The Arizona Protocol: The New Gold Standard for Election Transparency



The forensic election audit  currently underway  in Maricopa County, Arizona is, without a doubt, unprecedented. No election audit of this kind has ever been performed in the history of the United States. For decades, hand recounts and risk-limiting audits have been the status quo for addressing challenges to election outcomes. However, these methodologies can fail to detect  exploits to election systems and can no longer be considered sufficient.

The Arizona Protocol has set a new standard of thoroughness and transparency and will serve as a template going forward. This document seeks to detail the processes and procedures of  the Arizona audit and advocates for a substantially similar forensic audit implementation throughout the country. The auditors in Arizona are currently finalizing their audit report in Arizona and we expect that additional discoveries in Arizona and other states will prompt updates to this document.

Our goal is crystal clear: We seek to establish the Arizona Protocol as the minimum standard for conducting any election audit in the United States. All grassroots communities that mobilize to compel their local and state officials to conduct election audits should demand an audit that substantially adheres to the Arizona Protocol. Doing so will ensure that all evidence is thoroughly examined and will leave little to no opportunity for fraudulent or careless behavior.

The reputation and integrity of the companies and individuals performing the audit is paramount. All procedures must be performed legally and ethically to ensure the broadest acceptance of the audit results . Maintaining voter privacy, for example, is of the utmost importance. This Protocol is thorough, and therefore it is time and resource intensive. One should not expect that the audit will be completed quickly. Remember that the ultimate purpose of any audit is to maintain and/or restore accuracy, integrity, and confidence in the election system. Therefore, each step must be executed deliberately and with care. Failure to comply with applicable laws during the process could compromise the results and ultimately void the audit findings.

The Objectives of a Full Forensic Audit

First and foremost, the objective of any audit is to restore and maintain confidence in the integrity of an election system. This can only be achieved by investigating all aspects of an election. Therefore, the main objectives of a full forensic audit are as follows:

  • Verifying the accuracy of security measures used for election integrity. If gaps are found,  actions will be identified that can be taken to correct and fill the gaps legislatively.
  • Provide sufficient transparency to the electorate to ensure confidence and accuracy in the election process.
  • Hold our elected officials in charge of administering elections accountable. “Trust but verify.” – Ronald Reagan 

Risk-Limiting Audits Are Not Sufficient.

We Must Audit Everything!

In a risk-limiting audit, a random sample of ballots is compared to the voting machine’s computer records using a manual process. However, this style of audit has several fatal flaws.

First, these audits only seek to examine a small fraction of the paper ballots cast in an election. These supposedly “random” samples are also typically hand-selected by county officials who were charged with conducting the election under audit (the fox guarding the henhouse).

Another major problem is that a simple predetermined marking of the ballots or numbering of batches can be used to strategically manipulate this type of audit to avoid finding fraud.

Stark, PhD., is a Professor of Statistics and Associate Dean of Mathematical and Physical Sciences at the University of California, Berkeley. Stark was appointed by Nancy Pelosi to serve on the board of advisers for the U.S. Election Assistance Commission, and he is the inventor of the risk-limiting audit.

  • Stark stated in a presentation that “Current ballot-marking devices can be hacked undetectably to alter outcomes.”

“They are not software independent.” Stark went on to explain that an audit would not detect when the machine’s output generated a different voting preference than what the voter intended, “because there is no way for the audit to close that gap between what the user did on screen and what was actually printed on paper.”

  • As a result of this simple fact, it is possible for risk-limiting audits on ballot-marking devices or contracted vendors to be manipulated.


Here are a few audit bills that the legislatures are passing in each state. Please review to ensure the methods they are choosing are in compliance with the Arizona audit standards.

We Must Examine Voting Machines 

Inventor Jovan Hutton Pulitzer successfully hacked into a Dominion voting machine in real-time during a Georgia Senate Judiciary subcommittee hearing in December 2020, demonstrating that Dominion machines can connect to the Internet. 

This discovery left many Americans quite puzzled since they felt they had been led to believe that this was not possible. (Dominion CEO Testifies at Michigan Legislature Hearing Video)

Pulitzer has explained how voting machines maximize the opportunity for fraud. In some states, ballots are handed to someone who uses the machine to mark the oval for the chosen candidate, which is then handed to another person who is to place the ballot through a scanner. (Georgia Hearing Video)

The voter then walks away, never really knowing for sure if the vote was counted since they did not actually see it happen. 

Instead, if a ballot is not filled out correctly, it goes into another electronic bin. From there, an election worker will try to determine how the voter intended to vote (also known as “adjudication”) and complete the ballot using their best guess. In other words, the final ballot counted is not actually filled out by the voter! This creates many opportunities for people who want to game the system. (Understanding The Election Audits and The New Gold Standards Video)

Election Transparency Is the Right of Voters.

The lack of transparency and cooperation from elected officials following the 2020 election left millions of voters questioning the result.  Today, millions of voters remained unconvinced that the 2020 Presidential election was legitimate. 

Elections and state government officials’ salaries are paid for by the American people, yet our movement has been met with opposition every step of the way. Voters are entitled to investigate their elections at any time. 

America should have the most transparent and secure elections on earth. Software used in voting machines may contain defects and uncovering this defect can be challenging. Correct security measures put in place in an open-source model for voting systems can bring confidence to the election process. Transparency in the development of the election system is something every voter should want.

However, we have seen Secretaries of State, like Brad Raffensperger of Georgia, file amicus briefs to block the unsealing of ballots in Georgia. We have seen FOIA requests be blatantly ignored.  In the midst of a forensic audit, Maricopa county officials (Maricopa County Board of Supervisors) have still failed to turn over the passwords and routers that were ordered to be delivered under subpoena. These are just a few key examples of how elected officials are fueling suspicion and further claims of fraud.

If elected officials are truly concerned with ending what has been commonly referred to as “baseless conspiracy theories,” they should readily accept that the only path to curbing such claims is to actually refute them.

There are currently millions of law-abiding, tax paying citizens who believe that the election was stolen and may very well have lost all faith in the process. Without restoring confidence via election audits, many Americans may never vote again. This should be seen as an absolute tragedy and be rectified immediately.

Audit Everything, and Everywhere.

Phillip Stark believes that citizens should have full access to all aspects of the election. A summary report from the 2018 Election Audit Summit, to which Stark contributed, “Convincing the public that the election was properly conducted and that the correct winners were declared is a core activity of establishing legitimacy in a democracy.” An essay by R. Michael Alvarez included in the summary report advocates for the necessity of employing multiple procedures and methodologies to “audit everything,” i.e., all aspects of the election, from mail-in ballots to machines. Alvarez refers to this as the election jurisdiction’s “eco-system.” Alvarez agrees that every stage of the audit process should be viewed by the citizens, just as citizens have had 24/7 access to the live streaming of the Maricopa County Audit being conducted in Arizona by the State’s Senate.


Now more than ever, the “audit everything” process should be performed everywhere across the country as a response to the overwhelming amount of election irregularities that concern a large number of Americans. We believe election integrity and faith in the electoral system cannot be fully restored unless a full forensic audit of the 2020 election is conducted nationwide (including the US Senate runoff on January 5th, 2021).

Who Should Perform an Arizona Protocol Audit?

To ensure the audit is accurate and free from malicious intent, the company managing the audit must be a qualified and neutral third party. As the audit manager, this company will oversee the entire audit process, including selection and oversight of subcontractors used to perform various aspects of the audit. In Arizona, the company Cyber Ninjas was selected by the Arizona Senate to conduct the Maricopa County audit . Cyber Ninjas is a privately held provider of software security consulting services. CyFIR LLC, a forensics laboratory in Montana, was subcontracted by Cyber Ninjas.

Recruit Volunteers.

  • Volunteer recruitment is critical to achieving the full benefits of an Arizona Protocol audit. Any plan to conduct an audit of this type using only paid staff and no volunteers increases the risk of a budget shortfall that could potentially hinder the full implementation of the Protocol. 

    Furthermore, opponents could use the costs as a reason to advocate against a plan to have a forensic audit. Over 2,000 people volunteered for the Arizona audit, each vetted with background checks. The audit team was staffed 12 hours a day, six days a week. 

    Arizona Senator, Wendy Rogers, praised Cyber Ninjas for their hard work and integrity, “These professionals have come so far in the many weeks that they have been conducting this audit in terms of best business practices, taking lessons learned and implementing various procedures.” Sen. Rogers pointed out that at no time were volunteers asked about their political party affiliation.

    Volunteers signed non-disclosure agreements prior to working on the audit, which prohibits them from disclosing any details or talking about their experience until the audit is over.

No Unauthorized Visitors.

Access to the audit site must be under the complete control of the security team(s) to ensure that only authorized individuals are permitted within the operational perimeter.

Visitors to the site must be on the pre-approved list to enter the premises. Visitors on the site must provide ID, and they must be escorted into the site by authorized audit personnel. Then, before stepping onto the counting floor, all cameras, cell phones, and writing equipment on their person must be surrendered until they leave the site.

Onsite Observers.

Observers are an essential part of the process, as each audit check and processes need to be scrutinized as much as possible. 

After the observers arrive, they check in with security at the entrance to verify that their name is on the list of approved observers. After entering the building, they go through a series of check-in procedures, receive their name badge and any possessions that may have been locked up and secured in their locker.

On the counting floor, observers are only permitted to carry a red pen and a piece of paper. The main job of observers is to report anything that may compromise the audit’s integrity. If an observer has concerns, they may only speak to supervisors and other observers. (In addition to the Arizona Protocol – it would be beneficial to see all complaints publicly logged to instill transparency every step of the way.)

Observers are essential for the audit processes to be scrutinized as much as possible. The presence of interested parties ensures more transparency and ensures that people have confidence in how the audit was conducted.

Security 24/7

Operational security of the audit activities is critically important. Just one security lapse or breach can potentially damage the public’s perception of the credibility of the audit results.

If the people demand an independent auditor, they should be prepared to privately fund their audit’s security through fundraising efforts. In Arizona, the citizens recruited the Arizona Rangers, an armed, uniformed volunteer law enforcement auxiliary formed in 1901 as a result of a bill passed by the twenty-first Arizona Legislative Assembly.

The Arizona Rangers are well known throughout the state and regularly provide uniformed security services at events. The security protocol was airtight at the Arizona Audit, with multiple security checkpoints, and COVID-19 testing throughout the entire facility. According to former New York police commissioner Bernard Kerik, the Arizona Audit security was so efficient because it “employed the same methods that casinos use to catch cheaters.”

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Cameras Everywhere.

Conducting the audit behind closed doors is not acceptable under the Arizona Protocol. Operational transparency is dramatically increased by live-streaming the entire audit site allowing anyone from around the world to observe all activities being performed, including in the off-hours. 

In Arizona, nine wide-angle feeds were used to live-stream 24/7 from the audit site giving full access to the public during the entire process. These live camera feeds allowed citizens to observe the auditing activities, which resulted in several reports of potential misconduct at the audit site. 


Additional cameras should be placed above each table over each audit task and used in the ballot examination and recount. In Arizona, each ballot is taken out of its box securely and placed under a high-definition microscopic camera that takes a 600+ dpi image that will be used to identify folds, creases, bends, and other kinematic artifacts. Taking these images is critical to enable other present and future reviews giving interested parties the ability to challenge and scrutinize findings publicly. 

Color-Code Everything.

The extensive use of color-coding provides a simple way for remote and on-site observers to detect and report suspicious behavior at the audit site and then logged on a public ledger.

Color coding helps to ensure audit workers adhere to their assigned jobs. The Arizona Audit used tape on the floor to create lanes for observers to enter and served as a reminder to maintain distance from the counting tables and ballot counters.

The floor was divided into multiple sections, each representing the different stages of the audit process. Audit supervisors oversaw every two to three tables.

All tables were color-coded, and the audit workers wear matching-colored T-shirts.

Ballot Evaluation.

Ballot evaluation isone of the most important audit activities. Each ballot is taken out of its box securely and placed under a high-definition microscopic camera that takes a 600+ dpi image that will identify folds, creases, bends, and other kinematic artifacts. Taking these images is crucial for further reviews in the future. (Paper Evaluation Tables Video)

Hand Recount.

Unlike a risk-limiting audit that recounts just a subset of ballots, the Arizona Protocol requires that every ballot be counted by hand. This is time-consuming and requires a structured and coordinated process that mitigates the risk of human errors or intentional miscounts.

Arizona used rotating tables throughout the coliseum, with teams of three “counters” sitting at each table. Every table has a camera on the top and on the side. The ballots are placed in the middle, and the table rotates to show all three counters. All three counters must match the tallies, and they are not permitted to speak to each other during the process. Each batch that is given to the counters has fifty ballots, and once all of them are counted, they are placed in a box, sealed, and the names of each counter are written on the boxes. The boxes are then placed into a locked cage, and the chain of custody is updated.

  1. A ballot is placed in the ballot tray on the turntable. The turntable then rotates to show the ballot to each of the three counters sitting at the table.
  2. Each counter will mark a single line (tally) in the ballot column, indicating that one ballot has been viewed. 
  3. Each of the three counters looks at the paper ballot and marks a single line in the column that corresponds to the candidate selected. 
  4. An enlarged image of the ballot is displayed on the monitor above the counter’s desk area, but the selection must also be confirmed on the paper ballot.
  5. All tally marks are made in the same row as that ballot number. After five ballots, the tally marks will be made in the next column down on the page.

Paper Examination.

Inspection of the physical ballots for potential counterfeit or fraudulent ballots is required by the Arizona Protocol.


In Arizona, high-resolution cameras were used to conduct digital imagery of the ballots. Factors such as the weight, texture, ballot watermarks, and vote bubbles are tested. Forensics equipment and cameras are used, allowing ballot examiners to tell whether a ballot was scanned, or someone filled it out with a pen.  (Paper Examination Video)

Chain of Custody.

Chain of custody is a fundamental part of an election and must be congruent in an election audit. Each and every aspect of the chain of custody must be recorded and kept for the purpose of tracking the movement of all ballots, boxes, and the individuals that touched or moved them. If court evidence cannot be submitted without a proper chain of custody, then the votes without a chain of custody are considered illegal and illegitimate.

In his paper An Introduction to Risk-Limiting Audits and Evidence-Based ElectionsPhilip B. Stark refers to any audit that attempts to obtain voter intent from electronic records and not a verifiable paper trail as “security theater,” meaning it is basically pointless since there’s no reason to trust that these records show the correct electoral outcome. Which begs the question of why the chain of custody seemed to be such an afterthought to those involved in running the 2020 election in areas such as Fulton County, Georgia

Stark, the inventor of the risk-limiting audit and one of the most trusted voices regarding election audits, believes an audit without a paper trail is not actually an audit. Below are a few of the steps that he recommends should be taken to evaluate the integrity of an election’s paper trail:

  • Record seal numbers whenever a batch of ballots is sealed.
  • Whenever a batch of ballots is unsealed, check the physical seals for signs of tampering.
  • Use numbered seals, hard to forge or bypass; check seal numbers against the numbers recorded when the boxes or bags were sealed and log the result.
  • Review custody logs. Check that at least two staff accompanied the ballots whenever ballots were not locked securely and under surveillance.
  • Review surveillance video of secure ballot storage facility to ensure there was no unauthorized access to ballots.

Machine Examination.

The analysis of voting machines and any other equipment used during an election should be of paramount concern for all citizens. In An Introduction to Risk-Limiting Audits and Evidence-Based Elections, Stark makes it very clear that while voter-verifiable paper evidence is required in evidence-based elections, it isn’t nearly enough evidence to increase voter trust in elections going forward.

The method used to mark the paper also needs to be investigated and should not make it harder for voters to verify that the paper record reflects their exact voting choices. 

In this paper, he also drives home his own doubts regarding the usability of ballot marketing devices (BMDs)– a stance which no one seemed to take into consideration in recent years. Stark believes that for voters without disabilities, hand-marking ballots may be a much better option for ensuring their voting choices are made accurately.

As of July 2nd, 2018, Stark strongly felt that there needs to be more usability research performed before these BMD systems are installed as the primary mechanism of casting votes. There has not been adequate usability testing on these machines. Stark made a strong recommendation not to certify them for use and instead allow all voters to vote by hand-marking a full-face paper ballot.

So, if a machine marks the ballot, what does Stark think could happen? He advocates for checking whether the machine accurately marks the ballot with the individual’s choice of candidates because “the technology might alter the vote as a result of miscalibration, bugs or hacking.” In a paper which Stark wrote in collaboration with Andrew W. Appel in 2020, Evidence-Based Elections: Create a Meaningful Paper Trail, Then Audit, they explain the reality of how a hacked voting machine can, in fact, change the outcome of an election, especially if most of the voters affected didn’t notice or report equipment problems. 

Stark and Appel also made another critical point about hacked voting machines: “The gap between voter-verifiable and voter-verified makes ballot marking devices (BMDS) unacceptable; hacked BMDs can steal the vast majority of the votes they set out to steal before those votes are recorded onto the paper trail. The same analysis applies to a DRE [Direct-recording electronic voting machine] +VVPAT [Voter-Verified Paper Audit Trail] system.”

Also, Stark was very clear that if our country expects safe and transparent elections, we must “develop a publicly owned, open-source voting system designed from the start to be accessible, secure, reliable, and auditable, and to run on commodity “off-the-shelf” hardware to the extent possible.” This type of machine would even be an advantage to taxpayers, Stark adds, since “current annual maintenance costs greatly exceed the cost of developing, acquiring and maintaining a system of this sort.” The voting systems used in the 2020 election, however, failed to meet several of these requirements. The question is since Stark was the authority on this, appointed by the Speaker of the House, why weren’t his warnings taken into serious consideration?

For the Arizona Protocol, anyone collecting, handling, and processing digital evidence must strictly adhere to the CyFir policies and procedures. To ensure evidence will be admissible in court, it must be obtained properly due to the critical and volatile nature of the data on the machines involved in the 2020 election. Every step must be thoroughly documented as well. The key aspects of the digital forensic examination, which are outlined in the manual below, are:

  1. Case assignment and prioritization
  2. Equipment testing, validation, and updates
  3. Evidence and property handling
  4. Search and seizure
  5. Storage and retention of evidence
  6. Reports
  7. Materials and supplies
  8. Digital forensic lab access
  9. Release of information to the media
  10. Quality assurance policy and process

Link: Cyber Ninjas Digital Evidence Handling Policies

Also, due to the resources and limitations of the Arizona Audit facilities, there have been some modifications made to the standard CyFIR digital evidence handling procedures. 

Link: Cyber Ninjas Audit Evidence Handling Procedures

Future Elections: Watermarked Ballots

A new watermarked ballot prototype is being considered for future elections. This prototype ballot has been shown around the country by State Representative Mark Finchem. (Arizona Ballot Integrity Project Video)

The ballot is embedded with the Great Seal of the State of Arizona, which is only visible under a black light. Arizona State Senator Wendy Rogers has also pointed out that in the past, any company could print ballots, which increased the chances of fraud significantly. But these new prototypes can only be created by a single company that has been authorized to print ballots. 

This prototype ballot has an additional feature that will benefit voters: a QR code that can be scanned with a smartphone camera to show the unique ID number of that ballot. This feature is critical to securing future elections since it prevents ballots from being duplicated and used for more than one vote. The QR code shows only a number and protects the privacy of the voter.


Full-Spectrum Transparency

The Citizens Audit

Along with the full forensic audit and hand recount, the citizens should conduct their own parallel audit. To compare results, the County Clerk or Secretary of State should provide voter rolls, voter tapes, and any additional public records to help the citizens conduct their analysis. The citizens’ audit will help support the government’s election process by catching any outliers early on before the election is certified to ensure a free and fair election for all runners and races. The more transparency the citizens have, the greater the chances are of restoring faith in our election integrity.

Disclaimer: The Arizona Audit has been by far the most impressive effort to ensure voter accuracy and has inspired PopulistRevolt to write about their scope of work. This document is provided for educational and informational purposes only. This document does not replace independent professional work created by Cyber Ninjas or any other contracted workers.

Statement of work:

Link 1: CyFIR – Digital Evidence Handling Policies

Link 2: CyFIR – Maricopa County Handling Procedures

Link 3: WAKE TSI – Counting Floor Procedures

Author: Jessica Geraghty – BA in Journalism and Political Science at The University of Connecticut

Contributing Editors: The RULER and Nick Moseder

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