Labor & Employment Law Daily Wrap Up, DOL NEWS—Department ceases encouraging voter registration at American Job Centers, (May 5, 2025)

By Brandi O. Brown, J.D.

Stating that it is “committed to protecting and assisting the American worker,” the Department of Labor has rescinded guidance that encouraged states to enable American Job Centers to act as voter registration centers.

The Department of Labor’s Employment and Training Administration has announced that is rescinding TEGL No. 08-21, which requested that State Workforce Agencies and Local Workforce Development Boards work with election officials in their states to allow them to register individuals to vote. The brief and cryptic explanation for why it is seeking to diminish encouragement of voter registration in this way includes a reference to Executive Order 14248, a reference to “the prior Administration’s electioneering efforts,” and a statement that the Labor Department “is committed to protecting and assisting the American worker.”

What it said. Under TEGL No. 08-21, as issued in 2022, the DOL had requested that “State Workforce Agencies and Local Workforce Development Boards work with the election officials in their respective states to obtain information and materials necessary to effectively and legally register individuals to vote in the state, and also provide information in this Training and Employment Guidance Letter (TEGL) to appropriate programs and other staff in the state’s workforce system.”

Voting Rights Act compliance. TEGL No. 08-21 (2022) stated that, though states were not required to do this, doing so would help them comply with the National Voter Registration Act of 1993 (NVRA). “When designated as voter registration agencies,” that notice explained, “staff or volunteers within the AJC would work as voter registration staff and would distribute voter registration application forms, assist applicants in completing voter registration forms, and would accept completed voter registration forms for transmittal to the appropriate state election official.”

“While not required to provide these services,” the 2022 notice explained, “the public workforce system can play an important role in furthering the goals of the NVRA by facilitating non-partisan voter registration activities.” It added that DOL was “issuing this guidance so all states are aware that under existing NVRA provisions, states can designate AJCs as voter registration agencies, and that several workforce development programs additionally can assist participants with registering to vote.

No influence had been allowed. TEGL No. 08-21 also clearly stated: “Please note: voter registration activities must not influence an applicant's political preference or party registration, display any political preference or party allegiance, make any statement or take any action to discourage the applicant from registering to vote, nor make any statement or take any action to lead the applicant to believe that a decision to register or not to register has any bearing on the availability of services or benefits.”

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