TGDC presses for clearer accessibility standards in VVSG 2.1; members warn of ‘segregated’ deployments

The Technical Guidelines Development Committee (TGDC) of the U.S. Election Assistance Commission spent the bulk of a recent workshop disputing how the Voting System Guidelines (VVSG) 2.1 should define accessibility requirements.

"If something is not going to meet all the access standards as originally intended, then it needs to be clear that thing is not accessible," said Diane Golden, a TGDC member, arguing that current draft language and incorporated RFIs contradict each other and risk certifying equipment that election officials and voters will mistake for fully accessible devices.

The dispute centered on whether the compliance unit for accessibility should be the entire voting system — ensuring "at least one accessible path" for each voter — or each individual component. David Wagner, another committee member, proposed reframing the standard to emphasize system-level accessibility so jurisdictions and manufacturers could unambiguously know what is certified: "Think of this as a requirement that the system be accessible, not a requirement that every component be accessible," he said.

Members and staff agreed the ambiguity has practical consequences. Several local election officials cautioned that mandating fully integrated "all-in-one" ballot-marking-and-casting devices for every polling place would be prohibitively expensive, while others warned that relying on a single accessible unit in a polling place can relegate voters with disabilities to a separate, visible station — a form of segregation critics likened to "separate is inherently unequal." Paul Lux, speaking from the perspective of state and local administrators, urged the TGDC to include accessibility experts in further drafting and to make any distinctions clear to procurement officials.

NIST and EAC staff said the RFIs incorporated into 2.1 were intended to clarify implementation, not to change the substantive requirement that voting systems be accessible. Monica Childers, who led roll call and administrative confirmations for the meeting, confirmed a quorum was present and that members had been asked to send specific drafting suggestions to staff.

The committee agreed on next steps: staff and NIST will draft clearer language to specify whether the requirement refers to a certified system or individual components; members volunteered to circulate precise edits in chat and by email. Several committee members asked that representatives of the accessibility community be given substantive roles in the conversation before any final change is adopted.

The TGDC will reconvene for a working session on August 8; staff were asked to circulate revised text in advance.

The meeting record shows no formal policy vote on substantive VVSG 2.1 language; the committee approved the meeting agenda and adjourned by voice vote.