Source + trust record
Source checked as of September 18, 2026. Primary authority: USDOL TEGL 08-21, Change 2.
Check result: TEGL 08-21, Change 2 remains active continuing guidance. ETA federal financial assistance may not fund or reimburse voter-registration activities conducted within the American Job Center network. The restriction concerns use of ETA funds and does not itself eliminate separate state or local legal duties that may arise under other law. This AI-assisted brief does not receive human legal or compliance review. Official sources control.
Where the federal funding boundary falls when voter-registration activity occurs in shared AJCC space
TEGL 08-21, Change 2 says ETA federal financial assistance may not fund or reimburse voter-registration activities conducted within the American Job Center network. In a shared AJCC, the compliance question is therefore not simply whether voter registration occurs in the building. It is whether ETA funds bear any part of that activity’s cost.
🚩 Statewide Action Alert. Voter-registration activity costs incurred after July 8, 2025 may not be allocated to ETA grants. DOL states that such costs identified through federal grant oversight will be disallowed.
At a glance
Agency
USDOL ETA
Guidance
TEGL 08-21, Change 2
Issued
July 8, 2025
Status
Continuing
Applies to
ETA-funded programs, absent another legal exception
Local review
Policies · procedures · MOUs · cost-sharing
Core control
Keep ETA funds off voter-registration costs
Executive takeaway
DOL directs states, Local Areas, workforce boards, and AJCC programs to review their policies, processes, MOUs, and cost-sharing agreements so ETA-funded grants do not absorb voter-registration activity costs. The restriction applies across ETA-funded programs unless another federal law, regulation, or later DOL guidance provides an exception.
The rule is about the use of ETA financial assistance. It does not say that every activity occurring in the same building becomes an ETA activity, and it does not change a participant’s right to vote. It also does not override legal authority that states or local areas may have under laws such as the National Voter Registration Act.
Five things to know
- Voter-registration activity costs are not allocable to ETA funding.
- The guidance applies broadly across ETA-funded programs unless another legal authority provides an exception.
- Local Areas are specifically directed to review MOUs and cost-sharing agreements, not only program policies.
- In shared or co-located space, the guidance applies only to the ETA-funded portion of cost-sharing arrangements.
- Youth leadership and civic-engagement elements are not eliminated, but ETA grants may not pay for voter-registration activities themselves.
The practical boundary in a shared AJCC
| Situation | ETA funding treatment |
|---|---|
| WIOA-funded staff time conducting voter registration | Do not charge the staff cost to the ETA award. |
| Voter-registration materials purchased with WIOA or other ETA grant funds | Unallowable to the ETA award. |
| A partner uses separately funded staff/resources in shared AJCC space | The TEGL applies to the ETA-funded share; review cost allocation so ETA funds do not subsidize the voter-registration activity. |
| Shared facility overhead | Review the allocation methodology if space or shared staff support voter-registration activity; keep the related cost off ETA funding. |
| Youth discussion of voting as civic engagement | The youth leadership element is not rescinded, but ETA funding cannot be allocated to the act of conducting voter registration. |
| State/local legal duties under other law | TEGL 08-21, Change 2 does not remove authority granted by laws such as the National Voter Registration Act; use non-ETA funding as required by the applicable legal framework. |
Why MOUs and IFAs matter
AJCCs are intentionally shared environments. Staff, reception, common space, equipment, supplies, and other costs may be funded by several partners. TEGL 08-21, Change 2 therefore directs grantees to look at cost-sharing agreements, not just direct program expenditures. A compliant system should be able to show that ETA awards are not paying a share of voter-registration activity merely because the activity occurs inside a shared facility.
Youth programs: keep civic learning separate from registration costs
The TEGL names several youth-serving ETA programs and recognizes that leadership development can include discussion of voting and civic engagement. It does not remove those program elements and does not change anyone’s right to vote. The financial restriction is narrower: ETA grant costs cannot be allocated to conducting voter-registration activities.
Useful compliance question: “If this activity disappeared, would the ETA award still incur this cost?” If the answer is no, that is a strong signal that the cost is connected to the voter-registration activity and should not be allocated to the ETA grant.
WDB implementation considerations
- Review local fiscal, program, and AJCC procedures for any voter-registration activities charged directly or indirectly to ETA awards.
- Review MOUs, IFAs, facility-cost allocation, shared staff, and co-located partner arrangements where the issue could arise.
- Make sure WIOA Youth, YouthBuild, NFJP, and other ETA-funded youth providers understand the distinction between civic/leadership content and voter-registration costs.
- Document how non-ETA resources are separated when a partner conducts voter registration in a shared facility.
- Correct any post-July 8, 2025 ETA charges associated with voter-registration activity and consult fiscal/compliance staff as needed.
- Do not interpret the funding restriction as changing other legal responsibilities or participant voting rights.
Implementation traps
- Looking only for direct supply purchases while ignoring staff time, shared space, or overhead allocation.
- Assuming a partner-funded activity is automatically an ETA cost because it occurs inside an AJCC.
- Removing broader youth leadership or civic-learning content that the TEGL does not prohibit.
- Ignoring state or local obligations under other law because ETA funds cannot pay the cost.
Source basis and interpretation
Primary source: USDOL TEGL 08-21, Change 2 — Stopping the Use of Federal Funds in Conducting Voter Registration within the American Job Center Network
Effective cost rule: the TEGL states that voter-registration activity costs incurred after issuance and found during federal oversight will result in disallowed costs to ETA awards.
How to use this brief: This brief explains the ETA grant-cost restriction. It does not provide legal advice on voting law, the National Voter Registration Act, or state/local legal obligations. The official TEGL and applicable law control.