TGDC previews VVSG 2.1 draft that would bar machine‑readable vote encodings and require voter‑verifiable paper records

The Technical Guidelines Development Committee of the U.S. Election Assistance Commission met virtually to review the draft Voluntary Voting System Guidelines (VVSG) 2.1 and associated change notes, discussing new data formats, limits on machine‑readable encodings of votes, and a reaffirmed requirement for a voter‑verifiable paper record.

Brooke Waters, an EAC director involved in drafting the revisions, said the VVSG 2.1 draft adds two common data format specifications — a logical election ballot definition exchange and a micro CDF serialization — and "prohibits the use of barcodes or other machine readable codes from encoding and storing voter selections," aligning the draft with an executive order and committee consensus. Waters said the prohibition aims to ensure "all voters can verify selections directly from the paper record."

The EAC team also described the update as a "minor revision" covering errata and published requests for interpretation, and noted that some member recommendations were incorporated into the draft while others were deferred or deemed outside the scope of the current revision. The draft remains posted for the statutorily required 90‑day public comment period once the EAC advances that step.

NIST urged caution. Benjamin Long, speaking for the National Institute of Standards and Technology, said he views 2.1 as a minor update but warned that several proposed changes on the table—such as an outright hardware prohibition or broad shifts in verification and tabulation approaches—could be major in scope and carry downstream consequences for cost, reliability, and interoperability that "deserve longer‑term study." Long said specific research on barcode use cases has not been scheduled but could be undertaken at the committee's request.

Members discussed a narrow technical point about "indirect voter association" requirements used in end‑to‑end verifiable (ETEV) systems and provisional ballot use cases. Some members argued deleting the language would have no effect on currently deployed systems; others urged retaining suitable safeguards for provisional ballots and cryptographic use cases where indirect association remains relevant.

Procedural note: during the meeting, a motion to remove a planned vote on the TGDC recommendations from today’s agenda was moved and seconded and approved by voice vote. The committee therefore did not take the TGDC recommendations to a vote during this session.

The draft includes several provisions intended to reinforce transparency and interoperability while balancing accessibility and operational realities; EAC staff and NIST said they plan to continue studies and outreach to define implementation details. The committee discussed posting the draft and correspondence broadly; EAC counsel said the documents could be posted but clarified that letters received before a formal public‑comment window are being handled separately from the statutory 90‑day comment period.

The committee adjourned after agreeing to continue deliberations and to provide additional follow‑up and documentation for members and the public.