“State Citizenship Lists” in Trump’s March 31, 2026 Elections Executive Order

As part of the Trump administration’s March 31, 2026 “Ensuring Citizenship Verification and Integrity in Federal Elections” Executive Order (EO), the federal government is required to create and send a “state citizenship list” to each state.¹ To create the “state citizenship list,” the order requires the U.S. Department of Homeland Security (DHS) through the U.S. Citizenship and Immigration Services (USCIS) and the U.S Social Security Administration (SSA) to work together to compile before each federal election a list of individuals in each state who:

1. Are confirmed to be U.S. citizens;
2. Are 18 or older at the time of the upcoming federal election; and
3. Maintain a residence.

The U.S. Department of Homeland Security (DHS) would then transmit the “state citizenship list” to the chief election official of each state.

The order requires DHS to assemble the “state citizenship list” no fewer than 60 days before regularly scheduled or special federal elections. The list is supposed to be assembled from federal citizenship and naturalization records, SSA records, data from the DHS Systematic Alien Verification for Entitlements (SAVE) system, and “other relevant” federal databases.

The order also states that DHS will establish a process to allow people to access their individual records and update or correct their records in advance of elections, and will enable states to routinely supplement and provide suggested modifications or amendments to the list that is transmitted.

The process outlined in the executive order raises several implementation questions and presents practical challenges, even under the best conditions.

Federally-created “state citizenship lists” raise several practical considerations, particularly in three areas:

1. Many U.S. citizens are not included in federal databases.
2. The federal government cannot determine what state a U.S. citizen lives in at the time of an election.
3. Federal agencies do not have enough lead time to develop and implement a process for millions of individuals to prove their U.S. citizenship before the 2026 federal elections.

Many U.S. citizens are not included in federal databases.

• Initially, SAVE was not built to verify citizenship status. While a significant overhaul was initiated in May 2025,² that overhaul remains a work in progress. SAVE’s queries rely upon significantly incomplete and occasionally unreliable data. Evidence from multiple states’ use of SAVE in the last four months demonstrate failure to verify U.S. citizenship for a meaningful portion of registered voters – including those whose citizenship should have been known by SAVE, and where a lack of verification confirms SAVE’s ongoing data gaps.³
• SAVE can confirm that some people are U.S. citizens, but cannot definitively confirm that anyone is NOT a U.S. citizen.
• The federally-generated “state citizenship lists” will be incomplete due to gaps in U.S. citizenship records. SSA records are unable to substantiate U.S. citizenship for many people, including: people who were born outside of hospitals; people born outside the U.S. to U.S. citizens (such as children of the military); people who have changed their names due to marriage or other reasons; and people who became citizens after completing the naturalization process. In addition, SSA only began adding U.S. citizenship tags about 40 years ago, so the agency’s data on natural-born citizens is incomplete and may leave out elderly citizens.

The federal government cannot determine what state a U.S. citizen lives in at the time of an election.

• Millions of people in the U.S. move to a different state every year. In 2024 alone, more than seven million people moved to their current residence from a different state.⁴ For example, in 2024, about 64,000 people in the U.S. moved to Florida and more than 85,000 people moved to Texas. The same year, California lost 239,000 and New York lost about 120,000 residents.⁵ Each state list will be both underinclusive and overinclusive by thousands of people and require states to do their own work to verify U.S. citizenship for people residing in the state.
• The federal data identifying an individual’s state residency is spotty and stale. The order provides no information on where or how the federal government will obtain data on an individual’s residency. Setting aside federal data sharing questions, even if DHS were able to utilize addresses from the IRS’s federal income tax filings, which may be the most complete, the data will be several months old, and many voters with low incomes are not required to file income tax. Federal Medicaid data only includes addresses for those actually enrolled.
• States define “residency” differently for voting purposes. While federal law ensures that no state can require a voter to have lived there for more than 30 days prior to federal elections, states can set lesser deadlines beyond that time for who they consider a “resident” for voting purposes.

Federal agencies do not have enough lead time to develop and implement a process for millions of individuals to prove their U.S. citizenship.

• There is no time or precedent for federal agencies to establish a federal “cure process” for millions of individuals to prove their U.S. citizenship. There is no existing process for millions of individuals to engage with a new data system on curing their U.S. citizenship status at this scale. This program would potentially require individuals to upload proof-of-citizenship documents, requiring data security and user interface resources.
• A large number of eligible U.S. citizen voters may need to engage in a cure process. A meaningful portion of SAVE inquiries today require manual verification.⁶ For example, many U.S. citizens, such as married women who change their names,⁷ will not be verifiable in government databases and will need to go through a process of gathering documentation and submitting supporting documentation to prove their U.S. citizenship. Similarly, millions more eligible citizens may need to correct their residency information if they are erroneously left off of a particular state’s list.
• This may be redundant to state procedures, creating administrative burdens for voters. States already have a cure process for determining eligibility for multiple programs and benefits like Medicaid. If an individual’s U.S. citizenship or eligible immigration status is not verified electronically by state or federal data sources, states already know how to provide documentary proof to “cure errors.” States have detailed rules in place that indicate which type of documents can be used as proof and systems for uploading them or providing them in person. But there is no clear process for citizenship verification for Medicaid or other benefits at the state-level to transfer to the federal list.

<sup>1. The EO notes that the state citizenship list alone is not an indication of voter registration. People must still follow federal and state procedures to register to vote. The order is unclear on what states would actually do with this “state citizenship list” provided by DHS.
2. See also, Institute for Responsive Government, An Updated Federal System to Verify Voter Citizenship May 23, 2025, https://responsivegov.org/research/uscis-save-system-overhaul/.
3. See VoteBeat, “Hundreds of Texas voters flagged as potential noncitizens may have already proven their citizenship.” December 2, 2025. https://www.votebeat.org/texas/2025/12/02/travis-county-officials-investigate-potential-noncitizens-dps-save-proof-of-citizenship/, and ABC 17 News, “Local election authorities say a verification tool used in Missouri flagged citizens for removal from voter rolls.” February 13, 2026. https://abc17news.com/news/abc-17-news-investigates/2026/02/13/local-election-authorities-say-a-verification-tool-used-in-missouri-elections-flagged-citizens-for-removal-from-rolls/
4. U.S. Census Bureau, State To State Migration Flows, 2024, https://www.census.gov/data/tables/time-series/demo/geographic-mobility/state-to-state-migration.html
5. Ibid.
6. U.S. Government Accountability Office, “Immigration Status Verification Benefits: Actions Needed to Improve Effectiveness and Oversight.” Table 1, March 2017, https://www.gao.gov/assets/gao-17-204.pdf.
7. Institute for Responsive Government, The SAVE Act, How a Proof of Citizenship Requirement will Impact Elections, January 30, 2025, https://responsivegov.org/research/the-save-act-how-a-proof-of-citizenship-requirement-would-impact-elections/.</sup>