The IRS-letter rule and state documents
A mosque applies through its State Administrative Agency (SAA), the state office that administers the program. The FY2026 notice of funding opportunity (NOFO) names mosques in its eligibility section (FY2026 NOFO, p. 6):
"The Internal Revenue Service (IRS) does not require certain organizations such as churches, mosques, and synagogues to apply for and receive a recognition of exemption under section 501(c)(3) of the IRC. Such organizations are automatically exempt if they meet the requirements of section 501(c)(3). These organizations are not required to provide recognition of exemption."
State documents repeat the note, including New York's FY2026 FAQ and Maine's FY2026 subapplicant notice. The other eligibility rules are in the NSGP program guide.
The exemption follows the IRS's church rules. IRS Publication 1828 uses "church" to include mosques and says other religious organizations "generally must apply to the IRS for tax-exempt status" unless their gross receipts normally stay at or below $5,000 a year. A separately incorporated school, foundation, or community organization should confirm its own exemption record and ask the SAA what it accepts. For organizations the IRS requires to apply, the NOFO says "the state may not require recognition of exemption, if the method chosen is applied consistently." New York's FAQ says a 501(c)(5) organization doesn't qualify, so a center organized outside 501(c)(3) should ask first.
States can still ask for other documents. New York, for example, required FY2026 applicants to prequalify in its Statewide Financial System and to be registered with the Attorney General's Charities Bureau, have recently applied for registration, or be exempt from registering. It also required a Unique Entity ID (UEI) before issuing a subaward, and the NOFO says FEMA may request subrecipients' Employer Identification Number (EIN) and bank information (p. 8). Get your SAA's checklist early; the application steps cover the sequence.
Converted, leased, and trust-held buildings
Many mosques occupy buildings first built for another use. In its US Mosque Survey 2020, the Institute for Social Policy and Understanding (ISPU) found that 37% of mosques had been built as mosques (ISPU infographic). NSGP doesn't require ownership. Equipment may go on property "owned or leased by the nonprofit organization" (NOFO, p. 58), and FEMA's FY2025 FAQ says "any work funded by the NSGP must be permissible by the owner." The FY2026 Investment Justification (IJ) form on Grants.gov asks whether you own or lease and, for a lease, whether you have "the owner's permission to make the proposed security enhancements."
The NOFO sets no minimum lease term, and we found no SAA rule on the form of a landlord's approval, so ask the SAA what it wants. A converted building's age and past alterations also go on FEMA's environmental and historic preservation (EHP) screening form; see the EHP review guide.
Some congregations use a building that a trust owns. The North American Islamic Trust (NAIT) says it "holds titles to the real estate assets of Islamic centers and schools in more than forty States" (NAIT). None of the FEMA or state guidance we reviewed explains how an SAA treats that arrangement, and the IJ form allows only one nonprofit to apply per building or address (the church guide has a shared-building table). Ask the SAA in writing:
- Which entity should apply, and how should it answer the IJ's own-or-lease question?
- What document from the titleholder will the SAA accept as the owner's approval?
- Does the SAA count the trust as a second nonprofit at the address under the one-applicant rule?
Settle who signs, too. ISPU found that 76% of mosques "are managed entirely by volunteers," and that larger mosques (Friday prayer attendance over 500) more commonly have both a board of trustees and an executive committee. Record in the minutes which body approves the application, accepts the subaward, and signs contracts.
A congregation building or buying a new mosque applies for the site it occupies now. IJ projects must be for an address "that the nonprofit occupies at the time of application" (NOFO, p. 27), and New York's FAQ rules out a building under construction and land without a building. The NOFO doesn't say whether a hall rented for occasional large gatherings counts as a site the nonprofit occupies, so ask the SAA before planning around one.
Weekend and full-time Islamic schools
A school on the campus changes who applies only when it is a separate legal entity. The applying nonprofit self-identifies its organization type in the IJ, and the SAA validates that choice against its mission statement (NOFO, p. 27). A weekend school run by the mosque leaves the mosque's category unchanged: the mosque applies in the Ideology-based/Spiritual/Religious category, with the ×3 multiplier (p. 31), and its assessment and IJ should cover the school's hours and users.
A full-time Islamic school incorporated as its own nonprofit has its own mission, organization type, and funding history. If it shares the mosque's building or address, only one of the two may apply for that site. The private and religious school guide lays out each campus arrangement and the state programs for nonpublic schools.
Guard hours for Friday prayer and Eid
The FY2026 NOFO lets a subrecipient spend up to 100% of its award on contracted security personnel who comply with Information Bulletin 441, including off-duty police working as contract security (pp. 17, 67). Base the request on the organization's own documented calendar and vulnerability assessment: which periods need coverage, how many guards, for how many hours, at what rate. The safety guide from the Council on American-Islamic Relations (CAIR) and NAIT names Jumaah (Friday congregational prayer) and Eid services among the "high traffic times" for ushers and greeters, and it advises integrating security "in the routine way you plan for prayers, holidays, and Ramadan."
Treat the coverage schedule as a security document. Subrecipients "cannot claim pre-award costs" (NOFO, p. 19), so guard hours worked before the award can't be reimbursed; the NOFO tells subrecipients to contact the SAA if exigent circumstances exist. The synagogue guide shows how that timing affects a holiday season, and the security guard guide covers the IJ detail, competitive procurement, licensing, and claim records.
Documenting the threat
The NOFO's review criteria look for threats or attacks "by a terrorist or other extremist organization, network, or cell against the subapplicant based on their ideology, beliefs, and/or mission" (NOFO, p. 30). Appendix D says an applicant may draw on incidents at "closely related/similar organizations either domestically or internationally" and should show "they are at risk for the same reasons" (pp. 71–72). Its top threat score goes to "multiple, detailed, and specific threats or attacks" against the organization or a closely related one, so start with the site's own incident log, police reports, and threats received (see the Investment Justification guide).
Keep those records as incidents happen. The Muslim Public Affairs Council (MPAC) advises mosques to report every incident to local police, even minor vandalism or online trolling, and Florida's FY2024 NSGP guide asked applicants to include, if applicable, documents that support threats to the facility, such as police and insurance reports.
National hate-crime data gives context; it doesn't prove that a particular site is at risk. The FBI's Crime Data Explorer (CDE) is a public source for that context:
| Year | Incidents | Location entries coded "Church/Synagogue/Temple/Mosque" |
|---|---|---|
| 2021 | 154 | 18 |
| 2022 | 157 | 20 |
| 2023 | 252 | 26 |
| 2024 | 232 | 20 |
| 2025 | 210 | 28 |
The CDE covers only agencies that submit data, the bias finding is the reporting agency's, and counts change as agencies update their reports. The incident column counts single-bias incidents. The same CDE query also returns multiple-bias incidents that include an anti-Islamic bias (10 in 2021, 19 in 2022, 32 in 2023, 29 in 2024, and 23 in 2025), and the location column covers both kinds. The CDE records one location for each bias category reported, and the location code covers all houses of worship, so the last column counts entries, not mosques. A secondary source differs: the Arab American Institute, writing about the FBI's August 14, 2026 release, reported 205 anti-Muslim incidents for 2025 and 261 for 2024 (AAI, August 19, 2026). AAI's 2021, 2022, and 2024 figures equal the CDE's single-bias count plus those multiple-bias incidents, and its table reflects the CDE as of August 17, 2026; AAI said the 2025 counts would likely rise. Cite the CDE category, "Anti-Islamic (Muslim)," with the years and refresh date.
Safety resources for mosques
CAIR and NAIT posted Best Practices for Mosque and Community Safety, an update of CAIR's 2012 guide, on September 8, 2026. Its 52 pages include a planning framework, emergency scenarios, incident documentation, a five-minute walkthrough assessment, and a checklist, and its page notes that "Specific security recommendations can only be made by a security professional after an on-site inspection and risk assessment of your facility." The two organizations began regional safety seminars in August 2026 (SecurityToday, August 11, 2026). MPAC's Center for Security, Technology, and Policy publishes a security bulletin with steps such as greeting every visitor and keeping cameras working.
The Cybersecurity and Infrastructure Security Agency (CISA) calls its Houses of Worship Security Self-Assessment "a first step" that is "not intended to be an in-depth security assessment." CISA's December 2023 performance goals for faith-based communities say its Protective Security Advisors support faith-based communities "with vulnerability assessments, site visits, and training at no cost"; ask your CISA region whether that help is available now. NSGP funds can't pay for the application's assessment (NOFO, p. 17); the vulnerability assessment guide covers what the SAA expects.
State programs tied to hate-crime risk
None of the state programs we checked on October 14, 2026 names a faith. New York, California, and Maryland tie eligibility to hate-crime risk, and Pennsylvania ties it to serving people in an FBI hate-crime bias category. Where a program asks about risk, lead with the organization's own records and cite the FBI series as national context.
| State | Program | Eligibility wording | State guide |
|---|---|---|---|
| New York | Securing Communities Against Hate Crimes | Religious organizations, houses of worship, and other nonprofits "at risk of hate crimes or attack because of their ideology, beliefs or mission" | New York security grants |
| Pennsylvania | Nonprofit Security Grant Fund | The applicant "must principally serve individuals, groups, or institutions that are included within a bias motivation category"; religion is one of six categories | Pennsylvania security grants |
| California | State Nonprofit Security Grant Program | Nonprofits "at high risk for violent attacks and hate crimes due to ideology, beliefs, or mission" | California security grants |
| Maryland | Protecting Against Hate Crimes | Nonprofits, "including faith-based organizations," whose facilities and membership "can be targeted for a hate crime" | Maryland security grants |
Rounds, award limits, match rules, and deadlines differ by state and change with each budget. Check the state guide, or security grants by state for every state's agency, before you plan around a round.
Sources
- FEMA, FY2026 Nonprofit Security Grant Program NOFO
- Grants.gov, FY2026 NSGP posting and Investment Justification form FF-207-FY-21-115
- FEMA, FY2025 NSGP Frequently Asked Questions
- IRS, Publication 1828, Tax Guide for Churches and Religious Organizations (Rev. 8-2015)
- New York DHSES, FY2026 NSGP Frequently Asked Questions
- Maine Emergency Management Agency, FY2026 NSGP subapplicant NOFO
- FDEM, 2024 Florida NSGP Application Guide
- FBI Crime Data Explorer, hate crime data
- FBI Crime Data Explorer API, national Anti-Islamic (Muslim) hate crime totals, 2025 (data refreshed October 15, 2026)
- Arab American Institute, statement on the FBI's 2025 hate crime data (August 19, 2026)
- ISPU, US Mosque Survey 2020 infographic
- North American Islamic Trust, home page
- CAIR and NAIT, Best Practices for Mosque and Community Safety Guide (2026 version)
- CAIR and NAIT, Best Practices for Mosque and Community Safety (2026 PDF)
- SecurityToday, Islamic organizations launch regional active shooter training program (August 11, 2026)
- MPAC Center for Security, Technology, and Policy, Security Bulletin (January to March 2026)
- CISA, Houses of Worship Security Self-Assessment
- CISA, Physical Security Performance Goals for Faith-Based Communities (December 2023)
- Governor of New York, $70 million to protect community-based organizations (September 8, 2026)
- Pennsylvania PCCD, Nonprofit Security Grant Fund Program
- Cal OES, 2025-26 California State Nonprofit Security Grant Program RFP
- Maryland GOCPP, Protecting Against Hate Crimes grant