TGDC reviews draft VVSG 2.1, debates barcode limits and voter-verifiable paper records

The Technical Guidelines Development Committee, the advisory panel that helps the Election Assistance Commission review voluntary voting system guidelines, spent much of its meeting examining draft language for VVSG 2.1 and the implications of the President's executive order on election integrity.

Chairman Don Palmer opened the meeting by saying the draft responds to questions arising since VVSG 2.0 and to the executive order. "The EO prohibits barcodes containing voter selections with the exception of supporting accessible voting for voters with disabilities," Palmer said, framing the committee's central task.

Why it matters: The changes being considered affect how voting machines encode ballots, how voters confirm votes, and how testing laboratories evaluate systems. EAC staff and NIST officials told the panel that the 2.1 draft incorporates published requests for interpretation and two NIST common data format specifications, and that the draft clarifies when machine-readable barcodes may contain voter selections.

What the draft would do: John Panick, the EAC's chief election technology officer, and Brook Waters, the EAC's director of testing and certification, walked members through the proposed revisions. Waters said the draft adds technical clarifications arising from twelve published RFIs and two new common data formats: a ballot-definition CDF and an optional micro CDF for space-constrained machine-readable data on paper.

On barcodes and accessibility, Waters told the committee the draft's clarified wording is meant to limit production of barcodes that contain voter selections to the subset of systems used to —support accessible voting for voters with disabilities.— She summarized the change this way: "Specifically, only systems capable of producing such barcodes for electronic systems must meet the accessibility requirements in VVSG 2.0," and the 2.1 language makes that intention more explicit.

The draft also replaces language that permitted a pathway for paperless systems to be certified under the VVSG family with requirements for a voter-verifiable paper record (VVPR) or an EAC-approved end-to-end (E2E) cryptographic architecture. Waters noted that no EAC-approved cryptographic E2E protocols currently exist and therefore the practical effect is a stronger emphasis on VVPRs.

Member concerns: Committee members from the accessibility, state, and vendor communities raised technical and implementation questions. Diane Golden (TGDC member) warned that accessibility representation on the committee was incomplete because two Access Board seats had not yet been seated and said that the draft's changes to barcode and accessibility rules require a careful review of accessibility assertions. Judge Chot and others pressed staff to show where VVSG 2.0 already constrained barcode use; EAC staff said 2.0 contained criteria that implicitly limited barcode uses, and 2.1's drafting aims to make that explicit.

Several members asked about timing and the effect on vendors and states. Paul Lux and others said some states incorporate VVSG into state law and that forcing rapid re-certification or descertification would create procurement and operational problems. Industry representatives said major vendors can adapt but asked for predictable timelines.

What the TGDC decided: Members did not vote to recommend adoption of VVSG 2.1 at the meeting. Instead the committee voted to schedule a follow-up 'nuts-and-bolts' meeting to review specific draft edits and to provide substantive written comments to staff.

Next steps: EAC staff and NIST said they will accept detailed written edits and host office hours to answer technical questions; the TGDC agreed to a short follow-up schedule so members can circulate proposed language and prepare for a focused meeting to produce formal recommendations to the EAC.