Policy Corner: NVRA Implementation Plan

Originally published September 09, 2025
Library Developments Blog  |  Library Development and Networking Division

Texas State Library and Archives Commission

As we turn our attention to National Voter Registration Act (NVRA) compliance, consider the following scenario in which a well-intentioned effort to help patrons engage civically revealed how the absence of an implementation plan can lead to inconsistent practices, legal risk, and unintended harm to public trust.

The Gotham Public Library—a fictional, small, rural library in Texas—hosted a well-attended community resource fair in partnership with the Madame Selina Kyle Foundation and Gotham City Hall. As part of the event, library staff helped visitors apply for library cards, sign up for public computers, and learn about available social services. With the much anticipated mayoral race between Oswald Cobblepot and Bella Reál coming up, the table that included information about voting was doing brisk business in staff being asked by attendees where they can register to vote or update their voter registration. Since the library lacked a formal NVRA Implementation Plan, its workers were unsure how to respond and replied inconsistently. Although staffer Richard Grayson provided voter registration applications, some of the volunteers declined—unintentionally creating unequal access or the perception of political bias. Further illustrating the point, the Texas Secretary of State’s office called the following Monday to inform Director Gordon of the library’s lack of documentation on file with the agency.

According to Chapter 20 Section 20.001(c) of the Texas Election Code: Each public library, including any branch or other service outlet, is designated as a voter registration agency. In this chapter, “public library” means a library that:

• is regularly open for business for more than 30 hours a week;
• is operated by a single public agency or board;
• is open without charge to all persons under identical conditions; and
• receives its financial support wholly or partly from public funds.

If your library meets the definition above, then it is a designated voter registration agency. Because having a formal NVRA Implementation Plan in place facilitates the library’s ability to respond confidently, consistently, and lawfully, revisiting yours ensures that the library’s practices support civic access while protecting not only patrons but also this trusted community institution. So, as you look at your NVRA Implementation Plan, here are some questions and resources to help make sure it is compliant, practical, and community-centered.

Questions to Consider While Revising or Creating An Nvra Implementation Plan:

• What is the library’s mission statement, and how is it reflected in the plan?
• If the library’s mission emphasizes equal access to information, how does the implementation plan’s dissemination of voter registration information to eligible patrons support that?
• If the library’s mission statement highlights responsible use of public resources, how does the implementation plan demonstrate stewardship in terms of documenting compliance with federal and state law, training staff appropriately, and reducing institutional risk?

• How will you manage registering voters?
• When and how will the library act as a voter registration agency (e.g., during specific services, programs, or interactions)?
• Who is responsible for coordinating NVRA activities, maintaining materials, training staff, ensuring compliance, and serving as the point of contact?
• How will the library offer voter registration information or applications, respond to patron questions, and provide assistance in a neutral, nonpartisan manner?
• What is the list of approved voter registration materials (e.g. paper forms, links, signage)? Where and how will they be made available?
• How will library staff be trained and how will required activities be tracked?
• What activities are prohibited (e.g., advocacy, persuasion, targeting) and what are the expectations for maintaining political neutrality?
• What steps—consistent with the law and library policy—will be taken to ensure voter registration information is accessible to patrons with disabilities or limited English proficiency?
• What are the procedures for handling NVRA responsibilities during outreach events, collaborations, or community programs?
• How will this plan be maintained and revised over time? What is the schedule and process for reviewing and updating the plan as laws, guidance, or library services change?

• Are you working with an attorney?
• Only an attorney can provide legal advice. This could be a City or County Attorney, an attorney on retainer, or an attorney on the board.
• If you’re not currently working with an attorney, have you contacted other libraries in your area to see if there is someone they’d recommend?

General Suggestions for Library Policies:

• Use plain language: aim for a clear and concise summary that can be understood by any community member, even those that have never been to the library.

• Separate policy from procedure: a policy explains what the rules are, while this implementation plan explains how staff and patrons carry them out in practice. For example, a library policy that includes voter registration might affirm the library’s commitment to lawful, nonpartisan voter registration practices; cite the NVRA and applicable Texas guidance; define the library’s stance on neutrality and equal access; and establish authority and accountability. Whereas, an NVRA Implementation Plan might specify when the library acts as a voter registration agency; detail staff roles, workflows, training, and materials; provide guidance for programs, outreach, and patron interactions; and support consistency and compliance across locations and shifts. Keeping policies and procedures separate will ensure that each document can be updated easily.

• Review regularly: reviewing all policies on a regular schedule will help ensure they’re up to date and useful for patrons. It might be helpful to question: Is it a simple change in wording or is it broken? Could your grandmother understand the policy? Does your policy reflect the actual practice? Has the policy kept up with the times? Is there still a viable reason to have the policy? Finally, incorporating legal review by an attorney (a City Attorney, County Attorney, board member, etc.) is highly recommended.

• Have policies approved by the library's governing authority: this adds legitimacy to library policies, and helps the governing authority understand how the library operates.

Related Trainings and Resources:

Writing Support

• Write for your audience - plainlanguage.gov website
• Clear & to the Point: The Importance of using Plain Language in your Communications - TSLAC, Literacy Advance of Houston webinar
• Jargon-Free Libraries: Using the Language of Our Patrons - Colorado State Library webinar

Policy Basics

• Library 101: Policies - North Dakota State Library short video
• Determining Whether a Document is a Policy, Procedure, or Guideline - University of Wisconsin Madison
• Notes on Library Policy - Vermont Department of Libraries
• Developing and Writing Library Policies and Procedures - By Stephen Henson of BE&K Engineering. Includes an excellent list of additional sources.

Guides and Examples

• NVRA Guide to Implementation - TX Secretary of State
• Implementing NVRA in Public Libraries - TX Secretary of State
• Sample Texas State Agency NVRA Implementation Plan - TX Secretary of
• Example NVRA Implementation Plan - Converse Public Library
• Example NVRA Implementation Plan - Hamilton Public Library
• Example NVRA Implementation Plan - Taylor Public Library
• Example NVRA Implementation Plan - Blanco County South Library District

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For the full details about serving as a voter registration agency, see the Texas Secretary of State’s website where you can find guides and training specifically for public libraries.

And, if you’re in need of a thought partner as you work on your library’s NVRA Implementation Plan or additional Texas library examples, don’t hesitate to reach out. Email our Library Development and Networking team at ld@tsl.texas.gov