Federal research sponsors continue to expand research security, disclosure, training, and international collaboration requirements. Investigators should pay particular attention to research security training obligations, foreign collaboration disclosures, current and pending support reporting, foreign talent recruitment program restrictions, and agency-specific certification requirements. This resource provides a centralized reference for key sponsor requirements, updates, and guidance from NIH, NSF, DoW, DOE, and NASA.
National Institutes of Health (NIH)
- Foreign Components Definition (May 2026) – Expanded the previous definition of foreign components
- Research Security Training Requirements (December 2025) – Required for applications submitted for due dates on or after May 25, 2026
- New International Collaboration Award Structure (September 2025) - Effective for due dates on or after January 25, 2026, competing applications requesting funding for foreign components must use NIH’s new international collaboration award structure
- Updated NIH Policy on Foreign Subawards (May 2025) - Applies to applications submitted before May 1, 2025, and active projects on or before May 1, 2025
National Science Foundation (NSF)
- Prohibition on Collaborations with Restricted Entities - Beginning in FY 2027, senior/key personnel on NSF-funded projects will be prohibited from collaborating with entities on U.S. restricted parties lists. Institutions and senior/key personnel will be required to certify compliance with these restrictions during proposal submission.
- NSF SECURE Center
- Important Notice No. 149 - Effective December 2, 2025, including research security training certification, required supporting documentation for foreign appointments/employment/talent program participation, MFTRP certifications, Confucius Institute restrictions, and updated Foreign Financial Disclosure Report requirements.
- NSF Disclosure Information - Summary table updated January 2023
- NSF Biographical Sketch Format and NSF Current & Pending Support Format – NSF approved biographical sketch and current and pending support formats
Department of War (DoW)
- Academic Research Security - including the DoW risk matrix, policy for risk-based security reviews of fundamental research projects, 1286 entity list, and relevant memos.
- 2026 DoW Component Decision Matrix
- DoW Section 1260H List – List of names of “Chinese Military Companies” operating directly or indirectly in the United States
Department of Energy (DOE)
- DOE Covered Individual Form - DOE now requires covered individuals to complete the Common Forms for Biographical Sketch and Current and Pending (Other) Support in SciENcv, certify no current participation in a Malign Foreign Talent Recruitment Program, and, for R&D proposals, certify completion of research security training.
- DOE Research Security Training Requirement Covered individuals must complete research security training within the 12 months before application submission for applicable R&D applications/projects; mandatory as of May 1, 2025.
- DOE Current & Pending Support Disclosure Requirements
National Aeronautics and Space Administration (NASA)
- Research Security Training Requirement
- NASA Grant and Cooperative Agreement Manual / Common Disclosure Forms – Effective October 1, 2024, covered individuals must submit NASA’s biographical sketch and current and pending support disclosure forms with applications.
- NASA Common Disclosure Forms
- NASA Pre- and Post-Award Disclosure Requirements – NASA provides a disclosure matrix identifying which activities must be disclosed in the biographical sketch, current and pending support, facilities/equipment/other resources, and project reports.
- Wolf Amendment Guidance
General Federal Disclosure Resources
When to Contact the Research Security Office
Not sure whether an activity requires disclosure or review? The Research Security Self-Assessment Checklist below highlights common research security risk indicators and provides guidance on when to consult the Research Security Office.
Research Security Self-Assessment Checklist for Principal Investigators
A quick guide to help determine when to contact the Research Security Office. Please note that UT considers the following to be Countries of Concern (CoC): China (including Hong Kong and Macau), Russia, Iran, North Korea, Cuba, and Venezuela.
GREEN: Generally Low Risk
- Collaborations with U.S. institutions
- Standard publication, peer review, and conference activities
- Fully disclosed domestic and non-CoC international research support
- Equipment and software purchased through approved institutional processes
- Research activities consistent with award terms and conditions
YELLOW: Contact Research Security for Review
- Foreign appointments, visiting positions, adjunct appointments, or honorary titles
- International research collaborations
- Non-CoC international travel related to research activities
- Receipt of foreign funding, gifts, equipment, data, materials, or services
- Participation in foreign research programs or centers
- Foreign patent filings or intellectual property agreements
- Foreign students, scholars, or visiting researchers working on sensitive projects
- Sharing unpublished research, software, technical information, or proprietary data with international collaborators
RED: Research Security Review Required
- Participation in a Malign Foreign Talent Recruitment Program (MFTRP)
- Undisclosed foreign appointments, affiliations, or research support
- Undisclosed foreign collaborations
- Funding from, or collaboration with, restricted or prohibited entities
- Professional travel to CoCs
- Use of equipment, software, services, cloud platforms, or technologies associated with entities on federal restricted or prohibited lists
- Foreign ownership, control, or influence concerns involving research activities
- International transfer of controlled technical data, software, biological materials, or export-controlled technology
- Any sponsor notification involving research security, foreign influence, export controls, or disclosure concerns
Before Submitting a Proposal, Progress Report, or Renewal
- Have I disclosed all appointments and affiliations?
- Have I disclosed all current and pending support?
- Have I disclosed all foreign collaborations?
- Have I disclosed all outside professional activities?
- Have I reviewed equipment and vendors used on my project?
- Have I disclosed patent activity related to my research?
- Have I completed required Research Security training?
- Have all senior/key personnel completed required disclosures?
DoW-Funded Researchers: Additional Considerations
- Foreign Talent Recruitment Program participation
- Foreign Countries of Concern (FCOC) funding
- Foreign patent activity
- Collaborations with restricted entities
- Equipment or technology manufactured by entities appearing on DoW prohibited entity lists, including the Section 1260H Chinese Military Companies List
Examples of entities recently added to the Section 1260H list include Alibaba, Baidu, TP-Link, Unitree Robotics, WuXi AppTec, Novogene, and Complete Genomics.
When in doubt, ask. A quick conversation before a proposal submission, equipment purchase, collaboration, or foreign engagement can prevent compliance and research security issues later.