This numbered memo addresses the requirements and procedures for conducting absentee ballot meetings, as set forth in state law. It also addresses questions that are commonly asked in connection with absentee meetings or the review and custody of absentee ballots.
1. Legal Requirements for Absentee Meetings
1.1 General Requirements
Beginning every Tuesday on the fifth Tuesday before Election Day, county boards of elections must hold a public meeting at 5:00 p.m. each Tuesday to review and act upon absentee ballots.1 The county board of elections may change the time of these meetings (to an earlier or later time) and may provide for additional meetings, but the county board cannot move the Tuesday meeting to a different day of the week. Any additional absentee meetings shall not be held prior to the fifth Tuesday before Election Day. Any meetings that are held at a different time on Tuesdays and any additional meetings must be noticed in a county newspaper at least 30 days prior to the election. The county board must also ensure the meeting is properly noticed under the open meetings laws, including notice to the county political parties.
At each absentee board meeting, the county board must act upon all absentee container-return envelopes received prior to that meeting and after the previous absentee meeting.2 An absentee meeting must be held if there are any absentee ballots that are ready for the board to review—even if there is only one to review. Absentee meetings should only be cancelled if the board has not received any absentee container-return envelopes since the last absentee meeting.3 If the county board anticipates a high volume of absentee ballots returned, it is strongly recommended that the board schedule additional absentee board meetings, schedule its meetings to begin earlier than 5:00 p.m., or a combination of both.
A county board may recess an absentee board meeting to a date and time certain if it is not possible to complete review of absentee ballots during the specified meeting period. The notice should be sent as soon as possible but it is not required to be sent 48 hours in advance of the reconvened meeting if that is not possible based on when the meeting was recessed from.
In order to determine whether any additional absentee meetings will be needed, the county board may consider how many absentee ballot requests the county has received to date, and how many total requests the county received for a similar election in the past, then estimate how many requests the board anticipates based on the county’s current rate of requests. The county board may also consider historical numbers of absentee ballots that were returned for a similar election.
1.2 County Board Member Attendance
Absentee board meetings require a quorum of members present. A quorum is three members.4
If at all possible, at least one member from each political party should be represented at each absentee meeting when the board is approving absentee applications. Because board members must be able to view absentee envelopes in order to approve or disapprove the ballot, a quorum of board members must be physically present during each absentee board meeting.5
Once a quorum is physically present, remaining board members may attend the meetings via live video feed, but they must have a secure way to view the meeting and to participate. They must be able to view all materials that board members are reviewing to make decisions on the absentee envelopes.
A majority of board members present at a meeting must vote for an action for it to pass.
1.3 Public Attendance
Absentee board meetings are public meetings and are subject to North Carolina’s open meetings laws. For absentee meetings, it is recommended that the county board locate a meeting room large enough to accommodate members of the public. If it is not possible to procure a space sufficiently large enough for those who may want to attend in person, the county board of elections should consider broadcasting the absentee board meetings via video feed using a service such as WebEx or Microsoft Teams.
The public in attendance must be able to see and hear the proceedings without compromising the secrecy of any voter’s ballot. The county board and staff must ensure that the public watching in person or on a video feed cannot view any voted ballots or other confidential information, such as a photocopy of a voter’s photo ID included with their ballot. The county board must also ensure the public cannot retain confidential information like a ballot identifier number (CIV, MIL, etc.) that is associated with the identity of a voter, which could occur if the number is read aloud in an open meeting. County board members and staff must be particularly mindful of ballot secrecy when duplicating ballots and inserting ballots into the tabulator. The county board shall follow the directions in Numbered Memo 2022-01 for maintaining the confidentiality of information or documentation relating to absentee requests, absentee applications on the container-return envelope, and photo ID documentation.
The public is not permitted to disrupt the process of adjudicating the validity of absentee applications by the board and is not part of the deliberation process during absentee board meetings. The decision of the county board of elections as to the validity of the absentee ballot application is final and is not subject to public comment, objection, or review.6
2. Procedures for Review of Absentee Ballot Materials
At each absentee board meeting, the county board of elections will review each absentee ballot container-return envelope and application to determine whether it has been properly executed and is accompanied by either a photocopy of the voter’s photo ID or a completed Photo ID Exception Form (photo ID documentation), and if so, to approve the application and ballot.7 Given the volume of absentee ballots the county board is required to review and act upon at each meeting, certain preparatory work should be performed by staff in advance, and the board should consider ways to streamline the process.
2.1 Delegation of Preparatory Work
The county board has the authority to delegate to its director “so much of the administrative detail of the election functions, duties, and work of the board, its officers and members, as is now, or may hereafter be vested in the board or its members as the county board of elections may see fit.”8 However, the board may not delegate to a director or other staff any of its quasi-judicial or policymaking duties and authority.
Based on the volume of absentee ballots a county board anticipates receiving, the county board should determine which preparatory tasks staff can complete prior to absentee board meetings. A delegation of administrative duties by the board to the director or staff should occur by majority vote. The delegation may be by resolution or the approved motion should be documented in the minutes. It should delegate specific preparatory steps that staff can perform prior to absentee board meetings, and the delegation must provide for oversight by the board. The delegation can be made for a single election or made to apply to all elections. If the delegation applies to all elections, the county board should review the delegation before each election in case changes may be needed.
Preparatory steps include:
- Inspecting container-return envelopes, applications, and photo ID documentation for deficiencies and contacting voters. Note that staff is required to do this by Numbered Memo 2021-03. It is not permissible to wait for the absentee board meeting to contact the voter about the issue, unless staff need the county board to make a decision whether there is an issue.
- Sorting container-return envelopes with accompanying photo ID documentation into categories for the board to review and take action (e.g., approve or reject).
- Verifying the list of container-return envelopes against the absentee pollbook.
- Performing ballot duplication with a bipartisan team.
A delegation of administrative duties to the director or staff does not need to include a preliminary review of photo ID documentation for deficiencies or contacting voters about curable deficiencies because these tasks are already assigned to staff by administrative rule and statute.9
2.2 Staff Review of Envelopes
Upon receipt of an absentee ballot at the county board office, staff must review the absentee ballot materials: the photo ID documentation, container-return envelope, and application. Staff review must occur within one business day of the receipt of the ballot, and staff shall follow the procedures in Numbered Memo 2021-03 to identify and address any issues with the materials.
Staff should then perform an initial sort of container-return envelopes into categories upon initial review and present those recommendations to the board at each absentee board meeting. Those categories may include designations for recommended approval, recommended disapproval, pending cure or confirmation from the voter, and those that staff have questions about and which require deliberation by the board. A delegation may also require staff to prepare a report to the board indicating the number of ballot envelopes in each category for reconciliation purposes.
2.3 Board Review of Envelopes
The county board may choose to review all absentee envelopes and materials, or the board may, by majority vote, choose to accept staff’s recommendation for absentee applications that staff have reviewed and recommended for approval. If the board votes to accept staff’s recommendations of approval, then the delegation must include a process for the board to first review a meaningful number of the envelopes, applications, and photo ID documentation to ensure accuracy and consistency. However, the board must individually review all: (1) applications that have been recommended for disapproval by staff; (2) envelopes, applications, or photo ID documentation that either have a cure certification or documentation associated with it; (3) absentee materials where staff need further guidance from the board as to whether it meets all legal requirements, such as those discussed in Numbered Memo 2021-03; or (4) ballots that were duplicated.
It is also permissible for bipartisan teams of board members to pair off to review absentee ballot envelopes during each meeting, if the board votes to allow this.
Whether the county board delegates the initial review of absentee ballot materials to staff or chooses to have a bipartisan team of board members review envelopes during the meeting, all board members present at the meeting must vote to approve or disapprove the ballot applications.
A decision as to whether an application is properly executed and whether the photo ID documentation meets all requirements must be decided by a vote of the board as a whole and not by individual members.10
Review of Photo ID Exception Forms
The board must also individually review all completed Photo ID Exception Forms where staff has indicated that available information may lead the board to conclude that the Form is false or where a board member raises a question as to the falsity of the Form after staff review. A board’s decision to disapprove a ballot based on a finding that a voter’s Photo ID Exception Form is false can only be made by unanimous decision of all members of the board participating in the vote, and that decision must be in writing.11 Note that a decision to disapprove a ballot for any other reason, or to approve the ballot, is by majority vote.
When all county board members, or one fewer than all members, “have identified a specific reason, based only on facts and not speculation, to find that the [photo ID exception form] is false,” then the voter must be given notice and an opportunity to address the county board on the information that will be considered by the board. But if at least two board members do not agree that there are grounds to believe the affidavit is false, then no notice is required to be sent to the voter and their photo ID exception form cannot be rejected for being false.12
The voter may address the county board about their photo ID exception form that is submitted with their absentee ballot at a board meeting. This could be at a pre-Election Day absentee meeting. However, this must be at a meeting no later than the post-Election Day cure deadline meeting that must be held on the fifth business day after Election Day so the county board can “announce the tally of all absentee ballots, except those subject to a challenge or those cast in accordance with Article 21A of this Chapter.”13
If the board is considering a finding of falsity, the board’s review of the envelope should remain in a pending status until the absentee meeting at which the voter has the opportunity to be heard, and the board can only make a final decision on the approval or disapproval of the envelope after the voter has that opportunity to address the county board regarding their Form. Numbered Memo 2023-03 contains guidance as to what may be considered by a county board when reviewing a voter’s Photo ID Exception Form.
Review of Photo ID Photocopies
If the board reviews a photocopy of a voter’s photo ID, which staff have identified as being acceptable, but unanimously determines that the photocopy of ID does not meet all legal requirements, then that is treated as a curable deficiency and staff are required to notify the voter.14 The board’s review of the envelope should remain in a pending status until the post-cure deadline meeting on the fifth business day after Election Day. In this instance, the voter can still submit a new photocopy of their photo ID, or a Photo ID Exception Form, if they are unable to submit a photocopy of their photo ID.
Review of Deficient Photo ID Documentation that Is Uncured
If staff has indicated that a voter’s photocopy of their photo ID or Photo ID Exception Form is deficient, and the photo ID documentation remains uncured, the board must reserve its final decision on the approval of the envelope until the post-cure deadline meeting on the fifth business day after Election Day and, when doing so, must individually review the photo ID documentation that has not been cured.15 An uncured deficiency with the photo ID documentation does not prevent the board from making a preliminary determination on the envelope when staff has indicated further guidance is needed as to a potential deficiency, so that any envelope-related deficiencies can also be identified and the voter notified.
Formalizing Approval of Envelopes
After absentee envelopes and accompanying photo ID documentation are approved by the board, the task of stamping every envelope with “Approved” and stamping or otherwise affixing the chair’s signature or initials to the container-return envelopes may be delegated to staff. Alternatively, the board’s delegation may authorize the board to sign a cover sheet containing a list of envelopes that were acted upon during the meeting and indicating whether those envelopes were approved or disapproved in lieu of signing the individual envelopes.
3. Scanning Absentee Ballots at Absentee Board Meetings
Scanning and tabulating approved ballots are two different tasks that can occur at different times. “Scanning” is a preparatory step that occurs when the approved container-return envelope is opened, and then the ballot is removed from the envelope and inserted into the tabulator. The tabulator reads the ballots but does not print the totals at that time, and no election returns are released. “Tabulating” or “counting” occurs on Election Day and involves closing the polls on a tabulator and printing tabulated results from ballots that have been previously scanned. When the scanning and the counting of ballots occurs at any time before the close of the polls on Election Day, county board members and staff must keep in mind that it is a felony “for any person to knowingly reveal the result of any count of ballots prior to the close of polls on election day.”16
3.1 Pre-Election Day Meeting
A county board of elections may, by majority vote, decide to open the approved container-return envelopes and scan the absentee ballots during each absentee meeting.17 If a county board anticipates a large volume of absentee ballots, it is strongly recommended that the board authorize the scanning of approved ballots during absentee board meetings instead of waiting until Election Day. County boards are also encouraged to open the approved container-return envelopes to scan the ballots during the absentee board meetings because it may be possible that staff, upon opening the container-return envelope, identify a deficiency involving the ballot that would require it to be spoiled and a new ballot issued to the voter.18
The scanning cannot begin until a majority of the board members and at least one board member of each political party is in attendance. If a board member of each political party is not available, the chair or other member of the executive committee of the county political party of the absent member must be present. The political party representative shall act as an official witness to the scanning and shall sign the absentee ballot abstract as an “observer.”19
Staff may enter the approved ballots into the tabulator, but each board member present is responsible for and must observe and supervise the opening of the envelopes and scanning of the ballots.20 It is not permissible for approved ballot envelopes to be opened, for ballots to be removed from the envelope, or for ballots to be inserted into the tabulator outside of a board meeting. These tasks cannot be delegated to staff to complete outside of a board meeting.
If the board chooses to scan approved ballots during absentee meetings, it should consider ways to make the process as efficient and streamlined as possible. For example, the board could approve staff-recommended ballots first, then direct the staff to open those envelopes and enter the ballots into the tabulator while the board reviews the envelopes that require further consideration and those that staff have recommended be disapproved.
Scanning of ballots must be performed during a board meeting, and if scanning occurs before Election Day, ballots must be scanned at the same meeting during which they were approved.21 The number of approved absentee ballots must be reconciled with the number of ballots inserted into the tabulator. Reconciliation should be completed at each board meeting. If it is not possible to scan all approved ballots at that meeting, the board may recess the scanning to a time and date certain, which could be the next absentee board meeting. The county board should send out the notice as soon as possible but it is not required to be sent 48 hours in advance of the reconvened meeting. Ballots should be processed in groups, so that ballots from all opened ballot envelopes are processed in the same meeting.
3.2 Election Day Meeting
County boards are required to begin counting all absentee ballots on Election Day at a time between 9:00 a.m. and 5:00 p.m.22 The time and location must be stated in a resolution that is adopted by the county board at least two weeks prior to Election Day. A copy of the resolution for the counting of absentee ballots is no longer required to be published in a newspaper having general circulation in the county prior to the election, but county boards may still choose to publish the date and time of the meeting in the newspaper, which could be included with the published resolution for counting of early voting ballots required by N.C.G.S. § 163-182.2(a4). County boards may also choose to give notice of the meeting on a radio or television station or both. For public awareness and transparency, the county board shall post a copy of the resolution on its website.
At its meeting on Election Day, county boards must count all absentee ballots (civilian and UOCAVA) that have come in by the return deadline of 7:30 p.m. on Election Day, unless the ballot was challenged before 9:00 a.m. on Election Day. The county board is permitted to recess the meeting before completing the count of absentee ballots on the night of the election so that board members may take short breaks or take care of other board business as needed, but the county board shall not adjourn the meeting until the count of the absentee ballots is complete. County boards must also reflect any recesses in the full and accurate minutes of the meeting such that a person not in attendance would have a reasonable understanding of what transpired before and after any recess, and the minutes must include the number of outstanding absentee ballots immediately before and after any recess.23
No absentee ballot counting results may be released until after the polls close.
3.3 Post-Election Day Meetings
County boards must meet during the canvass period and again at the canvass meeting to take action on absentee ballots.
During the canvass period, county boards must meet on the fifth business day after Election Day to consider approval of any absentee ballots that required a cure and remained pending after Election Day, and to make any final decisions on absentee ballots where the voter’s photo ID exception form is being considered for a finding of falsity. The county board must then announce the tally of all absentee ballots that have been counted, except those subject to a challenge or those that are UOCAVA ballots.24
County boards also may provide for an additional meeting between Election Day and the day of canvass to count UOCAVA ballots that were timely mailed to the county board and received by 5:00 p.m. on the day before the canvass.25 If a county board plans to hold such a meeting, then it must adopt a resolution stating the time and location at least two weeks prior to Election Day. This resolution can be combined with the Election Day counting resolution discussed above. If the county board does not adopt a resolution to hold this additional meeting, then those UOCAVA ballots shall be counted at the canvass meeting along with any absentee ballots subject to a challenge.
4. Ballot Duplication
UOCAVA ballots and ballots that have been damaged or otherwise cannot be read by the tabulator must be duplicated in order to be scanned by the machine and to avoid having to manually enter the voter’s selections into the reporting software. County boards may adopt a policy to authorize a bipartisan team of staff members or poll workers to duplicate ballots outside of an absentee board meeting. The policy must include the following:
- Each bipartisan duplication team should consist of at least three staff members, and must not have more than two members, or all members, being of the same political affiliation. It is a best practice to have at least four members, two of each political party, to ensure accuracy.
- The director must supervise and train all members of the duplication team and may assign the following roles:
- Ballot Caller – Announces the voter’s selections listed on the original ballot to the Ballot Duplicator and Ballot Reviewer.
- Ballot Duplicator – Replicates the voter’s selections from the original ballot onto the machine-readable ballot as instructed by the Ballot Caller.
- Ballot Reviewer – Reviews the Ballot Caller’s readings from the original ballot and compares it to the selections recorded on the machine-readable ballot by the Ballot Duplicator to ensure accuracy. It is a best practice to have two ballot reviewers, one who will review the selection announced by the Ballot Caller and one who will review the selection made by the Ballot Duplicator.
- Prior to the start of the ballot duplication process, each member of the bipartisan duplication team must complete a participation log noting the date, time, and their name, role, and party affiliation.
- During the ballot duplication process, the duplication team is not permitted to leave each other’s immediate presence until the process has been completed, unless authorized by the director.
- All duplicated ballots must contain the following in the blank box at the top of each ballot:
- A notation (for example, “DUP”) to indicate the ballot is a duplicate of the original.
- The ballot number assigned to the voter.
- The precinct of the voter.
- When duplicating the original ballot onto the new ballot:
- The voter’s selections in all contests on the original ballot shall be replicated onto the new ballot.
- Under no circumstances shall the voter’s selections on the original ballot be altered, either permanently or temporarily.
- Upon completion of the process, the team must do the following:
- Ensure that the duplicated ballots are attached to the corresponding original ballots for the Board to verify at its next scheduled meeting.
- Enter the time of completion and their signatures to the ballot duplication log.
- Provide the completed duplication log and the ballots to the director.
- The director must ensure that the ballots are kept in a secured container until the next absentee board meeting.
- The board must review each duplicated ballot at its next scheduled board meeting prior to approval of the ballots.
It is a best practice to have a duplication team present at every meeting to duplicate any damaged ballots that are identified during the board meeting. Duplicating ballots at the board meeting when the ballot envelope was approved reduces the likelihood of mistakes.
5. Control of Board Meeting
The county board is responsible for maintaining control at its absentee board meetings. The county board must ensure that the public receives proper notice of the board meeting and is given the opportunity to attend. However, the county board should not permit public comment or questions while absentee envelopes and the accompanying photo ID documentation are being adjudicated, or while ballots are being duplicated, sorted, scanned, or tabulated. This will avoid disruption of carefully-managed proceedings, the potential for outside influence of the board’s decisions, and the potential for nonuniform review of ballots. Although the public must be permitted to attend the meeting and observe the process, they may not interfere with the election officials in the discharge of their duties.26
It is recommended that the board chair explain the process at the beginning of the board meeting and state that public comment is not permitted during the approval and scanning of absentee ballots. The board may, but is not required to, designate a separate part of the meeting for public comment.
At the end of each board meeting, the goal is total reconciliation of all envelopes, photo ID documentation, and ballots. To do that requires careful control of every document in the room. It also requires ensuring that the board members focus on the task at hand and that the public remains in an observer rather than a participant role. Envelopes, photo ID documentation, and ballots must not be allowed to be removed from assigned areas. A voter’s photo ID documentation must also be retained with the voter’s corresponding envelope. The reconciliation process shall ensure the number of ballot envelopes in each stack is tracked, and that the number of envelopes approved at the meeting is equal to the number of ballots entered into the tabulator. The county board shall record the count on the tabulator at the start and end of each absentee meeting. A sample reconciliation log that a county board may use is available here.
As noted above, the county board shall follow the directions in Numbered Memo 2022-01 for maintaining the confidentiality of information or documentation relating to absentee ballots.
- 1
N.C.G.S. §163-230.1(f).
- 2
See N.C.G.S. § 163-230.1(e): “At its next official meeting after return of the completed container-return envelope with the voter’s ballots, the county board of elections shall determine whether the container-return envelope has been properly executed.” (Emphasis added.)
- 3
See N.C.G.S. § 163-230.1(f), entitled “Required Meeting of County Board of Elections”: “During the period commencing on the fifth Tuesday before an election . . . the county board shall hold one or more public meetings each Tuesday at 5:00 p.m. for the purpose of action on applications for absentee ballots.” (Emphasis added.)
- 4
N.C.G.S. § 163-31(d): “A majority of the members shall constitute a quorum for the transaction of board business.”
- 5
See Numbered Memo 2022-08 regarding physical and virtual presence at absentee meetings.
- 6
N.C.G.S. § 163-230.1(f): “At these meetings, the county board shall pass upon applications for absentee ballots. . . . The decision of the county board on the validity of an application for absentee ballots shall be final subject only to such review as may be necessary in the event of an election contest. The county board shall constitute the proper official body to pass upon the validity of all applications for absentee ballots received in the county; this function shall not be performed by the chair or any other member of the county board individually.” The only exception to the board’s decision being final is if the board identifies a deficiency after approval and must revisit the application in accordance with Numbered Memo 2021-03.
- 7
N.C.G.S. § 163-230.1(e), (e1), (f), and (f1).
- 8
N.C.G.S. § 163-35(d).
- 9
08 NCAC 17 .0109(b); N.C.G.S. § 163-230.1(e1).
- 10
N.C.G.S. § 163-230.1(f); see also 08 NCAC 17 .0109(c) (“Final Review by County Board”).
- 11
08 NCAC 17 .0109(c)(2).
- 12
08 NCAC 17 .0109(c)(2). This rule also provides for the manner in which the notice is sent and how the voter may address the board.
- 13
N.C.G.S. § 163-234(12) (as revised by N.C. Session Law 2026-60 § 1.5). Note that for in-person voters whose photo ID exception form is being considered for falsity, the opportunity to address the board can be at the canvass meeting. See N.C.G.S. 163-182.2(a2) (as revised by N.C. Session Law 2026-60 § 1.2(c)) (“the county board shall determine whether to count the provisional official ballot by the date of the county canvass”).
- 14
08 NCAC 17 .0109(c)(1).
- 15
08 NCAC 17 .0109(c)(3).
- 16
N.C.G.S. § 163-275(15) (added by N.C. Session Law 2026-60 § 1.6, effective August 11, 2026, regarding the counting of absentee and early voting ballots before the close of the polls).
- 17
N.C.G.S. § 163-234(3).
- 18
See Numbered Memo 2021-03, which requires a spoil and reissue when there is no ballot or multiple ballots in the container-return envelope, when the voter has indicated on their ballot that they are requesting a replacement, or when the ballot is one the voter is not eligible to vote.
- 19
N.C.G.S. § 163-234(9).
- 20
N.C.G.S. § 163-234(5).
- 21
N.C.G.S. § 163-234(3): “Notwithstanding the provisions of subdivision (2) of this section, a county board of elections may, at each meeting at which it approves absentee ballot applications pursuant to G.S. 163-230.1(c) and (c1), remove those ballots from their envelopes and have them read by an optical scanning machine, without printing the totals on the scanner.” (Emphasis added).
- 22
N.C.G.S. § 163-234(2) (as revised by N.C. Session Law 2026-60 § 1.5).
- 23
N.C.G.S. § 163-234(2) (as revised by N.C. Session Law 2026-60 § 1.5).
- 24
N.C.G.S. § 163-234(12) (as revised by N.C. Session Law 2026-60 § 1.5).
- 25
N.C.G.S. § 163-234(11) (as revised by N.C. Session Law 2026-60 § 1.5).
- 26
See N.C.G.S. § 163-234(2) (“Any elector of the county shall be permitted to attend the meeting and allowed to observe the counting process, provided the elector shall not in any manner interfere with the election officials in the discharge of their duties.”).