Finish the Fight: Modernize Voter Roll Cleanup
INTRODUCTION
For the last thirty years, voter roll maintenance has relied heavily on the United States Post Office National Change of Address (NCOA) database and the Social Security Death Index (SSDI). In 1993, when the National Voter Registration Act was passed, these were the gold standards. That is no longer the case. Both systems now lag behind real-time changes: the NCOA depends on voluntary address updates, while the SSDI often omits recent deaths. Federal requirements remain rooted in 1993, while Americans move more often and modern data systems update continuously.
List maintenance became a national issue around 2012, during the presidential election cycle that saw lawsuits in Florida, Colorado, and Virginia over outdated and duplicate voter rolls. Since then, researchers, attorneys, and grassroots advocates have investigated how best to identify needed corrections within voter registration systems. These cases exposed long-standing issues like duplicate registrations, deceased voters remaining on rolls, and delays in removing those who relocated.
The broader election integrity movement in the United States grew out of the post-2012 election, as policymakers, litigators, and grassroots organizations began focusing on voter-roll accuracy as a cornerstone of public trust. Voters move and die in this country every single day, yet they remain on the rolls. This constant change in voters’ status has forced even the most experienced advocates to react to problems only after they appear, rather than prevent them at the source. This is not their fault; it simply shows how outdated our systems have become.
AFPI consulted with leaders within the election integrity movement to present a solution to America’s persistent struggles with voter roll maintenance. This issue brief outlines the root causes and consequences of inaccurate voter rolls and presents original and timely solutions to prevent future problems. AFPI contends that litigation and voter challenges are no longer viable or comprehensive solutions. Instead, American election officials must embrace commercial data to validate and actively monitor voter rolls.
THE DYNAMIC PROBLEM
Federal requirements for list maintenance are vague, slow, and do not account for modern technology beyond what the National Voter Registration Act of 1993 (NVRA) envisioned. A voter roll can go out of date almost as soon as it is received. Data systems across states are fragmented and rarely synchronized, making it impossible to automatically track when voters move or die. A lawsuit built on strong data can settle before any precedent develops, while weak or incomplete data can doom a legitimate claim and leave the same errors in place. Because these disputes are resolved case by case, officials feel pressure to act until forced by litigation, and frustrated grassroots advocates often respond with mass voter challenges instead.
The debate itself has become divided. Left-leaning critics argue that list maintenance risks removing eligible voters, while conservatives warn that inaccurate rolls open the door to fraud and distrust. The real issue is that the system was built for another era—one of paper records, slower mobility, and limited technology. Today’s elections depend on data that can change by the day, but most states still operate on procedures designed more than thirty years ago. Modern list maintenance demands constant updates and real-time verification tools that most jurisdictions simply do not have. The longer the system stays reactive instead of proactive, the more vulnerable it becomes to errors and mistrust.
A MODERN SOLUTION
The good news is that a solution already exists. Commercial data can bridge the gap between outdated federal tools and modern mobility. It answers questions regarding active management and validation of voter records while addressing concerns about accuracy and inclusion. Even if Congress never modernizes the NVRA, state and local officials already have the means to improve list maintenance now.
Commercial data provides election officials with what older systems lack—speed, reliability, and depth. These are not static databases but gateways that pull live and historical data on an individual from verified sources such as credit bureaus, address histories, and public records. They reveal full names, addresses, dates of birth, and Social Security information to confirm whether a voter’s record is current and legitimate. The same type of data is used every day in mortgage origination, background checks, and financial transactions. These tools give election offices the ability to validate voter information in real time, rather than waiting for the postal service to report a change of address months later.
Commercial data systems transform list maintenance from a reactive process into a proactive one. Instead of waiting for returned mail, undeliverable ballots, or lawsuits to expose errors, registrars can identify and correct inaccuracies before they create problems. Cleaner voter rolls mean fewer rejected ballots, faster processing, and lower administrative costs. More importantly, they strengthen public confidence in the outcome of every election.
PROVEN IN PRACTICE
Commercial data is already in use. There is a fast-growing body of evidence in support.
Tarrant County, Texas
In 2025, Tarrant County (home to Fort Worth) disclosed that it signed a contract with Thomson-Reuters for its CLEAR skip-tracing system, a commercially available data tool used in law enforcement and financial compliance to verify identities and addresses. “This is kind of a way that we can check the information we have against the most current information available,” Elections Administrator Clint Ludwig told local news outlets. County officials explained it would help demystify regular voter list maintenance operations when citizen challenges are filed in bulk before a major election.
Orange County, California
Orange County is broadly considered the first jurisdiction to utilize some element of credit bureau data to help maintain the voter roll since 2010. The county contracted with Experian (a credit bureau) to supplement its National Change of Address observation tools. The voter roll was periodically fed to Experian to identify which name and address combinations positively matched to subsequent addresses. With Experian’s results, Orange County sent postcards to affected registrants asking them to confirm the data. Over eight years, the county identified 401,000 address conflicts and was able to voter-confirm more than 74,000 move-aways, speeding their removals from the roll.
West Virginia
Under the care of then-Secretary of State Mac Warner, West Virginia engaged with Experian for a pilot project. Officials processed voter data for new “Best” addresses and arrived at 16,000 registrants needing a confirmation mailing. Twenty-five percent of the mailings returned undeliverable, setting those registrations on track for removal from the voter roll.
2025 Federal Study
Beginning in 2023, the U.S. Election Assistance Commission developed a coordinated study with Experian and interested state and local governments to recreate the West Virginia and Orange County “Best Address” pilots. In these pilots, a “Best Address” refers to the most current and verifiable residential address for a registrant, identified by comparing voter rolls with commercial data sources such as credit and utility records. In its August 2025 report, jurisdictions that fed at least 10% of a roll to Experian saw 7%–22% of registrant addresses lead to more recent “Best” addresses, compared to 2%–7% using the National Change of Address. One statewide sample revealed 2.6 million registrants flagged with “Best” addresses not on the voter roll at the time. The EAC concluded commercial data can be seen as “an additional new tool … for list accuracy and update processes.”
The bottom line is that commercial data beats legacy tools, identifies better addresses faster, and gives election officials a proven way to modernize list maintenance.
REFORMING FEDERAL DATA SYSTEMS
While states are taking steps to modernize their voter rolls, the federal government’s own data collection still lags behind. The Election Administration and Voting Survey (EAVS), managed by the U.S. Election Assistance Commission, is among the most comprehensive national dataset covering voter registration, mail voting, and election administration. In theory, it is the government’s central source of information about how well voter rolls are maintained. In practice, EAVS suffers from major reliability problems that prevent it from being used with confidence.
Participation in the EAVS is largely voluntary. Local election offices can skip questions, submit incomplete answers, or misreport data without consequence. Because there is no mandatory reporting standard or independent quality check, the results often contain errors or inconsistencies that misrepresent local performance. In some cases, counties have reported more registered voters than eligible adults, or voter removal figures that are implausibly low. These errors have even appeared in official filings to the federal government, later forcing corrections after lawsuits or public scrutiny.
Such inconsistencies create a serious credibility gap. Policymakers, journalists, and courts often cite EAVS data as evidence of compliance with federal law, but when the data itself is unreliable, it undermines oversight and public trust. For example, when questions about undeliverable or “unknown status” mail ballots produced troubling figures in previous surveys, those categories were quietly removed from later editions. Without consistent definitions or verification, trends over time cannot be accurately measured.
Congress can fix this. Lawmakers should require states to provide complete and verifiable responses to EAVS questions and direct the Election Assistance Commission to implement stronger data-quality controls. A model already exists: Section 1051 of H.R. 1 (117th Congress) would have required annual voter list maintenance reports from state election officials to the EAC. Requiring full participation would give Congress, researchers, and the public a reliable foundation for evaluating election administration nationwide. Clean, accurate data should not be optional.
CONCLUSION AND POLICY RECOMMENDATIONS
When the National Voter Registration Act was passed in 1993, the tools for maintaining accurate voter rolls were limited to paper records and postal updates. Today, Americans move more frequently, technology evolves by the day, and elections depend on real-time data that most states still cannot access. The system built for the 1990s cannot meet the demands of the 2020s.
To keep voter rolls accurate, transparent, and trusted, election officials and lawmakers should consider the following:
- States should adopt Commercial Data for List Maintenance
State and local election offices should begin testing and integrating commercial data tools such as those used in Tarrant County, Orange County, and West Virginia. These resources provide continuous, verified updates that reveal address changes, duplicate registrations, and deceased voters faster than traditional postal files. Commercial data allows registrars to identify problems before they affect an election.
- States should establish State Standards for Modern Maintenance
States should update list-maintenance statutes to reflect the use of modern data systems. Legislatures can set clearer thresholds for when a registrant is confirmed as having moved, died, or become ineligible. Matching standards for names, addresses, and signatures should be tightened once more accurate tools are in use. Commercial data should be used first; undeliverable mail should be the last resort.
- Congress should reform Federal Data Collection
Congress should make participation in the Election Administration and Voting Survey mandatory and direct the Election Assistance Commission to verify and reconcile data before publication. Federal reports should be consistent, comparable, and complete so that states, researchers, and the public can rely on them.
Clean voter rolls are not a partisan issue; they are an administrative responsibility. By moving from outdated, reactive systems to proactive, data-driven tools, election officials can restore public confidence and ensure that every legitimate vote is counted once and only once.