Elections: How Elections Work (Election Equipment Certification, Security & Testing)
June 22, 2026
Author’s Note: In light of the President’s continued assault on the integrity of US elections, I have started this new series “How Elections Work.” It’s designed to address the disinformation, misinformation, lack of information, and outright lies that have poisoned American’s attitudes towards US elections in the last 6+ years. Articles already posted under this subheading include:
Ballot Printing & More,
California Vote Counting Process 1 & 2,
Detailed Overview of Procedures (i.e., a Look at Election Administration Manuals), and
Questions to Ask the President About the “Rigged” 2020 Election.
I strongly encourage you to share these documents widely both on and off social media. The fate of democracy hangs in the balance. P.S. If you have any questions about election administration do not hesitate to ask them.
A. Election Equipment Certification
Based on comments on social media, many/most people may not know that hardware and software used in the conduct of US elections must complete a federal and/or state-based certification process before it may be used in any election.
The Help America Vote Act (HAVA) of 2002[1] led to the establishment of the U.S. Election Assistance Commission (EAC) and mandated the Commission to oversee the certification, decertification, and recertification of voting systems.[2] This legislation marked the first instance of federal oversight in these activities and resulted in the creation of the EAC’s Voting System Testing & Certification Program (T&C).
…. The EAC’s Election Technology Division encompasses the Voting System Testing & Certification Program (T&C),[3] Election Supporting Technology Evaluation Program (ESTEP), and Field Services Program (FSP). These programs support state and local election officials by ensuring the reliability and security of voting systems and election-supporting technologies used in national elections.[4]
The National Institute of Standards and Technology (NIST) also assists in this work.[5]
The Help America Vote Act (HAVA) of 2002 (Public Law 107-252) was signed into law by President Bush on October 29, 2002. Section 231 of HAVA requires the Director of NIST to provide for the accreditation of laboratories that conduct testing on the hardware and software of voting systems. In response to the HAVA, the National Voluntary Laboratory Accreditation Program (NVLAP) has established a program for laboratories that test voting systems.
The Voting System Standards of 2002 (VSS-2002) were approved for release and publication by the Federal Election Commission on April 30, 2002. The VSS-2002 provides for entities called “Independent Test Authorities” (ITAs): laboratories that test to the requirements of the VSS-2002 and certify products that meet the requirements. ITAs were approved by the National Association of State Election Directors. Testing is now conducted by NVLAP-accredited Voting System Testing Laboratories (VSTLs). Product certification is performed by the U.S. Election Assistance Commission (EAC).
On December 13, 2005, the EAC adopted the Voluntary Voting System Guidelines of 2005, known as VVSG 1.0. The VVSG 1.0 increased security requirements for voting systems and expanded access, including the opportunity for disabled individuals to vote privately and independently. On March 31, 2015, the EAC adopted the VVSG 1.1, clarifying some requirements and making them more testable.
Following the adoption of VVSG 1.1, a public working group process was developed to help inform NIST and EAC on the development of the next iteration of voluntary voting system guidelines.. On February 10, 2021 the (EAC) announced the adoption of the Voluntary Voting System Guidelines (VVSG) 2.0, improving the manufacturing and testing of voting machines. The EAC Commissioners unanimously approved the VVSG 2.0 documents including the Principles and Guidelines and Requirements, as well as approving the Testing and Certification Program Manual and the Voting System Test Laboratories (VSTL) Manual.
VSTLs are required to meet the requirements in ISO/IEC 17025, General requirements for the competence of testing and calibration laboratories, NIST Handbook 150, NVLAP Procedures and General Requirements, NIST Handbook 150-22, NVLAP Voting System Testing, HAVA requirements, VVSG requirements, and any other criteria deemed necessary by the EAC. VSTLs should be familiar with the election and voting communities including the National Association of State Election Directors (NASED) and the National Association of Secretaries of State (NASS).
NIST Handbook 150-22 augments ISO/IEC 17025, and NIST Handbook 150, by gathering technical requirements of the laboratory accreditation program (LAP) . Technical requirements are explained to indicate how NVLAP criteria are applied for accreditation under the Voting Systems LAP.
States supplement the federal standards with their own. Ohio, for example, established a Board of Voting System Examiners to manage its certification process.[6] That panel reviews and approves/disapproves ballot marking devices, ballots on demand systems, electronic poll books, and voter registration systems.
Texas election officials outline their process as follows:
The Texas Election Code requires all voting systems to be approved by the Secretary of State before they may be used in any election. The voting system vendor must submit an application to certify new voting systems and to certify modified voting systems.
The Secretary of State requires new systems and modifications to previously-certified systems be qualified by the Election Assistance Commission (EAC), with 2002 Voting System Standards/guidelines (VSSG) or newer, prior to being submitted for examination. [7]
Prior to submitting their application, the vendor should complete the Notice of Intent to Seek Certification. The purpose of this form is to secure one of the available dates for testing of the system. If a vendor would like to apply for certification after the deadline for submitting the Notice, they may still do so, but they should first contact the Secretary of State to determine what testing dates are still available.
The vendor applying for certification must complete and deliver application forms (Form 100, Form 101, and if applicable, Form 100 Schedule A), user operating and maintenance manuals, training material, final report(s) from an independent testing laboratory accredited by the EAC, a change log detailing changes from any previously-certified system or component, and application fee(s), to the Secretary of State no later than 45 days prior to examination.
The certification fee for a new election management system, tabulation device, electronic ballot marker, and other complex component(s) of a system is $3,000. The certification fee for a modification of a voting system shall be determined by the Secretary of State according to the complexity of the modification. This fee is used to administer the certification process and compensate the independent examiners for their time and expertise.
After all the above-listed materials have been received by this office, a time will be set to physically examine the voting system(s). Examiners will receive a packet of the submitted material, for their review, in advance of the physical examination. Examinations of voting systems will take place at the Office of the Secretary of State in Austin, Texas, unless extenuating circumstances provide otherwise.
The Secretary of State’s Office will supply sample ballot templates to the applicant after their application packet has been received. The applicant shall furnish a sufficient number of sample ballots, designed from the templates provided by the Secretary of State, at least two weeks prior to the examination. The sample ballots will allow examiners to test the accuracy of the voting system(s).
During the exam process, the applicant must demonstrate an installation of the software/firmware by using the Secretary of State’s copy of the software/firmware received from the independent testing laboratory. The applicant must demonstrate their system and explain how it meets all the requirements set forth in Form 101. The applicant must be prepared to answer technical, procedural, and security questions from the examiners. If a central count or central accumulator system is being examined, it must be demonstrated that it has the ability to produce and print a real time continuous audit log.
Each examiner will submit a written report to the Secretary of State stating his findings for each voting system no later than 30 days after examination. The examiner reports will be posted to the Secretary of State web site and a public hearing will be held to receive public comments regarding the approval or disapproval of the system examined.
The Secretary of State will review the examiner reports and information received at the public hearing, prior to making the decision to approve or disapprove the voting system(s). [8]
[See the attached PDF for the remainder of this long article and the many graphics posted with it.]
