DHS/FEMA election-security grant conditions: SAVE checks & 20% holdback

DHS/FEMA’s FY 2026 Homeland Security Grant Program (HSGP) notice of funding opportunity adds election-administration conditions to grant funding—centered on proof-of-citizenship checks using the USCIS Systematic Alien Verification for Entitlements (SAVE) system, post-election manual audits of 5%, and steps tied to a transition toward hand-marked paper ballots. It also creates a financial pressure point: FEMA will withhold an amount equal to 20% of each recipient’s total HSGP award until FEMA verifies compliance proof.

The key change: election rules get enforced through grant conditions

Under the NOFO, the requirements apply to the states and high-risk urban areas that receive HSGP election-security-related funding. Practically, that means the “what to do” items turn on grant acceptance and the process for submitting and verifying proof—not on a new, nationwide change to election law on the spot.

What the NOFO requires states and high-risk urban areas to do

The election-security conditions described in the NOFO include:

• Transition plan toward hand-marked paper ballots: a plan for jurisdictions currently using systems that rely on bar codes or QR codes for vote counting to move toward equipment that accepts hand-marked paper ballots, with a timeline and, if needed, a funding request to eliminate ballot marking devices.
• Post-election manual audit: proof of compliance with a post-election 5% manual audit, following guidelines established by the Secretary.
• Voter/ballot reconciliation: reconciliation of the number of voters who voted in each federal election to the number of ballots cast, using a methodology established by the Secretary.
• Voter-roll and election-worker citizenship verification using SAVE: use the SAVE system to verify the citizenship of individuals in the state voter registration database within 120 days of accepting the grant award, and take timely corrective action consistent with applicable law. The NOFO also requires SAVE (or another authorized government system) to verify citizenship for people working at polling places or operating election systems, including temporary workers and vendors.

How FEMA’s 20% holdback works (and why it can affect budgets)

The NOFO separates a spending requirement from a payment release condition:

• A 3% spending requirement: states and high-risk urban areas must dedicate at least 3% of SHSP and UASI awards to eligible election security investments.
• A 20% drawdown holdback: FEMA will withhold an amount equal to 20% of the recipient’s total HSGP award (SHSP, UASI, and OPSG) from drawdown until the recipient submits proof of compliance with the FY 2026 election-security requirements and the Department verifies/confirms that proof. Meeting the 3% allocation alone does not release the 20% holdback.

What readers should watch next

Because these conditions are tied to acceptance and FEMA verification, the timeline readers will feel starts with whether (and when) states accept the grant and submit proof:

• Key dates in the NOFO: applications are due July 24, 2026, with projected funding selection/award dates no later than September 30, 2026.
• The 120-day SAVE clock: the NOFO’s SAVE requirement for the voter registration database runs within 120 days of accepting the grant award.
• Proof submission and holdback release: states and high-risk urban areas will need documentation of their transition plan, the 5% manual audit approach, reconciliation methodology, and how they conduct SAVE-based citizenship verification; the 20% holdback depends on FEMA’s verification/confirmation.

WESA’s reporting on Pennsylvania illustrates how this lands day-to-day: it describes the state still reviewing the new requirements and working through the application process, alongside a federal indication of a 20% holdback tied to election-security demands.

How this fits with other federal election-security funding

Separate from DHS/FEMA’s HSGP election-security conditions, the U.S. Election Assistance Commission (EAC) explains that HAVA Election Security grants are formula grants intended to help states improve the administration of elections for federal office. Together, the streams can influence what election jurisdictions prioritize—especially around technology purchases, poll-worker training, and the documentation needed for post-election checks.

Sources

• DHS/FEMA, FY 2026 Homeland Security Grant Program (HSGP) NOFO—Election Security conditions and FEMA 20% holdback (PDF)
• U.S. Election Assistance Commission (EAC), Election Security Grant program overview
• WESA (public-radio) reporting: state response to DHS/FEMA election-security grant requirements (example: Pennsylvania)