EAC Staff Memo Lists What a Commission With No Members Can and Cannot Do: Certification and Grants Continue, VVSG and the Mail Registration Form Are Frozen

The EAC’s own staff memo, “Operations in the Absence of Commissioners,” says the commission “has no members appointed” effective July 9, 2026, and sorts its work into what may and may not proceed. The Voting System Testing and Certification Program, the test-laboratory program, Field Services, ESTEP, election-security grant disbursement, the advisory committees and the EAVS survey may proceed under existing delegations. Adopting or modifying the Voluntary Voting System Guidelines, adopting regulations, changing the National Mail Voter Registration Form, holding public hearings that feed policy, and accrediting or revoking a test laboratory may not. Democracy Docket reported the memo on August 10, saying it was published the week before.

Context: the memo is the agency’s own account of the standing condition recorded in 2026-07-09–crs-election-assistance-commission-without-commissioners-palmer-april-30-hicks-hovland-mccormick-july-9. It bears on the March 2025 executive order’s VVSG and proof-of-citizenship directives, which need a quorum to carry out. The memo’s exact posting date is not stated; the 2026-08 path of the PDF and Democracy Docket’s report date are the only anchors.