On Aug. 25, a federal judge temporarily blocked an Ohio law that requires individuals registering to vote at the Bureau of Motor Vehicles to provide documentary proof of citizenship.

Ohio is one of 12 states with laws requiring documentary proof of citizenship for voter registration, though it is the only one where the requirement applies only to voters registering to vote at a motor vehicle agency. Ohio allows individuals to register to vote at the BMV when applying for or renewing a driver’s license or state identification card. Documents accepted as proof of citizenship include a birth certificate, passport, certificate of naturalization, or driver’s license or state ID card issued after April 2023.

Governor Mike DeWine (R) signed HB 54, which enacted the requirement, in 2025. Individuals registering to vote online or via a paper form are not required to provide documentary proof of citizenship.

Two groups, Red Wine & Blue and the Ohio Alliance for Retired Americans, filed a lawsuit in August 2025 alleging that the proof of citizenship requirement violated the National Voter Registration Act (NVRA), which requires states to offer individuals the opportunity to register to vote at the department of motor vehicles.

In his order, U.S. District Court Judge Solomon Oliver Jr. wrote that the proof of citizenship requirement and Ohio’s procedures for registering to vote at the BMV likely violate the NVRA. 

Oliver wrote that the policy conflicts with an NVRA requirement that states may require only the minimum amount of information necessary to determine a person’s eligibility to vote, since the state accepts a sworn statement that the registrant is a citizen for other methods of voter registration.

"Not only does Ohio's motor voter system run afoul of the NVRA in practice, it also conflicts with the Act by statutorily requiring applicants to produce documentary proof of citizenship before registering to vote simultaneously with their driver’s license application," Oliver wrote. "The record shows, and Defendants acknowledge, that signed attestation to U.S. citizenship is 'the minimum amount of information necessary,' … to enable Ohio’s election officials to assess voter eligibility and administer other parts of the election process."

In a statement, Ohio Secretary of State Frank LaRose (R) said, "Under this order, the Bureau of Motor Vehicles would be required to offer a voter registration form to a person who’s applying for a driver’s license, even if that person can't verify that they're a citizen. We strongly disagree with that decision, and I’ve asked our legal team to file an immediate appeal. I will vigorously defend our legal authority to safeguard our voter rolls and protect the integrity of Ohio’s elections."

Ohio was one of two states to enact documentary proof of citizenship requirements in 2025, alongside Wyoming. Four other states — Florida, Mississippi, South Dakota, and Utah — enacted documentary proof of citizenship requirements in 2026.

For more information on proof of citizenship requirements nationally, click here.