Voluntary Voting System Guidelines

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The Voluntary Voting System Guidelines (VVSG) are guidelines adopted by the United States Election Assistance Commission (EAC) for the certification of voting systems. The National Institute of Standards and Technology's Technical Guidelines Development Committee (TGDC) drafts the VVSG and gives them to the EAC in draft form for their adoption.

Contents

Guidelines (2021) [1]

"The Guidelines allow for an improved and consistent voter experience, enabling all voters to vote privately and independently, ensuring votes are marked, verified and cast as intended, and that the final count represents the true will of the voters." [2]

The voting system

"Equipment (including hardware, firmware, and software), materials, and documentation used to enact the following functions of an election:

  1. define elections and ballot styles,
  2. configure voting equipment,
  3. identify and validate voting equipment configurations,
  4. perform logic and accuracy tests,
  5. activate ballots for voters,
  6. record votes cast by voters,
  7. count votes,
  8. label ballots needing special treatment,
  9. generate reports,
  10. export election data including election results,
  11. archive election data, and
  12. produce records in support of audits." [3]


All voting systems must also have [4] :

  1. Permit the voter to verify (in a private and independent manner) their choices before their ballot is cast and counted.
  2. Provide the voter with the opportunity (in a private and independent manner) to change their choices or correct any error before their ballot is cast and counted.
  3. Notify the voter if they have selected more than one candidate for a single office, inform the voter of the effect of casting multiple votes for a single office, and provide the voter an opportunity to correct their ballot before it is cast and counted.
  4. Be accessible for individuals with disabilities in a manner that provides the same opportunity for access and participation (including privacy and independence) as for all voters.
  5. Provide alternative language accessibility pursuant to Section 203 of the Voting Rights Act [VRA65].

Principles [5] :

Principle 1 - High Quality Design

  • Functional equipment requirements are organized as phases of running an election:
    • Election and Ballot Definition
    • Pre-election Setup and logic and accuracy (L&A) testing
    • Opening Polls, Casting Ballots
    • Closing Polls, Results Reporting
    • Tabulation, Audit
    • Storage
  • Requirements dovetail with cybersecurity in areas including:
    • Pre-election setup
    • Audits of barcodes versus readable content for ballot marking devices (BMDs)
    • Audits of scanned ballot images versus paper ballots
    • Audits of Cast Vote Record (CVR) creation
    • Content of various reports
    • Ability to match a ballot with its corresponding CVR
  • Guidance relevant to testing and certification has been moved to the EAC testing and certification manuals.

Principle 2 - High Quality Implementation

  • Adds requirement to document and report on user-centered design process by developer to ensure system is designed for a wide range of representative voters, including those with and without disabilities, and election workers

Principle 3 – Transparent

  • Addresses transparency from the point of view of documentation that is necessary and sufficient to understand and perform all operations

Principle 4 - Interoperable

  • Ensures that devices are capable of importing and exporting data in common data formats
  • Requires manufacturers to provide complete specification of how the format is implemented
  • Requires that encoded data uses publicly available, no-cost method
  • Uses common methods (for example, a USB) for all hardware interfaces
  • Permits commercial-off-the-shelf (COTS) devices as long as relevant requirements are still satisfied

Principle 5 - Equivalent and Consistent Voter Access

  • Applies to all modes of interaction and presentation throughout the voting session, fully supporting accessibility

Principle 6 - Voter Privacy

  • Distinguishes voter privacy from ballot secrecy and ensures privacy for marking, verifying, and casting the ballot

Principle 7 - Marked, Verified, and Cast as Intended

  • Updates voter interface requirements such as font, text size, audio, interaction control and navigation, scrolling, and ballot selections review
  • Describes requirements that are voting system specific, but derived from federal accessibility law

Principle 8 - Robust, Safe, Usable, and Accessible

  • References, Section 508 Information and Communication Technology (ICT) Final Standards and Guidelines [USAB18] and Web Content Accessibility Guidelines 2.0 (WCAG 2.0) [W3C10]
  • Updates requirements for reporting developer usability testing with voters and election workers

Principle 9 - Auditable

  • Focuses on machine support for post-election audits
  • Makes software independence mandatory
  • Supports paper-based and end-to-end (E2E) verifiable systems
  • Supports all types of audits, including risk-limiting audits (RLAs), compliance audits, and ballot-level audits

Principle 10 - Ballot Secrecy

  • Includes a dedicated ballot secrecy section
  • Prevents association of a voter identity to ballot selections

Principle 11 - Access Control

  • Prevents the ability to disable logging
  • Bases access control on voting stage (pre-voting, activated, suspended, post-voting)
  • Does not require role-based access control (RBAC)
  • Requires multi-factor authentication for critical operations:
    • Software updates to the certified voting system
    • Aggregating and tabulating
    • Enabling network functions
    • Changing device states, including opening and closing the polls
    • Deleting the audit trail
    • Modifying authentication mechanisms

Principle 12 - Physical Security

  • Requires using only those exposed physical ports that are essential to voting operations
  • Ensures that physical ports are able to be logically disabled
  • Requires that all new connections and disconnections be logged

Principle 13 - Data Protection

  • Clarifies that there are no hardware security requirements (for example, TPM (trusted platform module))
  • Requires Federal Information Processing Standard (FIPS) 140-2 [NIST01] validated cryptographic modules (except for end-to-end cryptographic functions)
  • Requires cryptographic protection of various election artifacts
  • Requires digitally signed cast vote records and ballot images
  • Ensures transmitted data is encrypted with end-to-end authentication

Principle 14 - System Integrity

  • Requires risk assessment and supply chain risk management strategy
  • Removes non-essential services
  • Secures configurations and system hardening
  • Exploit mitigation (for example, address space layout randomization (ASLR) data execution prevention (DEP) and free of known vulnerabilities
  • Requires cryptographic boot validation
  • Requires authenticated updates
  • Ensure sandboxing and runtime integrity

Principle 15 - Detection and Monitoring

  • Ensures moderately updated list of log types
  • Detection systems must be updateable
  • Requires digital signatures or allowlisting for voting systems
  • Requires malware detection focusing on backend PCs

History

Timeline

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References

  1. "VVSG 2.0". Election Assistance Commission. c. 2021.
  2. p. 6
  3. p. 10
  4. p. 10-11
  5. p. 14-17
  6. "Voluntary Voting System Guidelines - Voting Equipment - US Election Assistance Commission". www.eac.gov. Retrieved March 28, 2018.
  7. "U.S. Election Assistance Commission Adopts New Voluntary Voting System Guidelines 2.0 | U.S. Election Assistance Commission". www.eac.gov. Retrieved 2022-12-01.