FEMA election-security grant terms: 20% drawdown holdback until proof

FEMA’s updated FY 2026 Homeland Security Grant Program (HSGP) notice of funding opportunity (NOFO) says states and certain high-risk urban areas will have 20% of their HSGP awards withheld from drawdown until they submit proof of compliance with specific election-security requirements—and until FEMA verifies/confirms that proof.

The NOFO (updated July 9, 2026) sets a July 24, 2026 application end date. It also ties several election-security steps to the period after an award is accepted, which can create cash-flow timing pressure for election offices as they assemble documentation.

The key mechanism: a verified “20% holdback” from drawdowns

In the NOFO’s election-security section, FEMA explains that meeting the grant’s election-security spending requirement (described separately as a 3% minimum allocation) does not automatically unlock the withheld money.

Instead, for each state and for each UASI, FEMA says it will withhold from drawdown an amount equal to 20% of the recipient’s total HSGP award (SHSP, UASI, and OPSG) until the recipient:

submits proof of compliance with the FY 2026 Election Security National Priority Area (NPA) requirements, and
the Department verifies/confirms that proof.

After verification/confirmation, FEMA will notify the recipient and release the withheld portion(s) for drawdown under applicable grant administration rules.

What states are expected to prove under the NOFO checklist

The NOFO spells out an Election Security NPA “must do” list that FEMA ties to drawdown access. The items include:

Voter roll citizenship verification using SAVE, including a requirement that individuals in the state voter registration database be verified within 120 days of accepting the grant award. The NOFO also notes a contingency tied to the June 22, 2026 order in League of Women Voters v. U.S. Department of Homeland Security while on appeal, and says a state may resolve citizenship uncertainty by submitting relevant information to USCIS for an immigration records search consistent with 8 U.S.C. § 1373.
Corrective action by the state’s chief election official to remove verified non-U.S. citizens from the voter registration database, “consistent with applicable law.”
Election worker citizenship verification (for people working at polling places or operating election systems), including temporary agency workers and vendors, using the SAVE system or another authorized government system. The NOFO also requires that verified non-U.S. citizens be prohibited from operating election systems or working at polling places consistent with applicable law.
Paper ballot transition planning, for jurisdictions using electronic voting systems that count votes using bar codes or QR codes: a transition plan with a timeline and, if necessary, a funding request to eliminate ballot marking devices and use hand-marked paper ballots.
Post-election manual audit, requiring proof of compliance with a post-election 5% manual audit conducted according to guidelines established by the Secretary.
Voter/ballot reconciliation, requiring reconciliation of voters who voted in each federal election to ballots cast using a methodology established by the Secretary.

Timeline pressure: the July 24 deadline is only the start

The NOFO sets July 24, 2026 as the end of the application period. But several operational requirements are tied to award acceptance rather than the application date—for example, the NOFO’s 120-day window for certain voter-registration database verification steps begins after a recipient accepts the grant award.

Because the 20% holdback is connected to FEMA’s verification/confirmation of the submitted proof, election offices and state administrative agencies may focus on not only compliance, but also how quickly proof can be assembled and checked.

What this is—and isn’t—compared with EAC “Election Security” grants

FEMA’s HSGP program is one stream of federal election-related funding. Separately, the U.S. Election Assistance Commission (EAC) administers HAVA Election Security grants.

EAC describes its Election Security funding as a formula grant program under the Help America Vote Act, with Congress appropriating a FY 2026 election-security amount through the FY 2026 Consolidated Appropriations Act and including a 20% match requirement (with stated exceptions). That structure should not be confused with FEMA’s HSGP drawdown holdback, which is tied (in the NOFO) to FEMA verification of Election Security NPA compliance proof.

What to watch next

Near term, recipients will likely focus on three questions: (1) meeting the July 24, 2026 application deadline, (2) completing NOFO-linked operational steps that start counting after award acceptance, and (3) preparing the documentation FEMA expects for the “proof” and verification/confirmation condition needed to release the withheld drawdown portion.

Reporting from the Associated Press also highlights that these election-related requirements are being contested and discussed as states weigh their responses—so further federal guidance or clarifications could emerge as the deadline approaches.

Sources

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