President Trump signed an Executive Order on March 31, 2026 titled Ensuring Citizenship Verification and Integrity in Federal Elections. The order primarily addresses vote-by-mail and absentee ballots. It creates some significant challenges for the Postal Service, states, voting jurisdictions, and several federal agencies.
As part of the EO, the Postal Service was directed to develop regulations supporting the intent of the order. Say what you will about the Postal Service—they sure as hell can write regulations.
I've tried to capture the key elements of the new Postal Service regulations, and the Executive Order in general.
The process, in broad terms, is this:
- The federal government will provide each state with a list of eligible voters.
- States, in most cases, will distribute the appropriate lists to voting jurisdictions within their state.
- States or local jurisdictions will append trackable IMb values to the voter file—one IMb for the outbound ballot and another for the ballot being returned.
- This information will be uploaded to a yet-to-be-developed Federal Ballot Mail Portal.
- Ballot envelopes will be required to follow specific design standards, including use of the official Election Mail logo, automation compatibility, and printed IMbs on both envelopes. Mailpiece designs must be reviewed and approved by USPS.
- Including individuals not contained on the approved voter list uploaded to the portal will make a mailing noncompliant.
- If a state chooses not to participate, the EO specifies that certain federal funds may be withheld, and the Department of Justice may investigate and pursue enforcement actions where applicable.
Enforcement raises several unanswered questions:
- What happens to noncompliant ballots? Are they returned to the voter as UAA mail?
- If noncompliant individuals are identified in a mailing before it is entered, will the entire mailing be rejected?
- Would rejected pieces be treated as provisional ballots?
There are many additional issues that will need to be resolved.
In most states, voter lists are managed at the state level, while local jurisdictions conduct the mailings. There are more than 10,000 voting jurisdictions in the country, and most conduct their own ballot mailings. Roughly two-thirds of these jurisdictions have fewer than 5,000 voters. Simply printing an IMb will be a significant challenge for many of these areas. Having more than 10,000 envelope designs reviewed and approved could prove challenging as well, especially given the compressed time frame.
Will all of this work? It will not be easy to implement in time for this year's election. There simply may not be enough time to put all of the pieces together and overcome the legal challenges that have already emerged. The Postal Service can likely implement its portion of the process, but bringing 10,000 voting jurisdictions into alignment in just a few months appears ambitious. We may ultimately see some states complying and others choosing not to, adding even more uncertainty to election administration — and it's worth noting the regulations remain in the proposal stage.
The spirit and intent of the process are straightforward. The execution—and especially the timing—may prove to be much more difficult.
To read the Executive Order, click here.
To read the Federal Register notice, click here.