Texas SB 2166: New Testing Requirements for Voting Systems and ePollbooks

Texas Senate Bill 2166 was passed during the 89th Legislative Session and makes several changes to testing requirements for electronic voting system equipment and electronic pollbook systems.

At a high level, SB 2166 is about testing, transparency, and documentation.

For election offices, however, the operational impact is broader than simply adding another item to the election calendar.

What Actually Changed?

According to the Texas Secretary of State’s 2025 legislative summary, SB 2166 modifies the requirements for the Public Logic and Accuracy Test and tabulation testing for electronic voting system equipment. It also requires Logic and Accuracy Testing for electronic pollbook systems.

The Secretary of State summary states that:

• Public Logic and Accuracy Testing and tabulation testing must be conducted at the same time
• Testing procedures distinguish between precinct scanners and central accumulators
• Notice of public testing must be published on the political subdivision’s website at least 48 hours before the test begins
• The general custodian must demonstrate, using a representative sample of voting system equipment, that the source code has not been altered
• A Logic and Accuracy Test must be conducted for electronic pollbook systems
• The ePollbook test must be conducted at least 48 hours before voting begins
• Notice of the ePollbook test must be posted on the entity’s website at least 48 hours before the test begins

Why This Matters Operationally

For many election offices, testing is already part of the preparation process.

What SB 2166 does is make certain testing expectations more formal, more visible, and more time-sensitive.

For electronic pollbooks, this raises practical questions around:

• when the voter file is loaded
• whether ballot styles and precinct assignments are ready
• how test voters or test scenarios are prepared
• how the test is documented
• whether notices are posted on time
• how changes after testing are handled

The law creates a timeline, but each office still has to build the internal process that supports that timeline.

Why Timing Matters

The ePollbook test must be conducted at least 48 hours before voting begins.

That timing matters because election offices are often still receiving updated voter files, finalizing ballot styles, preparing devices, assigning equipment, training workers, and coordinating with other vendors close to the start of voting.

If an issue is found during testing, the office needs enough time to correct it, document the correction, and determine whether additional testing is needed.

That makes the testing calendar more than a compliance item. It becomes part of election readiness planning.

What Election Offices Can Review Now

As offices prepare for future elections under SB 2166, some practical questions are worth reviewing:

• Who is responsible for preparing the ePollbook test?
• What scenarios should be included in the test?
• How will the office document the results?
• When does the website notice need to be posted?
• What voter file will be used for testing?
• What happens if the voter file changes after the test?
• How will testing of the ePollbook align with voting system L&A testing?

These are not just technical questions. They involve scheduling, documentation, vendor coordination, and internal procedure.

Continuing the Conversation

SB 2166 makes testing requirements more specific for voting systems and electronic pollbooks.

For election offices, the real work is turning those requirements into a repeatable process that can be documented, explained, and completed on time.

As jurisdictions prepare for upcoming election cycles, ePollbook testing will likely become a more visible part of election readiness.

How is your office thinking about ePollbook L&A testing, timing, and documentation?