Michigan rules for electronic ballot delivery and CAC-only electronic return draw security and scope objections

The Michigan Department of State told the Joint Committee on Administrative Rules that the rule package to implement electronic return of voted ballots for eligible overseas uniformed service members is intended to meet statutory requirements and follow security standards set by the state's information-technology office, but committee members and public commenters raised security and scope concerns.

"Beginning September 1 of 20 25, eligible members of the military may choose to ... electronically return a voted ballot to their city or township clerk to be counted as provided in the Michigan election law," Erin Shore, legislative policy director with the Michigan Department of State, told the committee. Adam Fricasse, deputy director of the Bureau of Elections, described how the rules translate statutory language into operational procedures.

Why it matters: the legislature in 2022 directed the Department of State to establish procedures allowing certain overseas and uniformed service voters to return voted ballots electronically; the committee heard technical details about who is eligible, how identity verification will work and what security standards the department will use. The rules are scheduled to take effect to meet the statutory implementation date and include detailed timelines for ballot delivery and processing.

Scope and verification: Department officials said the rules require eligible voters to be a member of a uniformed service on active duty or a member of the merchant marine absent from the United States and to…