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TGDC debates paper‑ballot mandate and end‑to‑end verifiability in VVSG 2.1

Technical Guidelines Development Committee, U.S. Election Assistance Commission · August 9, 2025
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Summary

Members of the EAC Technical Guidelines Development Committee debated whether VVSG 2.1 should remove the path to paperless voting and end‑to‑end (E2E) verifiability, with advocates citing accessibility and future‑proofing and opponents urging a phased approach that preserves testing and procurement runway.

The Election Assistance Commission’s Technical Guidelines Development Committee spent much of its July 16 meeting debating whether the draft VVSG 2.1 should eliminate the path to paperless voting and the end‑to‑end verifiability (EDV/EDTE) approaches that some experts say can increase accessibility.

Chairman Donald Palmer opened the meeting by describing 2.1 as a minor revision to the standards and encouraging written comment, then introduced discussion of the executive order that directed greater reliance on voter‑verifiable paper ballots. Kevin Scogland, in written feedback, urged replacing sections that permit paperless options with a single requirement prohibiting indirect voter associations and removing paths for paperless systems. "Barcodes and paperless approaches create opaque vote records," Scogland said during the meeting, arguing that transparency principles in VVSG favor removing vote‑encoding barcodes and paperless architectures.

Other committee members warned that a wholesale ban on non‑paper systems would be "shortsighted." Paul Lux and Mary Saunders said the VVSG are voluntary standards and that states ultimately choose technologies. Several members — including Jud Chot and Isaac Kramer — pushed back that accessibility needs and remote or overseas voting use cases rely on electronic mechanisms and that development of E2E systems remains relevant. "If a state wants a paperless system, it can have one," Lux said; "but the standard should not eliminate options that might later serve disabled or remote voters."

Access experts said the trade‑offs are complicated. Kathy Ang of the U.S. Access Board told the committee she had not yet reviewed the detailed edits but cautioned that paper ballots can present accessibility barriers for blind or low‑vision voters and that any move to require paper should be evaluated with people with disabilities and accessibility specialists. Diane Golden, an accessibility advocate on the committee, said the community has repeatedly pressed the EAC to ensure one clearly identified, fully accessible voting device or combination of devices is available to voters who need it.

The committee did not adopt a final policy on the paper‑ballot question but agreed to produce a redline of edits for TGDC review: members were given one week to submit comments, one week for staff to create a draft redline, and two weeks for members to review and consult stakeholders before a public TGDC vote is scheduled.

The committee’s next step will be to collect written input from technical experts and disability advocates, then decide whether specific EDV provisions should be preserved, modified, or removed in the 2.1 package.