AB 1993 requires vote-by-mail identification envelopes to place any perforation, hole, window, or other opening at a distance that prevents the opening from overlapping voter mark areas on the ballot. The bill directs the Secretary of State to write implementing regulations addressing alignment standards, testing procedures, and certification of compliant envelopes.
The change is narrowly technical but operationally consequential: it forces changes to envelope and ballot layout practices, triggers testing and certification obligations, and creates potential new costs for county election offices and private vendors that supply ballots and envelopes.
At a Glance
What It Does
The bill establishes a minimum physical clearance between openings in identification envelopes and any 'fillable field' on the ballot, defines the term 'fillable field,' and requires the Secretary of State to adopt implementing regulations covering alignment standards, testing procedures, and certification. It applies to elections held on or after January 1, 2028.
Who It Affects
County election officials who design and mail ballots, ballot and envelope manufacturers and vendors, the Secretary of State's regulatory and certification functions, and ultimately voters who receive mail ballots. Local governments bear implementation duties and potential costs under California's mandate-reimbursement framework.
Why It Matters
A specific dimensional rule and a regulatory certification regime will change procurement, production, and quality-assurance workflows for mail ballots. That matters to compliance officers and procurement teams at counties and to election vendors that must adapt designs, run alignment tests, and obtain or demonstrate certification before large mailings.
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What This Bill Actually Does
AB 1993 focuses narrowly on where any opening in a vote-by-mail identification envelope can sit relative to the areas of a ballot that voters mark. Rather than leave placement to each county or vendor, it asks the Secretary of State to create enforceable standards that will be used statewide for design, testing, and certification.
The bill treats the relationship between envelope openings and the ballot as a technical alignment problem to be solved by regulation and testing, not by ad hoc practice.
The statute defines the substantive object of protection — a 'fillable field' — to include any voting target, write-in area, or other place intended for a voter to indicate a preference. It also fixes the measurement context: distance is measured when the ballot is fully inserted into the envelope following the voter instructions.
That measurement approach ties compliance to the actual way ballots are mailed and returned, which affects how counties will need to prototype and test envelope-ballot combinations ahead of mailings.Operationally, the bill will push counties and vendors to revise envelope templates, production tooling, and insertion processes. The Secretary of State's forthcoming regulations will be crucial: they will need to specify how to align ballots and envelopes, what testing methods and sample sizes suffice, how tolerances are defined (especially for folded or multi-page ballots), and what paperwork or labeling proves compliance.
Because the bill invokes the state-mandated local program reimbursement mechanism, counties may seek reimbursement for design, testing, and reordering costs, but those claims must follow the statutory reimbursement process.Finally, implementing the rule will interact with existing timelines and procurement cycles. Counties will have to schedule design reviews before printing runs, renegotiate vendor contracts where necessary, and factor certification into their quality-assurance calendars.
The bill does not spell out penalties or enforcement mechanics beyond certification requirements, so much of the practical effect will flow from how the Secretary of State structures the regulations and the certification regime.
The Five Things You Need to Know
The statute requires any perforation, hole, window, or other opening in an identification envelope to be positioned at least one-half inch from any fillable field on the ballot.
‘Fillable field’ is defined broadly to include voting targets, write-in areas, or any part of the ballot intended for a voter to mark or indicate a preference.
Distance is measured when the ballot is fully inserted into the envelope according to the instructions provided to voters — tying compliance to the actual insertion state.
The Secretary of State must adopt implementing regulations covering alignment standards, testing procedures, and certification of compliance.
The rule applies to elections conducted on or after January 1, 2028, and the bill creates a state-mandated local program subject to reimbursement procedures if the Commission on State Mandates finds costs are imposed.
Section-by-Section Breakdown
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Minimum clearance requirement for envelope openings
This subsection imposes the core substantive rule: any opening in an identification envelope must be placed with at least a one-half inch buffer from ballot markable areas. Practically, that fixes a dimensional standard that ballot and envelope designers must respect and that counties must verify before mailing ballots. Because the rule is absolute in form, small changes to ballot layout or to where openings (including perforations) are placed can produce noncompliance, so design choices that previously prioritized cost or machine compatibility may require revision.
Definition of 'fillable field'
This clause clarifies what the clearance protects: any voting target or area where a voter writes in a candidate or records a preference. The definition intentionally covers both machine-marked bubbles/targets and write-in zones, which matters because different ballot styles use different mark areas. The breadth of the term means even non-standard voting marks and write-in spaces must be checked during alignment testing.
Secretary of State to promulgate regulations, tests, and certification requirements
The statute delegates the technical implementation to the Secretary of State, requiring rules for alignment standards, testing procedures, and certification of compliance. Those regulations will determine how counties demonstrate that specific envelope-ballot pairings meet the clearance standard, the scope and frequency of testing (e.g., batch testing before every mailing), acceptable measurement methods, and what documentation vendors or counties must retain. The subsection turns the statutory minimum into a regulated compliance program rather than leaving it as a vague best practice.
Effective date for application
This short provision sets the operative date: the clearance and the regulatory regime apply to elections on or after January 1, 2028. That date creates a practical lead time for counties and vendors to redesign templates, execute test plans, and obtain any necessary certifications before the first covered election.
State-mandated local program and reimbursement provision
If the Commission on State Mandates finds that the act imposes state-mandated costs on local agencies or school districts, the bill specifies that reimbursement follows the standard statutory process. The inclusion signals potential fiscal impact for counties and preserves the administrative path for claiming costs associated with redesign, testing, and certification, though it does not guarantee timely or full reimbursement.
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Explore Elections in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Voters concerned about ballot integrity — fewer envelope openings overlapping markable areas could reduce physical interference with voter marks and lower the chance of inadvertent vote spoilage.
- County election offices that prioritize uniform ballot processing — a regulated clearance standard and certification process can reduce ad hoc disputes about envelope designs and create a consistent acceptance criterion.
- Election administration professionals who value standardization — having state-level alignment and testing rules simplifies auditability and procurement specs across jurisdictions.
Who Bears the Cost
- County election offices, which must revise envelope and ballot layouts, conduct or commission alignment testing, and integrate certification steps into pre-mailing workflows, creating direct administrative and procurement costs.
- Ballot and envelope manufacturers and smaller printers, which may need to modify tooling and production runs or perform additional quality-control testing to demonstrate compliance.
- The Secretary of State's office, which must devote staff time and technical resources to develop regulations, publish standards, and operate or oversee any certification program, potentially without new dedicated funding.
Key Issues
The Core Tension
The central dilemma is between improving ballot safety through a uniform, measurable design standard and imposing new technical, procurement, and testing burdens on local election offices and vendors: the statute reduces ambiguity and risk in ballot handling but transfers cost, timing pressure, and technical complexity to administrators who must implement and certify compliance.
The bill solves a clear design risk — openings that interact with markable areas — by imposing a single-dimensional safety buffer and delegating technical detail to regulations. That delegation is pragmatic, but it pushes complexity into the regulatory phase.
The Secretary of State will need to make judgment calls about measurement protocols (for example, how to measure multilayer or folded ballots), acceptable tolerances for manufacturing variance, the scale and frequency of testing, and how to certify or decertify vendors or specific envelope-ballot pairings. Each of those choices affects cost, timing, and legal defensibility.
There are operational grey areas the statute leaves unresolved. The clearance is measured 'when the ballot is fully inserted according to instructions' — but voters insert ballots inconsistently.
Regulations must therefore decide whether compliance is based on controlled insertion during testing, on the most likely real-world insertion, or on a worst-case insertion standard. The law also does not specify enforcement mechanisms or penalties for noncompliance, nor does it address legacy inventory of preprinted envelopes.
Finally, while the bill contemplates reimbursement if the Commission finds mandated costs, the reimbursement process is often slow and contested, leaving counties to absorb near-term expenses.
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