Introduction

Documentary Proof of Citizenship (DPOC) bills have captured the imagination of federal and state lawmakers across the country since the reintroduction of the federal Safeguard American Voter Eligibility (SAVE) Act in early 2025. In the months that followed, a deluge of states introduced their own versions of the bill.1

These bills vary in specifics but generally require all voters to present documented proof of their citizenship whenever they register or re-register to vote—often in person, and with strict limitations on what counts as proof of citizenship. Recently, advocates and lawmakers have devoted much attention to the ways that DPOC bills will disenfranchise many eligible voters and disproportionately harm voters of color, low-income voters, disabled voters, military and overseas voters, and married women voters. However, less attention has been paid to the financial and administrative burdens these proposals impose on states and local governments. While both are important considerations, we focus on the latter in this white paper.

Our research shows that a DPOC system can cost a state millions of dollars to implement, maintain, and defend. 

Our research shows that a DPOC system can cost a state millions of dollars to implement, maintain, and defend. Requiring applicants to present proof of citizenship significantly slows down and complicates the voter registration process. For each jurisdiction that passes such a bill, election officials need to develop and implement procedures for evaluating every applicant’s citizenship documents and recording the results. This involves changing voter registration forms, contacting voters about registration deficiencies, overhauling online databases, implementing data privacy protections for digital copies of documents, retraining all election officials to recognize and handle DPOC, accounting for staff time to review copies of DPOC, and, if a state’s law mandates it, devoting additional staff time to ongoing voter roll purges.2 Moreover, every jurisdiction that passes such a bill should significantly invest in voter education to make sure that voters know what documents they need and how to get them by registration deadlines.3 Yet, as our findings demonstrate, DPOC bills’ fiscal notes and similar analyses tend to grossly underestimate or completely ignore such costs.

Nor is there a singular, reliable database with citizenship information that could assist election officials in verifying citizenship. Federal systems like SAVE are not definitive,4 and state motor vehicle databases are not sufficiently up to date regarding citizenship information to be reliable.5 As a result, the costs compound once errors concerning voter eligibility are factored in. Thus, DPOC systems come with what we term “system error remediation costs”—high costs associated with correcting administrative mistakes, fixing wrongful voter purges, and related litigation.

We conclude that no matter how a state may choose to structure a DPOC bill, the costs and administrative burdens will be substantial.

In this white paper, we look closely at the costs that two states, Arizona and Kansas, have incurred due to DPOC legislation. First, we lay out our findings concerning the high costs that Arizona and Kansas have each faced to implement and maintain DPOC systems. Next, we describe how each state has incurred more in system error remediation costs. As we explain below, our findings represent a floor, rather than a ceiling, concerning the magnitude of expenses a state contemplating a new DPOC bill can expect. We then draw examples from a handful of additional states to demonstrate how existing state DPOC bills tend to grossly underestimate, or flat-out ignore, state and local costs of implementation and maintenance. We conclude that no matter how a state may choose to structure a DPOC bill, the costs and administrative burdens will be substantial.

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  • 1Voting Rights Lab, “Proof of Citizenship,” https://tracker.votingrightslab.org/issues/proof-of-citizenship
  • 2In a 2025 virtual policy conversation hosted by Votebeat, Arizona Secretary of State Adrian Fontes noted some of these costs, stating, “you’re going to have to process a whole new set of paperwork, and you’re going to have to train folks to process that whole new set of paperwork. And reprogram your computer systems to be able to accept that new column of data … there’s an enormous amount of backroom technical work that has to go into these sorts of things, before you even get to reaching out to voters. And there’s a lot of costs that can be involved in those sorts of things.” Votebeat, “Checking Citizenship: A conversation with two secretaries of state,” moderated by Jen Fifield, streamed live May 19, 2025, YouTube, 52:01, https://youtu.be/g5kDJwT3oNk?si=P4LIvxIXMd2sN3Pz&t=3121.
  • 3As New Hampshire Secretary of State David Scanlan explained, “We’re going to have to prepare by educating as best we can the population of individuals that need to be registered that they now have to bring these documents with them to be able to do that. ... We also know that there is no single federal database that contains citizenship information, and as other states, you know, get on the bandwagon and pursue a strict requirement of citizenship documentation that we are going to need resources to be able to help voters make that qualification. And I think that the states that are going in this direction, are going to have to be prepared to be a resource for voters to help them obtain that documentation if they don’t have it.” Votebeat, “Checking Citizenship: A conversation with two secretaries of state,” moderated by Jen Fifield, streamed live May 19, 2025, YouTube, 13:41, https://youtu.be/g5kDJwT3oNk?si=i-Lv1LSGvSoAKtSs&t=821.
  • 4When asked if it was practicable to compare all of his county’s voters against the SAVE system, Matt Jackson Webber, Program Manager for Voter Registration and Early Voting at the Yavapai County Recorder’s Office, answered, “Not without a lot more employees and, well, alien registration numbers. So practicably, no.” Transcript of Deposition of Yavapai County Recorder, represented by Matt Jackson Webber, at 91:9 - 92:7, Mi Familia Vota v. Fontes, 719 F.Supp.3d 929 (D. Ariz. 2024). See also Jasleen Singh and Spencer Reynolds, “Homeland Security’s ‘SAVE’ Program Exacerbates Risks to Voters,” Brennan Center for Justice, July 21, 2025, https://www.brennancenter.org/our-work/research-reports/homeland-securitys-save-program-exacerbates-risks-voters.
  • 5Michael Morse, Rachel Orey, and Joann Bautista, “Modernizing Voter List Maintenance,” Bipartisan Policy Center, September 9, 2025, https://bipartisanpolicy.org/report/modernizing-voter-list-maintenance-an-evidence-based-framework-for-access-and-integrity/.