The Trump administration is advancing a project to compile state-by-state lists of individuals the federal government identifies as adult citizens eligible to vote in the upcoming midterm elections. While a March 31 executive order originally mandated that these "State Citizenship Lists" be sent to state officials at least 60 days before the election, Department of Justice attorneys recently informed opposing counsel that the administration will not meet that deadline, which falls on Friday, September 4, 2026. Instead, officials stated they will provide a 48-hour notice to plaintiffs' attorneys before launching a digital portal containing the data.
The project is based on the March 31 executive order "Ensuring Citizenship Verification and Integrity in Federal Elections," which directs U.S. Citizenship and Immigration Services (USCIS) and the Social Security Administration (SSA) to share data to identify eligible voters. Although a lower court initially blocked the plan in 23 states and Washington, D.C., the U.S. Supreme Court stayed that injunction in late August 2026, permitting the administration to proceed. The administration has already secured a web domain for the portal, which briefly displayed a "Coming Soon" message in recent days.
The administration’s plan has faced multiple legal challenges. A motion filed Thursday, September 3, 2026, in a Maryland federal court by the Electronic Privacy Information Center (EPIC) and individual voters seeks to block a June 8 implementation memo from USCIS Director Joseph Edlow. The plaintiffs argue the plan violates the Privacy Act, which requires 30 days of public notice and comment before federal agencies share personal data for a new purpose. They also allege the government lacks accurate, up-to-date citizenship records, noting that SSA and USCIS databases often fail to reflect recent naturalizations or individuals who acquired citizenship as minors.
The scale of the project involves the personal data of millions of adult residents across all 50 states, Washington, D.C., and U.S. territories. For an individual voter, this could result in their citizenship status being shared between federal agencies and then disseminated to state election officials via a federal portal. If the federal data incorrectly flags a citizen as a noncitizen, that individual may face challenges to their voter registration or be required to provide additional documentation to maintain their eligibility. The executive order also instructs the Department of Justice to prioritize criminal prosecutions for unauthorized voting, creating a potential legal consequence for those inaccurately listed.
The knock-on effects include a shift in the traditional division of labor regarding elections. While the U.S. Constitution assigns the responsibility of maintaining voter rolls to the states, this project represents an effort by the federal government to create its own comprehensive citizenship lists for election purposes. Relatedly, Immigration and Customs Enforcement (ICE) recently published a request for information to hire vendors capable of compiling public voter rolls and history files from all U.S. jurisdictions to support fraud detection activities.
What happens next: The administration has committed to giving 48-hours notice before the citizenship portal goes live, though a specific launch date is not reported. The federal court in Maryland is expected to review the motion to block the plan filed on September 3. Additionally, lawyers for Democratic party groups have filed a separate motion requesting the court require the government to provide immediate updates on its implementation timeline. The upcoming midterm elections serve as the operational target for the use of these lists by state officials.