Re: Comment in Response to Petition of America First Legal Foundation for Rulemaking Before the Election Assistance Commission (August 21, 2025)

Public Rights Project submitted a public comment to the U.S. Election Assistance Commission (EAC) on behalf of 23 current and former local election officials. It urges the EAC to reject a petition that would require proof-of-citizenship documents for the federal voter registration form.

The coalition argues that Congress explicitly rejected this requirement when it passed the National Voter Registration Act. The comment explains that imposing a proof-of-citizenship requirement would discourage voter registration, increase administrative burdens and implementation costs, and create barriers for people who lack easy access to identification documents, including older adults and people experiencing homelessness.

The comment cites real-world examples of disenfranchisement in Arizona, New Hampshire, and Kansas, where ID requirements have led to disenfranchisement.