Open Doors: Unauthorized Entry of Non-Citizens onto New York’s Voter Rolls

Project CIVICA has just released a detailed examination of New York county voter rolls. The findings raise serious questions about how the state’s voter-registration system actually works in practice. Across just 14 counties — about 10% of New York’s population — we identified approximately 10,680 records carrying clear indicators of non-citizenship. Of those, 88 unique records show that the individual voted. Some of those votes occurred as recently as 2024 and 2025. The voting records appear in 12 of the 14 counties we examined.

The records fall into two primary categories:

• Type 1 – County-determined non-citizenship: Approximately 463 records contain a local status or reason code indicating the Board of Elections determined the person was not a U.S. citizen. 34 of these show voting history.

• Type 2 – Negative citizenship response (“N”): Approximately 10,248 records contain an “N” in the citizenship field. 57 of these show voting history.

Some records are dual-flagged, carrying both indicators. The overwhelming majority of the flagged records have now been purged, though a smaller number remain Active or Inactive.

The most striking finding is the source of the records.

In the most complete source field we examined, 96% of the records originated from DMVI — the Department of Motor Vehicles’ online / internet transactions.

Across every available source field, DMV and DMVI transactions dominate. Even when looking at other source fields, the pattern holds. In the Original Registration Source field, DMVI still accounted for 76%:

And in the Last Saved Registration Source field, DMVI remained the largest single source at nearly 60%:

This is the core system failure: thousands of applications that answered “N” (not a citizen) were still transmitted from the DMV into the election system.

The risk is heightened by the interaction of two separate policies. New York’s Green Light Law allows individuals to obtain a standard driver’s license without proving citizenship or lawful presence. At the same time, the DMV transmits voter-registration applications based largely on self-attestation. The Green Light Law itself does not require or authorize the transmission of voter registration applications from non-citizens.

Under New York Election Law and regulations (including 9 NYCRR § 6217.5 and Part 6223), an application that answers “N” is incomplete. It should not be transmitted by the DMV or any designated agency. It should not receive a statewide identifier (SBOEID). It should not become a voter record.

Despite these clear rules, the data show that large numbers of “N” applications were transmitted, accepted, processed, and in some cases assigned statewide identifiers and allowed to vote.

When counties later cancelled these registrations because the person was not a citizen, the statewide NYSVoter database most often recorded the reason as “Duplicate” (and sometimes “Death” or “Moved”). New York’s regulations contain no standardized non-citizen reason code. The available codes do not accurately reflect a citizenship-based cancellation and systematically obscure the actual reason for removal.

These patterns raise substantial compliance questions under the Help America Vote Act (HAVA), the National Voter Registration Act (NVRA), and New York Election Law. The problems appear at multiple stages of the registration pipeline: agency transmission, county acceptance and processing, statewide database coding, and preservation of the audit trail.

The 14 counties we examined represent only a fraction of the state. Many other counties do not release the citizenship-indicator or non-citizen reason-code fields necessary for comparable analysis. The true statewide scale is almost certainly larger.

• How did thousands of applications that answered “N” (not a citizen) get transmitted by the DMV into the voter registration system?

• How did some of those records receive statewide identifiers and voting history, some as recently as 2024 and 2025?

• Why does NYSVoter systematically record non-citizen cancellations mostly as “Duplicate”?

• Why isn’t there a non-citizen cancellation code at the state level?

• Can the State produce a complete audit trail for these records?

This analysis is based on primary county voter-roll data obtained through Freedom of Information Law (FOIL) requests, compared against independent snapshots of the statewide NYSVoter database.

The Full Report and Executive Summary, including detailed data tables, source analysis, legal provisions, and methodology — is available at ProjectCIVICA.org.