The federal government should not use grant rules to scare nonprofits out of helping people participate in democracy.
Yet that is the danger in the Office of Management and Budget’s (OMB) proposed revisions to the Uniform Guidance. Buried inside a broader rulemaking, alongside many other troubling provisions attacking DEI and “woke” practices opposed by the Administration, is a provision that would make “voter registration campaigns, drives, or related activities” unallowable costs under federal awards. The proposal would also expand restrictions on the use of federal funds for “issue advocacy” and certain public messaging, using language that creates confusion in an already complex compliance environment.
This may sound like a technical grants-management issue. It is not. It is a civic infrastructure issue.
Nonprofits are among the few institutions that still maintain durable trust in communities too often ignored by campaigns, policymakers, and public agencies. They are food banks, health centers, youth programs, and community-based organizations that help people navigate public systems every day. They also help people understand that democracy is not something that happens somewhere else; it is how we share in our community’s decision-making.
When federal rules make those organizations more afraid to speak, educate, or engage, it impacts communities that already face the greatest barriers to power.
The chilling effect is the point of concern
To be precise, the proposal would not ban every nonprofit that receives federal funding from conducting lawful, nonpartisan voter registration. The proposed restrictions only apply to the use of federal grant funds, not funds raised from other sources. That distinction matters legally.
But in practice, legal distinctions do not always prevent damage.
When rules are nuanced or confusing, organizations do not usually respond by confidently threading the needle. They pull back, pausing programs to avoid risk. They wait for legal review. They stop doing work that is lawful, needed, and central to the communities they serve.
That chilling effect is not hypothetical. It is the predictable result of federal policy that requires legal hair-splitting to navigate.
Nonprofits that receive federal grants already operate under strict rules. They separate funding sources, allocate staff time, and comply with reporting requirements. Compliance is not occasional; it is part of the daily operating reality of federally funded nonprofits.
What this proposal would add is not meaningful accountability. It would add fear.
And fear is an effective silencer.
The burden will fall hardest on community-based organizations
The proposal also risks colliding with existing federal law.
The National Voter Registration Act requires certain agencies that administer public assistance programs like TANF, SNAP, WIC, or Medicaid, as well as state-funded services to people with disabilities, to offer voter registration opportunities. This requirement also applies to nonprofits carrying out this same work under government contracts or grants.
That creates an obvious problem. If one federal law requires voter registration services be provided, while a new OMB rule discourages or restricts funding connected to that work, nonprofits could be trapped between compliance obligations. OMB should not create a compliance maze for organizations that are already doing the work Congress directed them to do.
This could conflict with existing voter registration obligations
The voter registration portion of the proposed OMB rule raises questions about consistency with existing federal law.
The National Voter Registration Act (NVRA) of 1993 requires organizations administering certain federal programs to provide voter registration assistance. In addition to requiring voter registration at state motor vehicle offices, the NVRA also requires programs such as TANF, WIC, Medicare, and SCHIP to offer voter registration opportunities. And when a nonprofit receives a grant or contract to administer such programs, they are also obligated to help eligible individuals register to vote. Higher ed institutions providing state-funded support for people with disabilities are also covered under the NVRA.
The proposed rule directly conflicts and creates confusion about these obligations.
Timing matters
The timing makes the danger worse.
According to the memo, the final rule could be announced on September 1, 2026 and take effect on October 1, just weeks before Election Day when voter registration drives are underway across the country. In doing so, the proposal risks injecting confusion into the busiest and most consequential period for voter registration work.
For large institutions, that confusion may lead to delays while legal counsel reviews the rule. For small community nonprofits, it may simply mean shutting down voter registration activity altogether. By the time anyone clarifies what is still allowed, registration deadlines in many states may have passed. The harm would already be done.
What nonprofits should do
The public comment deadline is July 13, 2026. Nonprofits should use that opportunity to speak plainly about how this proposal would affect their work. The rule matters for any nonprofit that receives federal funding and also engages in advocacy, voter education, voter registration, public education, community organizing, or policy communication. But that’s not all.
It’s not just the proposed rule limiting the nonprofit civic voice, there are a host of other provisions of deep concern to the sector from requiring federal grants align with the Present’s priorities, putting political appointees in key decision-making places, banning so-called “illegal” DEI, and more.
Now is the time to speak up, submit comments, and be heard.
Take Action Today
→ In just five minutes, you can submit a public comment urging OMB to reconsider provisions that could discourage lawful, nonpartisan voter registration and civic engagement by nonprofits.
Step 1: Click the link below to submit a comment.
Step 2: Use the sample comment below, or customize it with your own experience.
I am concerned that the proposed changes in Section 200.450 will create confusion and discourage nonprofits and higher ed from engaging in lawful, nonpartisan voter registration and civic engagement activities. Existing grant rules already provide sufficient accountability and oversight. Additional restrictions create unnecessary administrative burdens and could lead organizations to scale back important services that help people participate in our democracy. Any final rule should be consistent with existing federal laws, including the National Voter Registration Act which requires some nonprofits administering certain federal programs to offer voter registration, and should not create a chilling effect on lawful nonprofit activities.
→ Prefer to write your own comment? Consider including these points:
- Existing grant requirements already provide sufficient accountability for use of federal funds.
- Additional restrictions could create confusion, unnecessary red tape, and administrative burdens.
- The proposal will have a chilling effect, causing organizations to reduce lawful voter engagement activities and issue advocacy, even when using non-federal funds.
- Any final policy should be consistent with existing federal laws, including the National Voter Registration Act (NVRA) which requires nonprofits and higher ed administering certain federal and state programs to offer voter registration.
Taken action? Now help spread the word. Our voices have power en masse. Send this to (3) friends, coworkers, or allies and ask them to submit a public comment before July 13, 2026 today.
