FEMA HSGP election-security holdback: SAVE checks and 2026 midterm stakes

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FEMA’s FY 2026 Homeland Security Grant Program (HSGP) notice says it will withhold from drawdown a portion of grant funds—until states provide “proof of compliance” with election-security requirements tied to a federal citizenship-verification tool, SAVE. The NOFO also points to a June 22, 2026 court order in League of Women Voters v. U.S. Department of Homeland Security (Civ. Action No. 25-3501), and describes how states may handle uncertainty while the case is on appeal.

For election offices, the practical pressure point is workload and documentation: the grant conditions connect certain SAVE-linked steps to citizenship verification, and the funding drawdown is tied to whether FEMA verifies compliance.

What FEMA’s FY 2026 HSGP notice says states must do i

The NOFO describes election-security expectations for each state and high-risk urban area election jurisdiction. Two provisions are central to the citizenship-verification workflow.

• Voter-roll citizenship verification: Use the U.S. Citizenship and Immigration Services’ Systematic Alien Verification for Entitlements (SAVE) system to verify the citizenship of all individuals in the state voter registration database within 120 days of accepting the grant award. If SAVE’s functionality is impacted by the June 22, 2026 court order while the case is on appeal, the state may resolve uncertainty for voters lacking state citizenship records by submitting relevant information to USCIS for an immigration records search consistent with 8 U.S.C. § 1373.
• Election-worker citizenship verification: Use SAVE (or another authorized government system) to verify U.S. citizenship for any person working at a polling place in any capacity, or operating any election system in the jurisdiction—explicitly including temporary agency workers and vendors who work on or with election systems. The NOFO further says that to prevent sabotage, infiltration, or foreign interference, the state’s chief election official must ensure verified non-U.S. citizens are prohibited from operating election systems or working at polling places, consistent with applicable law.

How the 20% holdback is supposed to work i

The NOFO draws a clear line between two election-security mechanics:

• A 3% minimum allocation: Each state and high-risk urban area must dedicate at least 3% of its SHSP and UASI award to eligible election security investments.
• A separate 20% holdback: FEMA will withhold 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 NPA requirements—and FEMA/“the Department” verifies/confirms that proof.

Critically, meeting the 3% spending requirement does not automatically release the holdback. The NOFO says the holdback applies to funds beyond the 3% set-aside, and FEMA releases the withheld portion(s) only after confirmation.

Timing: application deadline and the 120-day clock i

The NOFO lists an application due date of July 24, 2026. But the citizenship-verification step is tied to a different milestone: the voter-roll verification requirement is due within 120 days of accepting the grant award.

Because acceptance dates can vary, that 120-day workload could overlap with preparation and operations around the 2026 election cycle, depending on when each state’s award clock begins.

Court limits appear directly in the grant language i

The NOFO explicitly incorporates the June 22, 2026 court order’s impact on SAVE functionality. It says that “to the extent” SAVE functionality is impacted while the case is on appeal, states may resolve citizenship-record uncertainty by submitting relevant information to USCIS for an immigration records search consistent with 8 U.S.C. § 1373.

That means the compliance picture is not static: court developments can affect what “proof of compliance” looks like in practice, and the NOFO itself anticipates uncertainty while litigation is ongoing.

What DHS leadership warned states about (and why election officials are watching) i

In reporting by the Associated Press, Homeland Security Secretary Markwayne Mullin said states that do not participate in the SAVE program could face fines, penalties, or prison time. The same AP report says a federal judge blocked the overhauled SAVE program over concerns about privacy and wrongful purges of eligible voters, and it quotes experts arguing that the threats were likely hollow given constitutional limits and prior court decisions.

Even if court challenges shape how SAVE-linked verification can be used, the NOFO’s funding condition is still a near-term administrative issue: states may need to show FEMA documentation of the steps they took (or the compliant alternatives they used) in order to unlock the held-back portion.

What readers should watch next i

• State implementation guidance: Whether chief election officials and state administrative agencies issue new instructions on how voter-roll and election-worker citizenship verification will be documented for grant compliance.
• FEMA’s “proof of compliance” requests and timelines: The NOFO ties the holdback release to FEMA/Department verification, so how FEMA asks for documentation could drive workload for election offices.
• Further SAVE-related litigation updates: Since the NOFO builds in a carve-out tied to the June 22, 2026 court order, new rulings could affect what states treat as workable “compliance” going into and after the 2026 midterms.

Sources

• FY 2026 Homeland Security Grant Program (HSGP) NOFO (FEMA) — election-security / compliance / holdback conditions (PDF attachment via Grants.gov)
• Grants.gov / Simple grants listing — FY 2026 HSGP opportunity page
• Associated Press — report on DHS leadership warning states about election-security compliance and funding stakes
• Democracy Docket — coverage explaining the FEMA/HSGP holdback and election-security conditions (July 7, 2026)

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