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Requests for Interpretation

Friday, June 21, 2024

A request for interpretation (RFI) is a means by which manufacturers and voting system test laboratories (VSTLs) may request the U.S. Election Assistance Commission (EAC) to provide a definitive interpretation of Voluntary Voting System Guidelines (VVSG) requirements when, in the course of developing or testing a voting system, the meaning of a particular requirement is ambiguous. 

An interpretation issued by the EAC serves to clarify what a given standard requires and how to properly evaluate compliance. An interpretation does not amend VVSG requirements but serves only to clarify existing requirements. 

More information on the policy, requirements, and procedures for submitting an RFI can be found under section 9 of the EAC Voting System Testing and Certification Program Manual, Version 3.0

RFIs Under Review

The following RFIs have been submitted and are currently under review. For each of these RFIs, either an interpretation will be made or the RFI will be rejected. 

Submitted Date Testing Standard Requirement Title Question
5/30/24 VVSG 2.0 9.1.5-G Preserving Software Independence

1. What is the EAC’s definition of the term “ballot selection area”? Does it refer to the entire area intended for voter marking, often bounded by timing marks, or is it specifically limited to contest option positions?

2. What is the EAC’s definition of the term ‘ballot selection area’ on ballots without timing marks e.g. summary-styled ballots?

3. The conformance language related to requirement 9.1.5-G, which addresses preserving software independence, is inconsistent between VVSG 2.0 and Version 1.3 of the VVSG 2.0 Test Assertions documents.

  • VVSG 2.0 9.1.5-G Requirement Discussion: “To preserve software independence the voting system should not be able to print over or within the ballot selection area because that would cause an undetectable change to the election outcome.”
  • Requirement TA9.1.5-G of the VVSG 2.0 Test Assertions v1.3: “The voting system MUST only be capable of printing outside of the bounds of the ballot selection area.”

Can the EAC confirm whether printing a unique identifier outside the ballot selection area is a mandatory requirement or an optional but recommended feature?

RFIs In Effect

The following RFIs are interpretations that have been made by the Test and Certification Program and remain in effect. 

RFI ID Testing Standard Requirement Effective Date Title Question
2024-03 VVSG 2.0 12.1-D 06/21/2024 Logging of physical connections and disconnections Is it required for voter-facing equipment such as precinct scanners and electronic BMDs to monitor and log the event of accessing a secure container, such as opening and closing the door to a ballot box, during an activated voting state?
2024-02 VVSG 2.0 12.1-B 06/21/2024 Unauthorized physical access alert Is it required for voter-facing equipment such as precinct scanners and electronic BMDs to produce an audible alarm if access to a secure container that stores or transports voting system records is detected during an activated voting state?
2024-01 VVSG 2.0 9.1.5-F 05/03/2024 Unique Identifier

1. Would a central-count scanner capable of adding a unique identifier meet the 9.1.5-F requirement?

2. Are precinct-count scanners required to physically mark the paper ballot to meet this requirement?

3. Can this requirement be accomplished procedurally?

2023-06 VVSG 2.0 3.3-B, 4.1-F 11/03/2023 Extensions to the VVSG 2.0

1. Does VVSG 2.0 requirement 3.3-B prohibit the use of extensions in CDF implementation?

2. VVSG 2.0 Appendix C calls out specific CDF publications, however, some have been revised since VVSG 2.0 was adopted. Which version of the CDF publications are required for implementation?

2023-05 VVSG 2.0 2.7-H 09/29/2023 Battery Backup for Central Count

Does the 2-hour battery backup apply to non-voter facing devices and workstations including the EMS and Central Count?

Given the size and power needs of a central count voting system regarding a battery backup requirement, is a central count voting system required to have a battery back up?

Can a graceful shutdown be done by means of user intervention or whether it must be done by systematic means only

2023-04 VVSG 2.0 9.1.5-F 09/29/2023 Unique Identifier

1. Would a central-count scanner capable of adding a unique identifier meet the 9.1.5-F requirement?

2. Are precinct-count scanners required to physically mark the paper ballot to meet this requirement?

3. Can this requirement be accomplished procedurally?

Superseded, please reference 2024-01 for answers.

2023-03 VVSG 2.0 2.1-A 09/29/2023 Block-Structured Exception Handling Request for clarification for using the Rust programing language which does not explicitly use block structured error handling. Would Rust qualify as using border-logic, meeting the VVSG 2.0 code requirement 2.1-A?
2023-02 VVSG 2.0 1.2-C 08/04/2023 Minimum Ballot Positions

Can the system collectively meet requirement 1.2-C for minimum number of ballot positions, or is each device required to read and tabulate a minimum of 10,000,000 marked or unmarked ballot positions?

If this requirement is to be met collectively by the system, is there a sample minimum for each unique tabulation device?

How will this requirement be applied to modifications to VVSG 2.0 certified systems?

How does this requirement apply to Ballot Marking Devices (BMD) that only read but do not tabulate?

2023-01 VVSG 2.0 10.2.4 02/10/2023 Logging of Ballot Selections May ballot selections that have been changed by an election official (for example, when adjudicating voter intent) be captured in the audit trail?
2021-02 VVSG 2.0 13.2-A 07/12/2021 Source and Integrity of Election Records Does the requirement for digital signing of cast vote records (CVRs) apply to common data format exchanges (CDFs)?
2021-01 VVSG 2.0 4.3-A 05/27/2021 Standard Device Interfaces What is considered the boundary of the hardware interface?
2020-01 VVSG 1.1 V1:, Appendix B.2 08/10/2020 Safety Can safety studies in support of VVSG 1.1 clause be performed, and would be accepted by the EAC, if performed under either of UL/IEC 60950-1 or IEC/UL 62368-1?
2016-02 VVSG 1.1 V1: 10/18/2016 Operating Environmental Testing

1. Does the temperature ranges outlined in a. unreasonably eliminate COTS products (such as tablets and laptops) from being more widely incorporated into voting systems?

2. Is it required that the relative humidity range of 5% - 85% described in VVSG Volume I Section be completed entirely in the Operating Humidity test described in VVSG Volume II Section or can the requirement be fulfilled by testing the range through the combination of tests described in VVSG Volume II Section 5.7.1 – Operating Temperature and Humidity Tests?

3. How many cycles are required for the Operating Humidity

2016-01 VVSG 1.1 V1: 3.2.5.a.iv 06/28/2016 Display Pixel Pitch What minimum display pixel pitch must a manufacturer use to the meet the requirement of Section 3.2.5?
2. Is the standard absolute or can allowances be made similar to those set forth in EAC Decision on Request for Interpretation 2015-04 (Visual Display Characteristics; Minimal display area).
2015-05 VVSG 1.0 V1: 3.2.3.c 12/11/2015 Touchscreen Technology Is it acceptable to use capacitive screen technology requiring human touch if assistive devices are provided to activate the screen?
VVSG 1.1 V1: 3.3.4.d
2015-04 VVSG 1.1 V1: 3.2.5.a.v 10/26/2015 Visual Display Characteristics; Minimal display area What size display panel must a manufacturer use to meet the requirement for a minimum display area of 700 cm2 ? What is the nature of this requirement, and is it an absolute?
2015-03 VVSG 1.1 V1: 09/09/2015 Ballot Reading Accuracy How should VSTLs conduct negative testing with different colored marking instruments?
2015-02 VVSG 1.1


07/23/2015 Certification Test Fixtures Can VSTLs use machine marked ballots, printed by the manufacturer, for Certification testing?
2015-01 VVSG 1.1 V2: 7.2.1 07/15/2015 Testing Breadth How much functional testing is required under VVSG 1.1 Volume 2 requirement 7.2.1?
2013-04 VVSG 1.0 V1: 3.1.1,,, 3.2.3.a 06/13/2013 Usability Testing How should voting system manufacturers interpret the somewhat vague requirements regarding usability testing contained in Section 3.1.1 of the 2005 VVSG?
2013-03 VVSG 1.0 V1: 05/29/2024 Timestamps Shall the proper presentation and implementation of timestamps include the year?
2013-02 VVSG 1.0 V1: 05/15/2013 Audio Presentation Volume Levels Should the default audio presentation volume for the voting system be raised to a higher dB?
2013-01 VVSG 1.0 V1: 03/08/2013 Extensions Clause Does the Extensions Clause, within the Conformance Clause, of the 2005 Voluntary Voting System Guidelines (VVSG), allow for the testing and certification of voting systems outside the traditional DRE, optical scan, and ballot marking device parameters?
2012-06 VVSG 1.0 V1: 7.6.1 10/01/2012 Use of Public Telecommunications Networks and Data Transmission Do the Data Transmission requirements of the 2005 VVSG apply to voting systems that transmit aggregate vote totals?
How should Voting System Test Laboratories and Voting System Manufacturers interpret these requirements?
2012-05 VVSG 1.0 V1: 7.5.1.b 10/01/2012 Public Telecommunications and Cryptography Which 2005 VVSG encryption requirements apply to systems using public telecommunications technologies?
2012-04 VVSG 1.0 V1: 7.4.6.e 08/23/2012 Software Setup Validation Does the 2005 VVSG require a trusted external interface or can voting system software be validated by other means?
2012-03 VVSG 1.0 V1: 9.1.1, 9.1.3 05/30/2012 Configuration Management of COTS Products How should voting system manufacturers handle the volatile nature of the COTS product marketplace while still meeting the configuration management requirements of the VVSG?
2012-02 VVSG 1.0

V1: Sections 2, 6, 7

05/30/2012 Official and Unofficial Results What is the distinction between official and unofficial results?

V2: Sections 1, 2, 6, Appendix A
2012-01 VVSG 1.0 V1: 02/03/2012 Ballot Handling How should a central count optical scan device perform the “halt” function required in VVSG when it detects a multiple feed?
2010-08 VVSG 1.0 V1: 5.2.7.a.ii 11/22/2010 Calling Sequence For documenting the calling sequence of units, are manufacturers required to list every unit in the order in which it is called, or can a “first use” listing of units called be used to meet this requirement?

VVSG 1.0

V2: 5.4.2.i

09/24/2010 Module Length It is not clear as to what source code properties should be used to calculate the number of lines in a module to comply with the requirement that “No modules exceeding 240 lines in length”.

VSS 2002
V2: 5.4.2.i
2010-06 VVSG 1.0 V1: Section 3 06/18/2010 DRE Accessibility Requirements and Other Accessible Voting Stations Shall ballot marking devices be tested to the same accessibility standards of DRE machines under the guidelines found in Section 3 of the VVSG?
2010-05 VVSG 1.0 V1: 1.7 08/18/2010 Modification Testing Which program requirements control with regard to the testing of modifications to an already EAC certified system?
2010-04 VVSG 1.0 V1: 2.1.1 06/24/2010 Functional Requirements with respect to Security Does the first sentence in the Functional Requirements Section with respect to Security allow the security requirements, a through f, in that section to be adhered to solely by administrative practices/procedural safeguards?
VSS 2002 V1: 2.2.1
2010-03 VVSG 1.0 V2: 5.4, 
5.4.2.a - v
06/14/2010 Data Load Shall database definition files be reviewed as source code under the guidelines found in Volume II, Section 5?
2010-02 VVSG 1.0 V1: 5.2.3.d, 5.2.5, 5.2.6, 5.2.7.b - e 05/25/2010 Coding Conventions For any given language implemented by a vendor, is there a limit to the number of coding
conventions that can be referenced for that language?
If the manufacturer chooses to use a coding standard other than the VVSG 2005 are they
then exempt from the coding standards in Volume I and Volume II?
V2: 5.4.2
2010-01 VVSG 1.0 V1: 03/16/2010 Electrostatic Disruption What voltage levels must be tested when performing the ESD test?
VSS 2002 V1:
2009-06 VVSG 1.0

V1: 4.3.3

04/16/2010 Temperature and Power Variation Tests

1. The EAC decision in RFI 2008-1 states that the test length per unit could be as short as 64 hours (of which 48 must be in an environmental chamber). Are the systems to remain voting in the test ballot counting cycle of Section 4.7.1 for the entire period?

2. If these 2 tests are combined as stated in EAC RFI 2008-1 and Appendix C, how can the test method incorporate the statement: For example, a typical system operations scenario for environmental operating hardware tests will consist of approximately 45 hours of equipment operation. Broken down, this time allotment involves 30 hours of equipment setup and readiness testing and 15 hours of elections operations.

3. EAC excerpt from Interpretation: The Reliability test (Section 4.7.2) and the Accuracy (Section criteria are constant hazard or time independent test criteria (The Accuracy criteria for failures are event based but the same logic applies). These are tests where the test criteria are valid for any number of devices provided the test represents a full operational cycle of all operating modes over the specified total hours.

4. What exact operations can be completed in a counting cycle as stated in the manual or an operational cycle as stated in the EAC interpretation? Are cycles different between Temperature Power and Reliability?

V2: 4.7.1,4.7.3, Appendix C4

VSS 2002

V1: 3.4.3

V2: 4.7.1, 4.7.2, Appendix C4

2009-05 VVSG 1.0 V1:, 10/05/2009 T-Coil Requirements What devices are required to provide T-Coil compatibility?
VSS 2002 V1:,
2009-04 VVSG 1.0 V1: 2.1.4, 2.1.5,, 5.4.3 09/29/2009 Audit Log Events What items constitute an “event” as it relates to the requirements of a voting system's audit logging?
VSS 2002 V1:,
2009-03 VVSG 1.0 V1:, 09/28/2009 Battery Back Up for Central Count

EAC Decision on Request for Interpretation 2008-06 does not address whether provision for a graceful shutdown can be done by means of user intervention or whether it has to be done by systematic means only.

In addition, the test sequence requires that the method used to stop the picking of ballots rather than allowing the batch to finish scanning and then providing for a graceful shutdown. With the speed of the coming generation of central scanners, the time needed to complete the input hopper is very short, requiring reasonable backup resources to allow for a graceful shutdown.

VSS 2002 V1:,
2009-02 VVSG 1.0 V1: 3.1.3 08/05/2009 Alternate Languages Must a Voting System be capable of supporting any language covered by law or only those applicable to a particular jurisdiction?
VSS 2002 V1:
2009-01 VVSG 1.0 V1: 7.8.2, 7.9.7 06/25/2009 VVPAT Accessibility Does the VVSG require a VVPAT device to provide audio output from the printed text on the paper? If so, can a barcode or other data be used as “features” to generate the audio?
2008-12 VVSG 1.0 V1: 2.1.5, 12/19/2008 Ballot marking Device/ Scope of Testing

1. Does the ballot marking device use a shared computing platform as intended by Section “Use of a shared computing platform”?

2. Does the ballot marking device “Host Election Software” that would require operating system audit enabled to ensure the accuracy and completeness of election data stored on the system as defined in section


VVSG 1.0

V2: 6.2.1

12/19/2008 Software branch analysis Should the VSTLs' testing include software branch analysis?

VSS 2002
V2: 6.2.1
2008-10 VVSG 1.0


08/28/2008 Electrical Fast Transient Why does the 2005 VVSG Volume I, Section note that the repetition rate for all transient pulses will be 100kHz, as required by IEC 61000-4-4 (2004-02), but Volume II , Section 4.8 sites IEC 61000-4-4 (1995-01) which actually requires testing at 5 kHz?

V2: 4.8

VVSG 1.0

V1: 4.3.8

08/25/2008 Safety Testing How should voting systems be tested to ensure that they meet the safety standards required in both the 2002 VSS and the 2005 VVSG?

VSS 2002
V1: 3.4.8

VVSG 1.0

V1: Glossary

08/01/2008 Bar Code Readers Should a component such as automatic bar code readers be considered part of a voting system and be tested as such?

VSS 2002
V1: Glossary

VVSG 1.0

V1: 2.2.4, 2.2.5, 2.2.6, 2.3.1, 5.4.3 

08/27/2008 Zero Report  Should a voting system warn and report the existence of votes that may be retained in memory or on disk at the start of an election? If so, how must this condition be reported?

V2:1.3, 3.3.1, 3.3.2

VSS 2002

V1: 2.3.4, 2.3.5, 2.3.6, 2.4.1, 4.4.3, 9.4

V2: 3.3.1, 3.3.2

VVSG 1.0


08/29/2008 Battery Back Up for Central Count Given the size and power needs of a central count voting system and in light of the EAC’s recent Request for Interpretation 2008-02 regarding a battery back up requirement, is a central count voting system required to have a battery back up?

VSS 2002

VVSG 1.0

V1: 4.3.2

07/30/2008 Durability How are the VSTLs expected to evaluate this requirement?

VSS 2002
V1: 3.4.2

VVSG 1.0


07/30/2008 Supported Languages Can a voting system meet the requirements of this standard by claiming support for a subset of languages required under Section 203 of the Voting Rights Act, or must every voting system submitted for certification testing support all languages required under Section 203?

VSS 2002

VVSG 1.0

V1:, 5.1.1, 7.2.1 

10/03/2008 Operating System Configuration What is required and appropriate for determining and validating operating system configuration settings?

V2: 3.5

VSS 2002

V1:, 4.1.1, 

V2: 3.5

VVSG 1.0


02/19/2008 Battery Backup for Optical Scan Voting machines Do optical scan systems require battery backup? The actual voting is done via paper and pen/pencil therefore normal voting operations can continue without power.

VSS 2002

VVSG 1.0

V2: 4.7.1, Appendix C

02/06/2008 Temperature and Power Variations

1. How many devices can be utilized to meet these requirements of this test?

2. How many ballots are required to be cast per hour?

3. Should the audio interface be tested also during this timeframe if the system is capable?

VSS 2002
V2: 4.7.1, Appendix C
2007-06 VVSG 1.0 V1: 4.1.1., 2.1.2.c, 2.1.2.f,, 2.4.3.c, 2.4.3.d 11/07/2007 Recording and reporting undervotes Clarification is requested on how undervotes should be recorded and reported in N of M contests. Requestors state that the 2005 VVSG defines an undervote but does not identify how an undervote is to be recorded and reported in the instance where an undervote is less than the maximum number allowed for an N of M contest. The ultimate question for clarification then is how shall undervotes be recorded and reported in a multi- candidate contest in which the voter chooses to cast a vote for less than the allowable number of positions to be filled for the contested office?
2007-05 VVSG 1.0 V1: 4.2.1 11/06/2007 Testing Focus and Applicability Because Section 4.2.1 of the VVSG does not define what is meant by “equivalent of these Guidelines,” the VSTLs and manufacturers are not clear what COTS testing should encompass. The requestors note that while COTS hardware equipment is typically designed to rigorous standards, they are not identical to those required by the VVSG, but encompass the same technical areas such as EMI, temperature ranges, power fluctuations, etc. Interpretation is requested on whether COTS hardware used in a voting system, which has been tested to rigorous Information Technology Equipment (ITE) standards, must also meet all of the VVSG requirements.
2007-04 VVSG 1.0 V1: 3.1.3 10/29/2007 Presentation of Alternative Language Vol. 1 Section 3.1.3 of the 2005 VVSG requires that voting equipment shall be capable of presenting the ballot, ballot selections, review screens and instructions in any language required by state or Federal law. Clarification is requested on the following:
• Which parts of the ballot or ballot selections require language translation?
• Do the requirements apply equally to all languages?
• Do systems that only support languages that use Roman alphabets need to provide translations of candidate names, parties, and office titles?
2007-03 VVSG 1.0 V1: 3.1.1 09/05/2007 Summative Usability Testing Does Vol. 1 Section 3.1.1 of the 2005 VVSG require the manufacturer to submit the summative usability testing report to the VSTL conducting the testing of the voting system or to the EAC?
2007-02 VSS 2002 V1: 4.2.5 05/14/2007 Variable Names Are variable names that differ by only a single character acceptable when they enhance the readability and intelligibility of the program? In particular when the names chosen are consistent and in agreement with the standard names as used by the operating system, industry accepted standards, or publicly documented interfaces or algorithms?
2007-01 VVSG 1.0 V1: 05/23/2007 Partial Vision For AutoMARK Technical Systems (ATS), is the current keypad design acceptable as shown?
If the keypad is specifically designed for blind voters and not partially sighted voters, does it fall outside Section (e)?

Rejected RFIs

The following RFIs have been rejected by the Testing and Certification Program. A reason for each rejection has been provided below. 

Testing Standard Requirement Title Question Explanation of Rejection
11/28/2023 VVSG 2.0  9.1.5-F Pre-print Unique Identifier For paper-based mail-in voting, is it permissible to print a unique randomly generated ballot identifier onto a ballot before it is mailed to the voter, and would this satisfy requirement 9.1.5-F (ability to add a unique identifier to the ballot after it is cast)? Requirement 9.1.5-F within VVSG 2.0 is unambiguous in that it requires the system to have capability to add a unique identifier after the voter has cast their ballot. This is at the time of ballot casting in a polling place or when scanning at central location. Printing the unique identifier prior to providing the ballots to the voter is contrary to requirement 9.1.5-F, and therefore does not satisfy the intent.
11/28/2023 VVSG 2.0

9.1.1-A &


Software Independence Does a DRE (Direct Recording Electronic) vote capture electronic device used with a VVPAT (Voter-Verifiable Paper Audit Trail) vote capture printing device achieve conformance to the 9.1.1-A and 9.1.5-A software independent requirements of the VVSG V2.0? Without more specific information on how the VVPAT is considered a voter verifiable paper record with respect to all VVSG 2.0 requirements, that is more of a hypothetical design evaluation rather than an actual controversy or unsettled ambiguity.