American Citizens Abroad (ACA) calls on the Department of Defense to restore overseas voting forms.

Washington, D.C.
October 30, 2026

American Citizens Abroad (ACA) calls on the Department of Defense to restore overseas voting forms. Earlier FVAP forms can still be used: Eligible Americans abroad should vote by November 3

Washington, D.C., October 29, 2026. American Citizens Abroad (ACA), a nonpartisan, non-profit, 501c4 advocacy  organization representing U.S. citizens living overseas, today calls on the Department of Defense and its Federal Voting Assistance Program (FVAP) to restore the previous Federal Post Card Application (FPCA) and Federal Write-In Absentee Ballot (FWAB), and to put any future changes through full public review.

Voters first. FVAP has advised states they may continue to process earlier versions of the forms, and the FWAB remains available as a backup ballot. Eligible overseas voters should not be deterred.

It may not be too late to register. Several states allow overseas voters to register and request a ballot later than the usual 30-day cutoff, and some accept the FWAB as a registration, ballot request and ballot in one, provided it arrives before the state’s deadline. A FWAB must be sent no later than Election Day, and some states require it to arrive by then. Deadlines vary by state, so voters should check theirs and contact their local election office now. Overseas Vote Foundation provides guidance for overseas voters, including an explanation of the form changes at www.overseasvotefoundation.org and www.overseasvotefoundation.org/blog/fpca-fwab-changes-what-voters-need-to-know.

In late August, 67 days before a federal election, the Department changed both forms through an emergency procedure approved by the Office of Management and Budget (OMB), without prior public comment and, as far as ACA is aware, without consulting the election officials who process the forms. The comment period closes on November 9, six days after the election the changes now govern.

ACA has three concerns:

Eligible voters are left without an accurate option. The forms no longer offer a checkbox classification for U.S. citizens born abroad who have never lived in the United States. Voter qualifications are for the states, and at least 37 states and the District of Columbia give these citizens a route to vote. Removing the checkbox does not make them ineligible; it leaves them without a truthful answer on a sworn application.

An ID option election officials cannot yet verify. The revised form steers voters without a driver’s license or Social Security number toward documents such as a passport, although federal law provides for a state-assigned identifier. As far as ACA is aware, no passport-verification system is available to election officials for this election. Applications that cannot be verified risk rejection too late to correct.

An emergency asserted, not demonstrated. The Department cited no complaint, no incident and no request from any state, and stated that “no additional steps are necessary to consult with interested parties.” No federal deadline required replacing forms that states may still accept.

ACA asks the Department and FVAP to restore the previous forms pending full review; to tell voters and states clearly, now, that prior versions remain valid; to publish the emergency justification and the evidence behind it; to republish the notice with the revised forms and a full comment period outside the election season; and to consult state election officials and overseas-voter organizations before any further change.

Roland Crim, ACA Director of Voting Affairs, said: “A form is not a law. The Department can redesign a form, but it cannot redefine who is eligible to vote, and it should not leave eligible Americans guessing whether they still qualify. Comments filed on November 9, six days after the election these changes govern, cannot remedy a decision made in August without meaningful consultation. The right remedy is to restore the forms previously in use, and then to hold the debate that should have taken place before any change was implemented.”

Media Contact:
Marylouise Serrato
ACA Executive Director
[email protected]
+1 202 322 8441

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