Introduction

Center for Election Confidence, Inc. (“CEC”) is a non-profit organization based in Arlington that promotes ethics, integrity, and professionalism in the electoral process. CEC works to ensure that all citizens can vote freely within an election system of reasonable procedures that promote election integrity, prevent vote dilution and disenfranchisement, and instill public confidence in election systems and outcomes. 

CEC submits these comments concerning 1 Va. Admin. Code 20-100 [hereinafter VAC] to the Virginia State Board of Elections in response to the periodic review of this regulation required by Va. Code Ann. §§ 2.2-4007 and -4017.1, 1 VAC 20-10-120, and Executive Order 19 (2022).

CEC’s interest in this periodic review relates directly to its purpose of “advancing the role of ethics, integrity, and legal professionalism in the electoral process, including safeguarding the right of eligible voters to vote” by undertaking efforts that “increas[e] confidence in election results and election systems”.[1]

Update Statutory References

To the extent that existing regulations contain outdated references to previous versions of the Virginia Code, CEC urges the State Board to update such regulations to provide for accurate and up-to-date citations and to review such references specifically for accuracy during each periodic review.

Complete Other Required Rulemakings

Various other sections in Title 24.2 of Va. Code Ann. require the State Board to promulgate regulations, but the State Board has failed to do so. To the extent such regulations would be codified in Chapter 100, Agency 20, Title 1 of the Virginia Administrative Code, CEC urges the State Board to undertake such rulemakings.

Conclusion

The Center for Election Confidence urges the State Board to take the necessary steps to implement the proposals contained in this Comment for the benefit of Virginia voters’ confidence in the Commonwealth’s elections.

                                                                        Respectfully submitted this 31st day of December 2025,

                                                                        /s/ Caleb J. Hays

                                                                        Chief Policy Counsel

                                                                        Center for Election Confidence, Inc.