WASHINGTON, D.C. – All Voting is Local submitted comments to the U.S Department of Homeland Security regarding the Statement of Record Notice (SORN), strongly urging the DHS to not expand the Systematic Alien Verification for Entitlements Program (SAVE) for use in voter verification because it will likely disenfranchise eligible voters and create a security risk for Americans’ personal data and information. Read the full comment below:
FOR:
Roman Jankowski, Chief Privacy Officer, U.S. Department of Homeland Security
Angela Y. Washington, Chief of the Office of Privacy, U.S. Citizenship and Immigration Services
FROM: All Voting is Local
DATE: November 26, 2025
RE: Systematic Alien Verification for Entitlements Program System of Records Notice [Docket No. USCIS–2025–0337]
Thank you for the opportunity to comment on the modification of the Systematic Alien Verification for Entitlements Program (SAVE), USCIS-2025-0337-0002. All Voting is Local (“All Voting”) is a nonpartisan organization that works on the ground in eight states for free and fair elections. In a moment of ongoing threats to our democracy, All Voting advocates state and local officials for policies and practices that ensure the American people choose their leaders, not the other way around. All Voting submits this comment on the docket USCIS-2025-0337 to urge a reconsideration of the Statement of Record Notice (“SORN”) codifying the expansion of the Systematic Alien Verification for Entitlements Program (“SAVE”) database and encouraging its use in voter verification.
All Voting strongly urges against the expansion of SAVE for use in voter verification because doing so will 1) likely disenfranchise eligible voters and 2) create a security risk for Americans’ personal data and information.
Background
In accordance with the Privacy Act of 1974, the Department of Homeland Security (DHS) proposes to modify and reissue a DHS system of records notice (SORN) titled, “Department of Homeland Security/U.S. Citizenship and Immigration Services (USCIS)-004 Systematic Alien Verification for Entitlements Program (SAVE).”
According to the Department of Homeland Security, “SAVE is an online service for registered federal, state, territorial, tribal, and local government agencies to verify immigration status and U.S. citizenship of applicants seeking benefits or licenses.”
The SAVE system is maintained by the Department of Homeland Security for use by states, localities, and other federal agencies when processing applications for government benefits that are limited by immigration status. Until now, SAVE has primarily operated using information relevant to immigration and derived from immigration documents, such as Alien Registration Numbers, Permanent Resident (Green) Card information, and similar documents. The administration’s claims that its rapidly developing new SAVE system will enable election officials to identify noncitizens on voter rolls are more complicated. Digging into the details triggers significant concerns about Americans’ privacy, booting completely eligible voters off the rolls, and disinformation about our elections.
Use of the SAVE database risks disenfranchising American citizens
In the last few months, the Department of Homeland Security has unlawfully created a new voter citizenship check system, which they are calling the “Overhauled SAVE” system. DHS is encouraging states to run their entire voter rolls through this new system, and the system is providing states with lists of individuals who DHS believes may be noncitizen voters. The SAVE system was not designed for tracking U.S. citizenship or verifying voter eligibility. It’s a federal query system initially designed to help verify the citizenship and immigration status of individuals who are applying for public benefits. The results are likely inaccurate for many voters, especially naturalized citizens.
States and counties who are working with DHS on using the new SAVE system are now improperly accusing eligible voters of being “noncitizens” and demanding that they prove their citizenship by showing their citizenship papers in order to be allowed to vote. Proving citizenship requires readily producing a birth certificate, passport, or similar document which are not easily accessible documents for many Americans. This will create additional barriers to voting and likely result in disenfranchisement of citizens who do not have the time nor the resources to complete an unnecessary and intrusive administrative process.
Expanding the SAVE system will put American’s data at risk
The administration’s unlawful changes to the SAVE system combine multiple sources of identifying information for Americans, which creates additional privacy risks. Novel connections to the Social Security Administration’s database create particularly pointed risks. It threatens to subject Americans to unwarranted investigations and creates unprecedented security risks by placing millions of Americans’ sensitive, personal information in a single target-rich system.
Conclusion
The administration rushed head-first into making sweeping changes to the SAVE system and altered its intended purpose. Only after being sued has DHS belatedly sought public input on its decisions to make these improper changes. In summary, problematic changes to the system include mixing federal data, such as Social Security numbers, requiring less individual information about a voter to create accurate matches, and bulk uploads of potentially hundreds of thousands of voters. This retooling effectively supercharges an otherwise flawed system. Here are five things you should know about the impact of the changes and retooling of the SAVE system and how it contributes to election interference:
1. Retooling the SAVE system is nothing but a smokescreen for the administration to continue laying the groundwork for election interference and undermining elections—for all of us. 2. Retooling the SAVE system for voter list maintenance goes beyond its intended purpose. 3. Retooling the SAVE system, without a thorough investigation into its ability to pool information accurately and reliably, blatantly disregards the impact on all voters.
4. Retooling the SAVE system fuels the false narrative about widespread, intentional, and illegal voting; the number of noncitizens removed from rolls for ineligibility is typically less than 1% in states where removals have occurred —and in some instances, without confirming removal for illegal voting with the individual.
5. Retooling the SAVE system is also a waste of time in terms of its outcomes (see #4), at a time when 76% of Americans are more concerned about political conflict and 56% about economic struggles.
For the reasons outlined above, All Voting is Local strongly urges a rejection of the expanded use of SAVE as a voter verification tool as detailed in this SORN.
Sincerely,
All Voting is Local