2025 Arizona Elections Procedures Manual: What It Means for Tribal Voters

September 12, 2025

Submitted by

STATE CAPITOL, PHOENIX

PHOENIX - The Draft 2025 Elections Procedures Manual (EPM) sets operational guidance for Arizona’s 15 counties and, once approved, has the force of law.

For tribal communities, the draft continues the 2023 manual’s core protections—access to voter registration, acceptance of tribal identification and documents, consultation on polling place siting on or near tribal lands, placement of official ballot drop boxes at tribal government buildings, language assistance for covered jurisdictions, treatment of Indian census numbers as confidential, and operational reminders such as Daylight Saving Time observance on the Navajo Nation.

Based on ITCA’s review, the 2025 draft emphasizes clarity and continuity rather than wholesale changes to tribal related policy. This report synthesizes those provisions, evaluates potential positive and negative impacts for Native voters, and outlines implementation considerations for counties and tribes ahead of final approval. Legal & Timeline Context

• A.R.S. § 16 452 requires the Secretary of State to prescribe election procedures, in consultation with county election officials. In odd numbered years, the Secretary must transmit a draft EPM to the Governor and Attorney General by October 1; approval is due by December 31.

• For 2025, the Secretary of State opened public comment on August 1 and closed the portal at 5:00 p.m. on August 31, 2025. The transmittal deadline is October 1, 2025. Tribal Related Provisions in the Draft 2025 EPM Registration Access (Forms to Tribal Governments) County recorders and the Secretary of State provide voter registration forms to tribal government agencies, supporting on reservation registration and updates. Potential Positive Impacts:

• Streamlines access to official forms for tribal residents and outreach teams; supports continuous, compliant registration activity on tribal lands. Potential Risks/Negative Impacts:

• Requires consistent inventory management so that tribal offices have current forms; counties should designate a liaison for distribution and replenishment. Proof of Citizenship (DPOC) & Tribal Documentation The draft maintains acceptance of tribal documentation—such as tribal enrollment or census documents and other established tribal/bureau records—within the statutory proof of citizenship framework. Potential Positive Impacts:

• Reduces registration rejections when standard state documents are difficult to obtain; acknowledges valid tribal/bureau sources. Potential Risks/Negative Impacts:

• County staff require periodic training and job aids to recognize and process the full range of tribal documents consistently. Residence & Non Standard Addressing The manual continues guidance allowing non standard or descriptive addresses and the use of tribal identifiers where conventional addressing is limited. Potential Positive Impacts:

• Improves access for voters in rural or traditional housing areas on reservations; supports accurate precincting when street addressing is unavailable. Potential Risks/Negative Impacts:

• Risk of geocoding errors or mismatches if poll books are not configured for descriptive addressing; requires clear county procedures for reasonable match determinations. Voter Identification at the Polls — Tribal IDs Tribal identification and specified tribal documents remain acceptable within the state’s proof of identity lists, with existing Native voter protections for scenarios where address elements are not present. Potential Positive Impacts:

• Minimizes unnecessary return trips to provide supplementary ID; reduces confusion for voters presenting tribal credentials. Potential Risks/Negative Impacts:

• Poll workers need refreshers on list combinations (photo/address/name) to avoid inconsistent application and provisional ballots. Polling Place Siting & Consultation on/near Tribal Lands Counties with tribal lands should consult with tribal governments to ensure a reasonable and adequate number of voting locations on or near tribal lands. In remote areas, a single central site on tribal lands may be designated. Potential Positive Impacts:

• Promotes access, trust, and culturally aware site selection; central sites can reduce travel burdens in dispersed communities. Potential Risks/Negative Impacts:

• Requires early facility coordination, IT and connectivity checks, and MOUs for access and hours; transportation planning must match local realities. Official Ballot Drop Boxes at Tribal Government Buildings The draft allows drop box placement inside or in front of tribal government buildings with appropriate security and chain of custody procedures. Potential Positive Impacts:

• Provides a convenient return option for ballot by mail voters on reservations; can reduce travel and mailing delays. Potential Risks/Negative Impacts:

• Demands coordinated retrieval schedules and clear signage; counties and tribal facility managers must align on custody and monitoring protocols. Language Access (Section 203) & Bilingual Staffing Jurisdictions covered by Section 203 must provide language assistance; historically oral tribal languages require oral assistance. The draft underscores collaboration with Tribes on terminology and staffing and encourages recruiting bilingual poll workers (e.g., Navajo, Hopi, Tohono O’odham, Apache, Paiute, Yuman). Potential Positive Impacts:

• Improves clarity, accuracy, and community trust in translations and assistance; strengthens voter understanding of processes and choices. Potential Risks/Negative Impacts:

• Interpreter coverage and translation approvals take time and budget; staffing during early voting and Election Day is a recurring challenge. Operations & Timing — Navajo Nation (DST) The manual reminds election officials that the Navajo Nation observes Daylight Saving Time, affecting opening/closing times and communications for border precincts. Potential Positive Impacts:

• Helps prevent closing time errors and public confusion; improves coordination across county lines. Potential Risks/Negative Impacts:

• Requires tailored public communications and staff briefings in mixed time observance areas. Privacy & Confidential Identifiers The draft treats sensitive identifiers (e.g., Indian/Native American census numbers) as confidential fields in voter records. Potential Positive Impacts:

• Protects voter privacy and reduces risk of exposure through public records requests. Potential Risks/Negative Impacts:

• County workflows must consistently flag and redact; front line staff need reminders about handling these numbers. Comparative Notes vs. the 2023 Elections Procedures Manual

• Most tribal related provisions in the 2025 draft mirror the 2023 manual’s framework: acceptance of tribal IDs and documents, consultation on siting voting locations on or near tribal lands (with allowance for a central on reservation site in remote areas), drop box placement at tribal government buildings, Section 203 language assistance with oral support for historically oral languages, recognition of Navajo Nation Daylight Saving Time, and confidentiality for Indian census numbers.

• Where differences appear, they are primarily clarifications or emphasis—e.g., stressing collaboration with Tribes on language translation quality and staffing pipelines—rather than changes to underlying policy requirements. Implementation Considerations (for Counties and Tribes)

• Siting & MOUs: Initiate consultation early; confirm connectivity, accessibility, and security for proposed locations; memorialize access, hours, and facility needs in MOUs.

• Poll Worker Pipeline: Build and maintain a bench of bilingual workers and interpreters with schedules that cover early voting and Election Day; coordinate training on tribal IDs and list combinations.

• Registration & DPOC Job Aids: Provide visual guides of acceptable tribal documents; train staff on non standard addressing workflows and reasonable match determinations.

• Drop Box Protocols: Align on placement, signage, retrieval schedules, and chain of custody documentation for boxes at tribal buildings.

• Communications: Publish clear closing time communications for precincts near or within the Navajo Nation; ensure translation/interpretation is ready for outreach materials.