Should documented proof of citizenship be required for voter registration?
US Election Commission accepting comments until Oct. 20
Nonprofit America First Legal sent a “petition for rulemaking” to the US Election Assistance Commission in July asking it to amend the federal voter registration form to require “Documentary Proof of Citizenship.”
Part of EAC’s decision making process about this matter is to ask for public comments, which is taking place now at Regulations.gov.
You too can take part in that process and give your comments by clicking on “Comment” on this page at Regulations.gov.
The Regulation.gov website today says the government shutdown will not impact its collection of comments: “During the lapse in federal government appropriations, Regulations.gov will continue to operate.”
In its petition America First Legal gave background information including problems with foreigners appearing on voter rolls (paragraph 8 in filing):
There are numerous instances of foreigners appearing on voter rolls.
For example, a North Carolina audit before the 2014 midterm elections found that 1,454 registrants were not naturalized before Election Day.14 Further investigation showed that 89 of these registrants showed up to vote, and 24 were challenged, with 11 challenges being sustained.
Similarly, in 2019, Texas identified nearly 100,000 possible foreigners on their voter rolls, of which around 58,000 may have voted in previous elections. Since 2021, the State of Texas has removed over 6,500 potential foreign citizens from its voter rolls. Of those 6,500 foreign citizens, 1,930 actually voted.
Between January 16, 2024, and August 13, 2024, the office of Alabama Secretary of State Wes Allen identified and purged from voter rolls 3,251 foreign citizens who were registered to vote in the State.
On August 21, 2024, Ohio Secretary of State Frank LaRose announced that his office had identified 597 foreign citizens who were registered to vote in Ohio and that 138 of them had actually voted.
On August 7, 2024, Virginia Governor Glenn Youngkin issued an executive order requiring more thorough list maintenance procedures because “between January 2022 and July 2024, records indicate we removed 6,303 non-citizens from the voter rolls.”
The Heritage Foundation’s database includes 1,499 proven instances of voter fraud, with 1,275 criminal convictions. This data highlights significant vulnerabilities in the current voter registration system.
This data highlights significant vulnerabilities in the current voter registration system.
Evidence of Non-Citizens Registering in EAC EAVS Reports
The EAC released its Election Administration and Voter Survey (EAVS) 2024 Comprehensive Report in June with information about the Nov. 2024 election, which included comments about non-citizens voting or attempting to register or vote in 2024.
EAVS Reports from 2016 through 2022 all showed similar comments and concerns about non-citizens.
Sample comments from 11 states in the EAVS 2024 report (caps are from original EAVS data files) related to citizenship:
Arizona, Field A11l_Other, “CITIZENSHIP PROOF NEEDED”
Kansas, Fields A12i_Other, A12j_Other: “PROOF OF CITIZENSHIP NOT SUBMITTED”
Florida, Fields A11lOther: “VOTER MAY NOT BE A US CITIZEN.” or “VOTER NOT A CITIZEN”
Georgia, Field A4-A9Comments: “VOTER WAS CANCELED AS PART OF A CHALLENGE HEARING, CLERICAL ERROR, OR BECAUSE THEY SIGNED A JURY AFFIDAVIT STATING THAT THEY WERE NOT A US CITIZEN.”
Idaho, Field A11m_Other: “CITIZENSHIP VALIDATION”
Maryland, Field A12i_Other, “NOT ELIGIBLE OR NON-CITIZEN”
Michigan, Field A12i_Other, “CLERK DETERMINED THAT VOTER DID NOT MEET EITHER AGE, CITIZENSHIP, OR RESIDENCY REQUIREMENT.”
New York, Field A12i_Other, “NON CITIZEN, MISC, RESIGN, ADDRESS, INCOMPLETE, FAMILY REQUEST”
Ohio, Field A12i_Other, “NON-CITIZEN: PERSON INDICATED THEY WERE A CITIZEN ON THEIR VOTER REGISTRATION CARD BUT THE SECRETARY OF STATE’S OFFICE LATER FOUND THAT INFORMATION TO BE FALSE.”
South Dakota, Field A3g_Other, “INVALID - NON-CITIZEN OR FELONY OR MISSING DATA”
Texas, Field A12Comments, “OTHER CANCELS - FPCA- EXPIRED, NON US CITIZEN”
Two examples from all years …
From 2016 to 2024 four states reported “NON-CITIZENS” in a number of EAVS fields:
States: Arizona, Texas, Ohio, South Dakota
Fields: A11i_Other | A11h_Other | A12i_Other | A4l_Other | A5l_Other | A6l_Other | A7l_Other | A8l_Other | A9l_Other | A3g_Other
From 2016 to 2024 nine states reported: “NOT A CITIZEN”
States: Alabama, Colorado, Delaware, Florida, New York, Ohio, South Dakota, Tennessee, Texas
Fields: A11i_Other | A11h_Other | A9i_Other | A9h_Other | A9j_Other | A7k_Other | E2l_Other | A12j_Other | A3g_Other
Methodology
All cells in the five EAVS Excel file reports from 2016 through 2024 were scanned for the word “citizen” anywhere in a response. Earlier reports were not considered because of formatting changes in the files.
Initially, there were 203 unique phrases with “citizen” extracted from the five files, but 32 were deemed irrelevant to the analysis, like “senior citizens” or “dedicated citizens”.
The cells with the remaining 171 “citizen” phrases were extracted from all five EAVS reports, which resulted in 8842 being selected.
These 8842 comments were aggregated by unique combinations of states and years to create the file EAC-EAVS-2016-2024-Citizen-Hits-Unique-Values.xlsx with 171 lines for inspection.
Review this summary Excel file here:
Related
“Petition for Rulemaking” from America First Legal to the US Election Assistance Commission, July 16, 2025.
See this page for information about “state file” EAVS 2024 extracts specific to a state instead of the enormous 2024 EAVS file of 6461 jurisdictions by 535 columns. Technical types might start here at GitHub.
Locally we will have opportunity to ask questions of S.O.S Scott Schwab, soon. How many times does this issue appear in Kansas Data? (Not citizen) mr Schwab is smooth talker, IMO. He should be NO WHERE near the Governors mansion in Kansas!