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Letter to the Standing Committee on Procedure and House Affairs following the CEO's March 29, 2022 appearanceCEO appearance on the Main Estimates 2022-2023 before the Standing Committee on Procedure and House Affairs

Le directeur général des élections The Chief Electoral Officer

Our file: 2022-103835

April 11, 2022

The Honourable Bardish Chagger, P.C., M.P.
Chair, Standing Committee on Procedure and House Affairs
Sixth Floor, 131 Queen Street
House of Commons
Ottawa, Ontario
K1A 0A6

Dear Bardish Chagger:

I am writing to share information that I committed to provide in my appearance before the Standing Committee on Procedure and House Affairs on March 29, 2022, during the Committee's study of Inclusion of Indigenous Languages on Federal Election Ballots.

The information included in the annexes to this letter identifies the provisions of the Canada Elections Act that would need amendment in order to have Indigenous languages added to the federal ballot (Annex 1), as well as the time and steps required for the production of ballots for a federal election (Annex 2).

I trust that this information will be of assistance to the Committee and invite you to contact me if you have any further questions.


Stéphane Perrault

Chief Electoral Officer


c.c.: Justin Vaive

Clerk of the Committee

Annex 1: Canada Elections Act (CEA) Provisions Requiring Amendments to Include Indigenous Languages on Ballots

Candidate Nomination Process

  • The prospective candidate must complete a nomination paper where they register the name that they wish to have appear on the ballot (subparagraph 66(1)(a)(i) of the CEA). The prospective candidate may request that a name by which they are commonly known be registered to appear on the ballot (subparagraph 66(1)(a)(i.1) of the CEA).
  • Under section 66(2) of the CEA, the name of the candidate shall not include any title, degree or other prefix or suffix.
  • Under section 67(2) of the CEA, a prospective candidate shall prove their identity with one piece of identification issued by a government or two pieces of identification authorized by the Chief Electoral Officer.

Ballot and Special Ballot Format

  1. Ballot
    • Form 3 of Schedule 1 of the CEA provides the ballot form. It includes an image of the ballot used by EC.
    • Pursuant to Form 3 of Schedule 1 of the CEA, ballots are in English and French. Only Latin alphabet characters appear on the Form 3 ballot.
    • Pursuant to Form 3 of Schedule 1 of the CEA, the CEA provides that EC has the obligation to provide ballots in both official languages. However, even if the names of candidates and political parties must be written using Latin characters, they do not necessarily have to be in English or French.
    • Section 117(1) of the CEA provides that ballots shall contain the names of candidates arranged alphabetically. The mention of alphabetical order in section 117(1) refers to the Latin alphabet, as ballots are, for now, published in English and French.
  2. Special Ballot
    • Under section 186 of the CEA, special ballots shall be in accordance with Form 4 of Schedule 1, which includes an image of the ballot used by EC.
    • Form 4 of Schedule 1 of the CEA provides the exact form of special ballots, which are in English and French. On these ballots, electors are asked to write the given name and surname of the candidate of their choice.
    • Under sections 213(2), 227 and 258 of the CEA, electors shall write the given name and surname of the candidate of their choice. The CEA does not include any provisions regarding the language in which electors can write the name of the candidate of their choice. Pursuant to Form 4 of Schedule 1, it is presumed that electors will use the Latin alphabet and one of the two official languages, as the ballot is available in English and French only.
    • Sections 269(2) and 279(2) of the CEA provide that no special ballot shall be rejected for the sole reason that the elector has incorrectly written the name of the candidate of their choice if the ballot clearly indicates the elector's intent.
    • Paragraphs 269(1)(e) and 279(1)(e) of the CEA provide that a ballot shall be rejected if there is any writing or mark on it by which the elector could be identified.
  3. Requirements for Printing Ballots

    • Section 116(1) of the CEA provides that ballots shall be printed according to Form 3 of Schedule 1 as soon as possible after 2:00 p.m. on the 19th day before polling day.
    • Sections 116(2) and 116(3) of the CEA provide that ballots shall have a counterfoil and a stub, with a line of perforations between the ballot and the counterfoil and between the counterfoil and the stub. In addition, ballots shall be numbered on the back of the stub and the counterfoil.


    • Paragraphs 385(2)(a) and 385(2)(b) of the CEA provide that the leader of a political party may apply to register the party. To that end, they shall provide the political party's full name and the party's short-form name (or its abbreviation). According to section 117(2), ballots include the political party's short-form name as referred to in paragraph 385(2)(b).

    Under the approach adopted by Parliament regarding the inclusion of Indigenous languages on ballots, other legislative amendments related to the production of ballots will inevitably be required in order to meet certain established deadlines and fulfill other CEA requirements, or to allow a successful implementation. As an example, the provisions related to the closing day for nominations, the length of the election period and the list of candidates must be modified to ensure a successful implementation of the selected approach. Annex 2 provides additional details on these timelines and on the production of ballots.

    Annex 2: Ballot Production Timeline

    Under the Canada Elections Act, ballots must be printed and distributed in the narrow window that exists between the close of candidate nominations, 21 days before election day, and the first day of advance polls, 10 days before election day. In large and remote ridings, getting the ballots printed and distributed across the riding in time for advance polls is already a significant challenge.

    Below is an overview of the current ballot production process.

    Days 34/33-21 1: Nomination period

    Candidate nominations are open, and candidates may submit their nomination forms, including their name as it should be printed on the ballot. Nominations close on Day 21 at 2:00pm, with a deadline for withdrawals of 5:00pm local time. The ballot production process cannot start before this occurs as the list of candidates is not yet finalized.

    Days 30-29: Ballot paper shipped to printing companies

    Elections Canada liaises with printing companies to confirm logistical details. Any printers no longer available are replaced. Printing companies are spread throughout Canada to reduce shipping delays. Elections Canada then ships the ballot paper to the printing companies and confirms receipt by Day 24.

    Days 21-18: Preparation of Ballot images

    • Day 21 (2:00 pm): End of nomination process
    • Day 19: (2:00 pm): End of the nomination approval process by Returning Officer (RO)
    • Day 21-18: Preparation and verification of ballot images

    Elections Canada headquarters (ECHQ) staff perform the following steps in preparing ballot images:

    1. Review information in any last-minute candidate nominations and ensure that names and other information are captured correctly into nomination system;
    2. Generate a list of candidates Verification Report for each electoral district (ED) listing the candidate and party names;
    3. Generate ballot PDF images for each ED;
    4. Send the Verification Reports to the ROs, who must confirm the information is correct and perform quality control of ballot PDF images
    5. After the RO has confirmed the information on the Verification Report and the ballot PDF for that ED has also passed a quality control inspection, ballot PDF images are emailed to the printing company.

    There are approximately 20 EDs, covering the northern half of Canada, where the timely distribution of ballot booklets to remote polling stations is a challenge. These EDs are treated as a priority and steps (a) to (e) are completed by the evening of Day 21 (presuming RO verification of all nominations is done by that time). The remaining EDs are processed in batches and completed no later than 7:00am on Day 18.

    If the RO identifies an issue with the information on the Verification Report or the ECHQ quality control inspection turns up a problem, the data for that ED must be corrected and the process restarted, with a new Verification Report and ballot PDF image.

    Days 18: Ballot proof preparation

    The printing company prepares a ballot proof for the RO to inspect and approve, prior to the start of printing. The RO inspects the proof using a checklist and authorizes the start of printing. If the RO discovers a problem, this step must be repeated.

    Days 18-13: Production of the ballot booklets

    The printing company prepares the ballot booklets for the advance polls. This includes these high-level steps:

    1. Make the necessary adjustments to paper sheets provided by EC for printing needs;
    2. Print images and individual serial numbers on ballots;
    3. Perforate each ballot and separate ballot from counterfoil and then counterfoil from stub;
    4. Assemble sheets into groups of 50 such that the serial numbers are in order;
    5. Cut sheets into individual ballots, add covers, and bind ballot booklets.

    Printing companies have indicated that the perforating, cutting, and often serial numbers steps use separate specialized machinery operated manually with a slower production rate than printing. Many printing companies do not have this equipment, which limits options for ballot production.

    Days 14-13: Delivery of first booklets to ROs

    The printing company delivers the ballot booklets for the advance polls to the RO.

    Days 13-11: Quality control of booklets and preparation for advance polls

    The RO and their office staff perform the following tasks:

    1. Count the ballot booklets to ensure the correct quantity has been provided;
    2. Perform quality control of the ballots;
    3. Deliver some of the ballot booklets to the Additional Assistant Returning Officer (AARO) office, if applicable;
    4. Prepare and distribute the appropriate number of ballot booklets to the Deputy Returning Officer (DRO) and/or Central Poll Supervisor (CPS) of each advance poll in the ED, tracking every single booklet and who it is given to on the Record of Ballots and Ballot Control Sheet).

    Days 11-7: Advance polls

    During this period, quality control, such as making sure number of booklets received and serial numbers match the Record of Ballots, is done by election offices (EOs) and then ballots are issued at the polls. Once issued, DROs perform quality control as they use each booklet.

    If the CPS contingency supply is not used during advance polls, these are returned to the office on Day 7/6 for use at ordinary polls. Each book is "checked back in" to the RO office.

    Days 13-6: Preparation and delivery of election day booklets to RO

    After the printing company has completed printing the ballots for the advance polls, they continue to print ballots for the ordinary polls, repeating the steps performed on Days 18-13 above, and deliver the ballot booklets for the ordinary polls to the RO.

    Days 6-1: Quality control of booklets and preparation for ordinary polls

    The RO and their office staff repeat the tasks performed on Days 13-11, for the ordinary polls.

    Day 0: Ordinary polling day

    The CPS and DRO collect ballots, perform quality control, issue ballots as needed and track their usage.


1 These days indicate the number of days before election day, with election day being "Day 0".