Researcher: MHF Page 1 4/14/25
OLR Bill Analysis
sSB 1535
AN ACT CONCERNING THE SECRETARY OF THE STATE'S
RECOMMENDATIONS RELATED TO EARLY VOTING.
SUMMARY
This bill makes several changes to the state election laws. Primarily,
it changes the state’s early voting procedures to allow ballots cast during
early voting to be deposited into voting tabulators instead of requiring
they be sealed into ballot envelopes and stored until election day. The
bill also requires certain municipalities with a college campus to add an
early voting location if a certain number of students live on campus or
in institutional housing.
It modifies certification and reporting requirements for early voting
and same-day election registration (SDR) locations. The bill also
prohibits election and primary officials, while serving in that role during
an early voting or SDR period, from performing services for any party
or candidate or appearing at any political party headquarters until the
early voting or SDR location closes that day.
Additionally, the bill makes various changes concerning moderators,
including (1) expanding reports designating moderators and when they
are submitted, (2) adding provisions regarding moderators at SDR
locations, and (3) specifying certain crimes that make a moderator
ineligible for appointment.
It also modifies when party enrollment privileges for unaffiliated
voters attach if they do not apply in person. Finally, the bill also makes
technical and conforming changes.
EFFECTIVE DATE: July 1, 2025, except that provisions concerning
unaffiliated elector party enrollment privileges and prohibitions on
individuals convicted of certain crimes from serving as moderators take
effect January 1, 2026. 2025SB-01535-R000663-BA.DOCX
Researcher: MHF Page 2 4/14/25
§§ 1 & 2 — EARLY VOTING BALLOT PROCEDURE S
The bill makes several changes to the early voting process, primarily
to require early voting ballots to be inserted and counted by a voting
tabulator instead of being sealed in a ballot envelope, stored by town
clerks, and transported to the registrars on election day for counting.
Early Voting Eligibility
Under existing law, to vote early, an elector must (1) appear in person
at an early voting location within the designated times, and (2) comply
with election day identification requirements by either (a) showing
adequate identification or (b) signing an affidavit attesting to his or her
identity. The bill eliminates a requirement that the elector also swear an
oath that he or she has not previously voted in the election.
Receiving a Ballot
As under existing law, if an elector has established his or her
eligibility, the registrars must check the statewide centralized voter
registration system (CVRS) to see if the elector has already voted. If the
registrars of voters believe that the elector may have already voted in
the election, they must review the matter. If they cannot resolve it, the
elector may request and cast a challenged ballot (see BACKGROUND),
and the registrars must report the incident to the State Elections
Enforcement Commission, which must investigate.
If a voter is determined not to have previously voted, the elector must
be given an early voting ballot and the registrar must record the
issuance. The bill additionally requires the registrar to tell the elector
their voting district and the correct ballot they should receive.
Casting a Ballot
Under current law, when a voter applies for an early voting ballot,
the voter must mark his or her ballot, place it into a ballot envelope, and
deposit it in a secured early voting ballot receptacle. Once the day’s
early voting period has ended, registrars are required to transport the
receptacle to the town clerk for storage in as near a manner as possible
to the required methods for securing absentee ballots. 2025SB-01535-R000663-BA.DOCX
Researcher: MHF Page 3 4/14/25
Instead, the bill requires the ballot, after it is marked, to be inserted
into a voting tabulator. At the end of each day’s early voting period,
registrars must publicly open the tabulator, secure and seal the day’s
early voting ballots in a secure receptacle, and secure the tabulator in a
locked area. Accordingly, the bill eliminates the requirement that voters
be provided an early voting ballot envelope or sign the affirmation on
it.
Securing and Storing Ballots
The bill also shifts the responsibility for retaining and storing these
ballots from the town clerk to the registrars. The bill specifies they must
be secured in a manner as near as possible to that for those cast at a
polling place on election day.
After the polls close on the day of an election or primary, the early
voting moderator must, in the presence of others, immediately lock the
voting tabulator and produce the vote totals. The bill otherwise requires
early voting ballots to be subject to all procedures relating to the
custody, control, and counting of ballots cast at polling places on
election day under existing law, as nearly as possible. As under existing
law, a section of the head moderator’s return must still show the number
of early voting ballots received.
Correspondingly, the bill eliminates provisions for delivering the
early voting ballots to the registrars for counting, counting these ballots,
storing these ballots in depository envelopes, and putting the early
voting ballot tallies in these envelopes.
§§ 1, 3 & 4 — EARLY VOTING AND SDR LOCATIONS
Existing law requires that each municipality have at least one early
voting and SDR location. Under the law, registrars of voters are
responsible for designating this location for their municipality, which
must be able to access the CVRS and certified to the secretary of the state
(see below). Under the bill, if the registrars cannot agree on an early
voting location, the municipality’s legislative body (or the board of
selectmen if the municipality’s body is a town meeting) must designate
the location, subject to the same requirements. 2025SB-01535-R000663-BA.DOCX
Researcher: MHF Page 4 4/14/25
Early Voting and SDR Location Certification
Deadline. In order to designate an early voting or SDR location,
registrars must submit a written certification to the secretary of the state
with certain information about the location. Current law requires
submitting an (1) early voting location certification 60 days before an
election or primary and (2) SDR location certification 45 days before an
election. The bill instead requires that they be annually submitted by
February 15. The SDR certification must be included in the early voting
certification.
Content. As part of the early voting certifications, registrars must
provide certain information, such as the name, street address, and
contact information associated with the location, the number of officials
serving at the location, a description of the location’s design, and a plan
for the efficient conduct of early voting. The bill also requires it to
include the SDR implementation plan (see below).
Current law also requires SDR certifications to include similar, but
not identical content as the early voting certification, including a plan
for the effective completion and processing of SDR registrations. The bill
eliminates the requirement for an SDR certification to list the name and
address of each election official appointed for a location and instead
requires the certification to note the number of officials and their roles
like for early voting certifications.
Approval. Additionally, the bill specifies that the secretary must
approve or disapprove these certifications by March 1 (instead of 45
days before an election contest for early voting or 29 days before an
election contest for SDR certifications). Existing law, unchanged by the
bill, outlines procedures if the secretary disapproves the annual location
certification.
Amendment. The bill creates a process for registrars to amend their
early voting or SDR written certification after it is submitted. Under the
bill, they must submit an updated written certification as the secretary
determines, and clearly indicate the changes from the earlier
certification. The update must be submitted as soon as practicable, but 2025SB-01535-R000663-BA.DOCX
Researcher: MHF Page 5 4/14/25
no later than seven days after the change.
The secretary must approve or disapprove the amended certification
as soon as practicable, but no later than seven days after the submission.
If the secretary disapproves the certification, she must, as for original
certifications, give the municipality a written reason for the disapproval
and any order for corrective action she deems necessary (e.g.,
appointing additional officials or altering any submitted design or
plan).
Additional Early Voting Locations
Under existing law, municipalities of 20,000 or more may authorize
early voting locations under certain procedures in addition to the one
required by law. The bill requires the municipality’s legislative body, or
board of selectmen if the legislative body is a town meeting, to designate
any additional early voting locations instead of its registrars.
The bill also requires registrars to designate an additional early
voting location on a college campus in a municipality, regardless of its
size, if at least 1,000 students live on campus or in institution-owned, -
operated, or -affiliated housing. Like the required early voting location,
the added location must be able to connect to CVRS and be certified by
the secretary.
§§ 1, 3, 4, 6 & 7 — MODERATORS
Moderator Reports (§§ 1, 3 & 4)
Existing law requires registrars to provide a written report with the
names and addresses of all moderators designated to serve at regular
polling locations. Currently, this report must be submitted at any time
before each election and primary. The bill instead requires that this
report be made at least 14 days before an early voting period begins. The
bill requires registrars to also include the moderator’s cell phone
number, if available, and provide this and the above information for
early voting and SDR moderators.
SDR Moderators (§ 3)
Current law authorizes registrars of voters to delegate any of their 2025SB-01535-R000663-BA.DOCX
Researcher: MHF Page 6 4/14/25
responsibilities or duties to election officials appointed to serve at SDR
locations, subject to the registrars’ supervision and training. The bill
generally maintains these requirements, but also implements similar
moderator requirements for SDR locations as required for early voting
locations.
Specifically, registrars must appoint, as previously required in the
SDR certification, a moderator and other election officials who will serve
at the SDR location. Moderators must perform any duty required by and
may exercise any power authorized under the state’s election laws in
order to complete and process SDR registrations.
The bill specifies that the municipality’s registrars of voters may
agree to appoint one of themselves to serve as the moderator instead. If
they choose to do so, they must submit a certification of their agreement
to the secretary of the state as well as a written coverage plan for the
registrar’s regular duties, to ensure the registrar abstains from any that
conflict with his or her role as moderator while serving in that role.
Persons Prohibited From Serving as Moderator (§§ 6 & 7)
The bill restricts registrars of voters from designating or appointing
a person as a moderator if the person has been convicted of, or pleaded
guilty or no contest to, any offense under the state’s election laws, or
felonies involving fraud, forgery, larceny, embezzlement, or bribery.
Under existing law, moderators are generally required to be certified by
the secretary of the state before serving at an election or primary (see
BACKGROUND) and are subject to the same restrictions in order to
receive their certification.
Registrars of voters are responsible for designating a moderator for
each polling place, including early voting and central counting
locations. If a moderator is unable to serve, a certified alternate
moderator may assume the role of moderator. However, if a town or
voting district lacks a moderator, the registrars of voters must appoint a
new moderator. The new moderator should, if possible, become
certified. If all instructional and certification sessions have already been
conducted at the time of the moderator’s appointment, he or she must 2025SB-01535-R000663-BA.DOCX
Researcher: MHF Page 7 4/14/25
receive instruction from the registrars.
§ 5 — PARTY ENROLLME NT PRIVILEGES FOR UNAFFILIAT ED
ELECTORS
By law, unaffiliated voters who are eligible to vote, in most cases, are
immediately entitled to the privileges of party enrollment (e.g., voting
in a party’s primary) if they file an application in person with the
registrars by noon on the business day before a primary.
However, under current law, if the voter submits the application by
other means (e.g., by mail) and it is filed within five days before the
primary, the privileges generally attach after the primary except in some
instances for members of the armed forces or certain residents
temporarily overseas. The bill expands this period to 18 days before a
primary (§ 5).
BACKGROUND
Challenged Ballots
Under existing law, a voter’s right to cast a ballot may be challenged
if a challenger knows, suspects, or reasonably believes that a person is
not qualified or entitled to vote (CGS § 9-232 et seq.). A moderator must
review these challenges and, if a moderator’s decision is unfavorable to
the challenged voter, the voter may apply for a challenged ballot. As
part of the application, the voter must complete an affidavit attesting to
the voter’s qualifications and entitlement to vote at the election. The
town clerk must preserve the ballots for at least 180 days after an
election. In the case of a contested election, the court may order that
challenged ballots be delivered to the board of admissions. The board,
if ordered, must review all challenged ballots and determine which ones
may be counted in the election and added to the vote totals.
Moderator Certification Requirements
State law requires the secretary to provide instructional sessions for
moderator training each year, subject to certain geographical and
timeliness requirements. At a minimum, the curriculum must include
(1) procedures for counting and recording absentee ballots, (2) hands-
on training for using voting tabulators, and (3) the moderator’s duties 2025SB-01535-R000663-BA.DOCX
Researcher: MHF Page 8 4/14/25
in conducting a primary or election.
The secretary must generally certify anyone who successfully
completes an instructional session or regional instructional session (i.e.
a session conducted by a regional election advisor) and passes an exam
she administers. A person cannot be certified if he or she has been
convicted of, or pleaded guilty or no contest to, any felony involving
fraud, forgery, larceny, embezzlement, bribery, or any criminal offense
under the state’s election laws.
The secretary’s certification is valid for four years. Before it expires, a
certified moderator may undergo an abridged recertification process the
secretary administers. Once completed, the certification must be
renewed for another four years.
Related Bills
sSB 1163 (File 531), favorably reported by the Government
Administration and Elections (GAE) Committee, makes identical
changes concerning persons prohibited from serving as moderators.
HB 7129 (File 366), favorably reported by the GAE Committee,
provides for the transfer of voting tabulators to municipalities.
COMMITTEE ACTION
Government Administration and Elections Committee
Joint Favorable Substitute
Yea 13 Nay 6 (03/27/2025)