The Idea behind the Citizenship Audit
Instead of an expensive, open-ended review stretching back 30+ years, states should conduct a targeted 10-Year Citizenship Integrity Audit: a focused review of voter registrations created or updated in the past decade — the period during which Automatic Voter Registration and modern DMV-linked systems expanded fastest across the country — cross-checked against available citizenship data.
Why 10 Years, and Why Now
The 10-year window isn't arbitrary — it targets the specific period when most states rolled out Automatic Voter Registration and expanded DMV-to-voter-file data sharing, meaning it's the window where both the highest registration volume and the best available cross-check data overlap. Recent findings underline the need:
● New Jersey: a software glitch registered roughly 6,600 people who had indicated they were not U.S. citizens; about 400 voted.
● Multiple Pennsylvania counties hold non-juror lists — people excused from jury duty solely for non-citizenship — drawn from the same source data used for voter registration, containing thousands of names.
● Utah's 2025-26 full, all-years review of 2 million+ voters found 27 confirmed non-citizens and over 5,000 registrants whose status couldn't be confirmed at all — largely older records that predate DMV/SSN cross-verification.
How It Would Work
● Review registrations created or updated in the last 10 years.
● Cross-reference against DMV records, the federal SAVE system, and other available citizenship data sources.
● For any flagged registrant, provide individualized written notice and a minimum 30-day cure period to submit proof of citizenship before any removal — consistent with NVRA due-process requirements and the notice model Utah adopted under HB 209.
● No audit activity — flagging, notices, or removals — within 90 days of a federal election, in line with the NVRA's existing quiet-period requirement for systematic list maintenance.
● Counties may extend the cure period for documented hardship (e.g. difficulty obtaining a birth certificate or passport), so no eligible voter loses their registration solely due to paperwork delay.
● Publish transparent summary results — records reviewed, confirmations, removals, unresolved cases — so the process itself builds public trust.
● Acknowledge upfront that DMV cross-checks are not infallible: older, pre-verification DMV records can carry unconfirmed citizenship status of their own, which is why the notice-and-cure step, not the database match alone, is the actual safeguard.
The Cost Comparison
Utah just completed the closest real-world comparator available: a full, all-years review of its entire 2 million-plus voter roll, using this same SAVE/DMV cross-check method. According to Utah's official fiscal note for HB 209, the state's fiscal note for its full citizenship review together with its new ongoing verification system totaled approximately $100,000 in state costs plus roughly $149,800 one-time and $32,200 annually ongoing for local governments — call it around a quarter-million dollars combined. That figure covers both the one-time historical review and the state's new permanent verification process, not the audit alone in isolation — but even bundled, it's a useful ceiling for what this kind of effort costs at state scale.
A 10-year-scoped audit reviews a smaller subset of records than Utah's full review did, using the same existing infrastructure — meaning per-state cost would plausibly come in below that quarter-million-dollar mark, not above it. Compare that to the $10 billion Congress set aside nationally in its July 2026 budget resolution to incentivize states toward full documentary-proof-of-citizenship systems under the SAVE Act: a targeted state-level audit is a rounding error by comparison, deployable long before a national mandate could ever take effect.
Expected Benefits
● Cleaner, more accurate voter rolls, without a costly full-history overhaul
● Increased public trust in election outcomes through transparent, published results
● Built-in due process — no one is removed without individual notice and a chance to respond
● Complements, rather than replaces, existing routine list-maintenance procedures
Call to Action
State legislators, election officials, and Congress should authorize and fund pilot 10-Year Citizenship Integrity Audits — funded at the state level, consistent with how states already bear the cost of routine voter-list maintenance, with optional federal cost-sharing where SAVE Act incentive funds are available. Pilots should begin with counties and states that already have SAVE system access; states lacking that access would need to establish it first, which some do not yet have.
Sources:
Utah Lt. Governor's Office — Final Citizenship Review Summary
Utah HB 209 — Official Fiscal Note
Bipartisan Policy Center — Six Things to Know About the SAVE America Act