CEC Submits Second-Round EAVS Comments to EAC

The Center for Election Confidence (CEC) submitted comments to the U.S. Election Assistance Commission (EAC) in response to its second-round EAVS public comment period, which covered an updated draft of the EAC’s 2026 Election Administration and Voting Survey (EAVS). CEC submitted comments during the EAC’s first-round EAVS public comment period on March 16, 2026.

CEC encourages the EAC to include additional questions in the 2026 EAVS concerning voter list maintenance, voting by mail policies and postmarking practices, and cybersecurity planning and preparedness. Broadly, CEC also urges the EAC to examine the survey as a whole to ensure that the burden imposed on state officials is justified by the utility of the information requested and by whether such information is otherwise available outside of the EAVS.

With respect to list maintenance, CEC thanks the EAC for incorporating questions concerning the sources of information states use for inter-state exchange of voter registration information, which CEC suggested in its March 16, 2026, initial comments. CEC further encourages the EAC to collect additional information concerning the total number of inactive registrants, registrants who voted in at least one federal election in an eight-year period, registrants removed under Section 8 of the National Voter Registration Act, and registrants who respond or fail to respond to confirmation notices, as well as with respect to the use of state and federal databases for list maintenance activities. CEC’s comments explain that collecting this information would benefit state officials, Congress, and the public by providing quality, trustworthy information in a single, identified repository.

CEC also renews its suggestion that the EAC include questions relating to voting by mail statutes, policies, and practices, including questions concerning postmarking, transmission and receipt deadlines, and timely acceptance of ballots. CEC highlights recent changes to United States Postal Service postmarking practices and explains that such changes may introduce uncertainty into election administration in jurisdictions that rely on postmarks to determine whether a ballot was timely cast. To that end, CEC encourages the EAC to include questions concerning approximate transmission timelines for ballots sent by mail and ballots returned by mail, to the extent such information has been or may be collected by election officials.

Finally, CEC encourages the EAC to include questions relating to cybersecurity planning, preparedness, and resources. CEC notes that cybersecurity incidents involving ransomware, data exfiltration or manipulation, and privilege escalation with respect to Internet-connected non-voting equipment can cause voter distrust, panic, and confusion concerning the trustworthiness of the election process. CEC explains that state officials and Congress should have access to quality, trustworthy information concerning the current status of these important defenses against bad actors.

CEC urges the EAC to include these suggested items in the 2026 Election Administration and Voting Survey.