The U.S. Department of Homeland Security (DHS) has introduced new, stringent requirements for states and local jurisdictions seeking federal election security funding. Under the updated guidelines for the Homeland Security Grant Program, recipients must now implement specific measures—including the transition to hand-marked paper ballots, mandatory post-election audits, and new citizenship verification protocols—to receive their full grant allocations. According to the department, the Federal Emergency Management Agency (FEMA) will withhold 20% of each award until these compliance standards are verified by federal officials.
This policy change affects the distribution of more than $1 billion in federal grants currently available to state, Tribal Nation, and territorial governments. While the grant program remains voluntary, jurisdictions that choose to accept these federal funds must now adhere to a framework designed to mitigate risks ranging from cyberattacks and foreign interference to internal administrative discrepancies. The initiative represents an effort by the federal government to link financial assistance directly to the adoption of standardized, verifiable election security infrastructure.
Transitioning to Verifiable Paper Records
A primary component of the new funding condition is the move away from electronic voting systems that rely on barcodes or QR codes for ballot tabulation. The DHS mandate requires participating states to submit a transition plan for replacing equipment that does not provide a voter-verifiable paper record. By prioritizing hand-marked paper ballots, the department aims to ensure that election administrators possess a physical record that can be independently audited against machine-generated totals, according to the official grant notice.
The policy does not mandate an immediate, total replacement of all existing voting machinery. Instead, jurisdictions must provide a documented path toward upgrading systems that currently use barcode-based counting methods. This shift is intended to create a layer of redundancy, allowing officials to investigate potential equipment errors or irregularities before election results are officially certified. To support this, participating states are now required to conduct a manual audit of at least 5% of all ballots cast following every federal election. This audit process involves a physical review of a random sample of ballots, which must then be reconciled with the results reported by the electronic equipment.
Citizenship Verification and Litigation Challenges
The DHS has also tied grant eligibility to the verification of voter citizenship. Within 120 days of accepting an award, states must utilize the U.S. Citizenship and Immigration Services (USCIS) Systematic Alien Verification for Entitlements (SAVE) system to cross-reference voter registration databases with federal citizenship records. This requirement extends to election personnel, with states expected to verify the eligibility of workers at polling locations and those tasked with operating election systems, as outlined by the Department of Homeland Security.
However, the implementation of this mandate faces significant legal hurdles. A federal court order issued on June 22, 2026, in the case of League of Women Voters v. U.S. Department of Homeland Security placed restrictions on the expanded use of the SAVE system while the federal government pursues an appeal. Because of these ongoing legal proceedings, the availability and functionality of the verification system may vary by jurisdiction. In instances where SAVE is restricted, the DHS has indicated that states may submit relevant information to USCIS for an immigration records search under 8 U.S.C. § 1373. The intersection of these grant conditions with active litigation creates a complex environment for election officials, who must navigate conflicting federal court directives regarding access to citizenship data.
Accountability and Federal Funding Framework
The Department of Homeland Security maintains that these conditions serve as an accountability mechanism for taxpayer-funded infrastructure. By withholding 20% of the total grant award, FEMA ensures that states provide concrete evidence of compliance—such as documentation of audit procedures and voter reconciliation efforts—before the final portion of funding is released. This structure is intended to connect federal spending with measurable security outcomes, according to departmental statements.
DHS Secretary Markwayne Mullin emphasized the national security implications of the new policy, stating, “Election security is national security and protecting the Nation’s critical infrastructure is a top priority.” He noted that the actions are intended to protect systems from foreign interference and insider threats, ensuring that the results of federal elections remain trustworthy. For states and local governments, the decision to participate involves a trade-off: accepting federal resources now requires adherence to a specific set of federal procedural standards that may necessitate significant administrative and technical adjustments.
As the implementation period begins, jurisdictions will need to monitor further guidance from FEMA and updates regarding the legal status of the SAVE system. Further details regarding compliance deadlines and reporting formats are expected to be communicated through official FEMA channels as the grant cycle progresses. Readers are encouraged to monitor the official federal registers for updates on these requirements and to follow the progress of current federal litigation affecting election administration policies.
Worth a look