, Edition 2, Information Technology Equipment – Safety – Part 1: General Requirements. March 27, 2007. Available from 

https://standardscatalog.ul.com/standards/en/standard_60950-1_2. September 2019. 

UL13: UL 437:2013, Edition 8, Standard for Key Locks. May 15, 2013. Available 

from https://standardscatalog.ul.com/standards/en/standard_437_8. 

September 2019. 

UL16UL19: UL 943:2016, Edition 5, Standard for Safety for Ground-Fault CircuitInterrupters. May 17, 2016. Available from 

https://standardscatalog.ul.com/standards/en/standard_943_5. September 

2019. UL 62368:1 Edition 3, Standard for Audio/video, Information and 

Communication Technology Equipment - Part 1: Safety requirements

USAB14a: US Access Board Technical Guide: Clear Floor or Ground Space and Turning 

Space. February, 2014. Retrieved from: https://www.accessboard.gov/attachments/article/1553/clear%20floor%20sapce-ABA.pdf. October 2019.

USAB14b: US Access Board Guide to the ADA Standards, Chapter 3 Operable Parts. 

Retrieved from: https://www.access-board.gov/guidelines-and- standards/buildings-and-sites/about-the-ada-standards/guide-to-the-adastandards/chapter-3-operable-parts. October 2019.

USAB17USAB

18:

US Access Board (2017)2018) Section 508 Information and Communication 

Technology (ICT) Final Standards and Guidelines (36 CFR Parts 1193 and 

1194, RIN 3014-AA37, published in the Federal Register on January 18, 

2017, Amended March 23, 2017) as Retrieved from: https://www.access- board.gov/guidelines-and-standards/communications-and-it/about-the-ictrefresh/final-rule. October 2019. Final Rule, March 23, 2018) 

USDOJUSDOJ

16: US Department of Justice ADA Checklist for Polling Places, 2016. Retrieved from: https://www.ada.gov/votingchecklist.htm. October 2019.

Valgrind19: Valgrind home page, http://valgrind.org/, September 2019.

VRA65: The Voting Rights Act of 1965, Public Law 89-110, August 6, 1965. Available 

from https://www.govinfo.gov/content/pkg/STATUTE-79/pdf/STATUTE-79- Pg437.pdf. October 2019.
429

Requirements for VVSG 2.0 February 29, 202010, 2021

VRI_CDF: Wack et al. Voter Records Interchange (VRI) CDF Specification (NIST SP 

1500-102), Version 1.0. August 2017. 

VSS1990: Performance and Test Standards for Punchcard, Marksense, and Direct 

Recording Electronic Voting Systems, January 1990 edition with April 1990 

revisions, in Voting System Standards, U.S. Government Printing Office, 

1990. Available from 

https://www.eac.gov/assets/1/28/FEC_1990_Voting_System_Standards1.pd

f (or https://www.eac.gov/voting-equipment/voluntary-voting-systemguidelines/). September 2019. 

VSS2002: 2002 Voting Systems Standards, Volumes I and II. Available from 

https://www.eac.gov/assets/1/28/Voting_System_Standards_Volume_I.pdf

and 

https://www.eac.gov/assets/1/28/Voting_System_Standards_Volume_II.pdf

, respectively (or https://www.eac.gov/voting-equipment/voluntary-voting- system-guidelines/). September 2019. 

VVSG2005: 2005 Voluntary Voting System Guidelines, Version 1.0, Volumes I and II, 

March 6, 2006. Available from 

https://www.eac.gov/assets/1/28/VVSG.1.0_Volume_1.PDF and 

https://www.eac.gov/assets/1/28/VVSG1.0Vol.2.PDF, respectively (or 

https://www.eac.gov/voting-equipment/voluntary-voting-system- guidelines/). September 2019. 

VVSG2015: 2015 Voluntary Voting System Guidelines, Version 1.1, Volumes I and II. 

Available from 

https://www.eac.gov/assets/1/28/VVSG.1.1.VOL.1.FINAL1.pdf and 

https://www.eac.gov/assets/1/28/VVSG.1.1.VOL.2.FINAL.pdf, respectively 

(or https://www.eac.gov/voting-equipment/voluntary-voting-system- guidelines/). September 2019.2015 Voluntary Voting System Guidelines, 

Version 1.1, Volumes I and II. March 31, 2015.

W3C10: W3C WAI (2010) WCAG 2.0 Web content and Accessibility Guidelines. 

Retrieved from https://www.w3.org/WAI/GL/WCAG20/. October 2019.