Trust Through Transparency: Why States Should Audit Voter Rolls for Noncitizens
A Wisconsin think tank has proposed a process for states to regularly check the issue, while protecting voters already on the rolls.
By Kyle Koenen
Confidence in American elections doesn’t just depend on outcomes. It depends on voters trusting that the rules are being followed and applied consistently. That reality cuts to the core of the ongoing debate in Congress over the House-passed SAVE Act, its more ambitious successor the SAVE America Act, and the Make Elections Great Again (MEGA) Act.
Specifically, the debate around the SAVE legislation reflects legitimate concerns of voters. Americans want to be confident that only eligible citizens are voting in elections. Polling shows that a bi-partisan majority — roughly 89 percent of Americans — believe it is important to prevent ineligible voters from casting a ballot. A recent CBS/YouGov poll further suggests that 66 percent of Americans support requiring voters to provide documentary proof of citizenship, a key tenant of the SAVE America Act. That is a healthy instinct in a self-governing republic.
But as Congress debates what federal policy should look like as it relates to noncitizen voting, states already have the authority and tools needed to strengthen confidence right now. How? By auditing their voter rolls to identify noncitizens who may be registered to vote or have cast a ballot.
Several states have already undertaken these audits. Across these states, the pattern has been pretty clear: Audits uncover isolated cases, not widespread problems. A sampling of them:
Iowa audited its 2.3 million registered voters and identified 277 noncitizens on the rolls, including 35 who cast ballots. An additional 5 noncitizens attempted to vote but were rejected.
Georgia’s audit found that out of 8.2 million registered voters, 20 were not citizens and none had cast a ballot in the 2024 election. Nine had cast ballots in prior elections.
Utah found only one noncitizen registered voter out of 2.1 million registered voters.
Louisiana found 403 registered noncitizens, including 83 who voted in at least one election since the 1980s. The state has 2.96 million registered voters.
Idaho discovered 36 “very likely” registered noncitizens in a pool of approximately 1 million voters.
Montana found 23 possible noncitizens out of 785,000 voters.
Ohio and Texas are among the states that have undertaken similar reviews. Despite these state audits and other evidence showing that noncitizen voting is rare, states should still take the steps to conduct regular, transparent audits that flag potential noncitizen voting. Failing to conduct audits will continue to fuel distrust that is deeply rooted, with only about three in ten Republicans expressing confidence that votes are cast and counted accurately, according to one representative Gallup poll from 2024.
These efforts also respond to real concerns voters are expressing. In November 2024, 71 percent of Wisconsin voters approved an amendment to the state constitution reaffirming that only citizens may vote in Wisconsin elections, joining substantial majorities in 14 other states since 2018 to enact similar state constitutional provisions. The Illegal Immigration Reform and Immigrant Responsibility Act of 1996, a federal statute, expressly barred noncitizens from voting in federal elections under penalty of deportation and ineligibility to become citizens. But the recent state amendments are a clear signal that voters want both strong safeguards and confidence in the system. Audit procedures specify an enforcement mechanism: They are how that desire of voters can be put into practice.
So, how should these reviews be conducted? At the Wisconsin Institute for Law & Liberty, we released a guide that proposes a step-by-step framework outlining how Wisconsin should conduct a citizenship audit of its voter rolls in a manner that is both effective and fair. The process we propose is a funnel model, where potential noncitizens are flagged and further investigated at each step of the process.
The process would begin by identifying records within the statewide voter file that may indicate noncitizen status based on available state data, including information maintained by the state Department of Transportation. This could include green card holders or temporary workers who have Wisconsin driver’s licenses. Those flagged records are then reviewed using the federal Systematic Alien Verification for Entitlements, or SAVE, database to confirm citizenship status. This database, maintained by US Citizenship and Immigration Services (USCIS), is used by states and local governments to verify eligibility for public assistance programs.
An essential clarification at this stage is that any individuals flagged during this process are not automatically removed from voter rolls. Instead, they are provided notice and an opportunity to respond and demonstrate that they are eligible to vote before any action is taken. Only after this review process is completed are non-respondents removed from the voter rolls. These additional safeguards are important because they help to ensure that eligible voters are not mistakenly removed, as no database is 100 percent accurate.
This approach mirrors the one taken by Iowa and can be replicated in states around the nation. In fact, over the past year, the process has become even more streamlined for states, as USCIS has expanded access to the SAVE database and enabled bulk data processing, making verification more efficient for state governments. Now, entire state voter rolls can be processed in a matter of hours.
While it has been red states that have predominately taken advantage of the opportunity to conduct these audits, this should not be an inherently partisan effort. In fact, the results of these audits, which show only a small number of noncitizen cases, strengthen claims that noncitizen voting is not a significant issue.
But that doesn’t diminish the importance of this effort. Maintaining public confidence and ensuring accurate voter rolls are shared responsibilities of every state. In addition to conducting an initial audit, states should codify these reviews as a regular part of their post-election duties. Public trust in election outcomes is essential to a healthy republic, and citizenship audits are a practical way to meet voters where they are and ensure that trust is earned, not assumed.
Kyle Koenen is the Policy Director at the Wisconsin Institute for Law & Liberty, a law and policy center based in Milwaukee.