EAC Comment in Opposition to DPOC Requirement

In July, anti-voter group America First Legal Foundation (AFL) submitted a petition for rulemaking to the Election Assistance Commission (EAC), requesting the EAC amend the federal voter registration form to require Americans to show a passport or other citizenship documents when registering to vote. These show-your-papers requirements create unnecessary barriers that are particularly hard on students, among other communities. Fair Elections Center is submitting this comment to oppose adding barriers to voter registration. As expressed in our comment, Elections Assistance Commission (EAC) should not—and cannot—make the changes to the national mail voter registration form to add a show your papers proof requirement to register to vote as requested in the Petition for Rulemaking submitted by America First Legal. Such changes would violate federal laws.

Specifically, adopting a DPOC requirement would plainly contradict prior EAC decisions, as well as responses to prior requests from states to add a DPOC requirement to their state instructions on the Federal Form. EAC declined to establish documentary proof requirements for naturalization and citizenship respectively because it was not necessary to validate the eligibility of an applicant and would not serve any additional election security purpose than a citizenship attestation requirement alone. Critically, the EAC should decline to add this requirement now because it will disenfranchise many of the millions of otherwise eligible voters in the United States who lack access to DPOC.

National Mail Voter Registration Form Comment

In April of 2025, Fair Elections Center submitted a comment to the Election Assistance Commission, urging the commission to avoid making changes outlined in the President’s Executive order, “Preserving and Protecting the Integrity of American Elections,” to the national mail voter registration form. Making these changes would, FEC noted, would violate the NVRA and the Administrative Procedure Act.

SAVE Act (2025)

Fair Elections Center opposes the Safeguard American Voter Eligibility (SAVE) Act, which would require every American to provide documentary proof of citizenship to register or re-register to vote. Requiring oftentimes hard-to-get and expensive documents make it harder for citizens to vote, and doesn’t solve any problems with our elections. Recent studies show that around ten percent of voting-eligible Americans do not have documents to show their citizenship. Those citizens are more likely to be women, low income people, and from communities of color.

Youth Voting Rights Act

Just like the 15th and 19th Amendments prohibit the denial of the right to vote on account of race, color, previous condition of servitude, and gender, the 26th Amendment to the U.S. Constitution prohibits denying the right to vote based on age to anyone over the age of 18. However, 50 years later the full promise of the 26th Amendment remains unfulfilled. Much like the Voting Rights Act was needed to fully realize the 15th Amendment’s purpose, Sen. Warren and Rep. William’s Youth Voting Rights Act is crucial to finally realizing the purpose of the 26th Amendment and creating structures that actually welcome-in the newest members of our democracy.

For the People Act of 2021

With the introduction of the For the People Act in the U.S. Senate (S. 1), Congress is one step closer to protecting the most sacred tenet of our democracy, the right to vote. The bill is a sweeping reform package that will strengthen that hallowed right to vote, especially in Black, brown and indigenous communities, as well as for the elderly and students.

Student Bill of Rights

Students Learn Students Vote Coalition partners — through the Youth Voting Rights Subcommittee — identified core policy priorities that, if equitably implemented, would ensure every eligible college student and young person can vote under fair, equitable and accessible conditions that welcome them into the democratic process, regardless of their background or location:

John Lewis Voting Rights Advancement Act (2024)

Statement in support of the John Lewis Voting Rights Advancement Act which will restore and strengthen the Voting Rights Act, repairing damage done by the Supreme Court and modernizing the most successful civil rights law in history.