Federal Agency Research Security Requirements

Many sponsors are implementing research security requirements for applicants and awarded researchers.

Always confirm that the information below aligns with the sponsor’s latest requirements before submitting a proposal or annual certification.

Table of Contents

• DARPA – Defense Advanced Research Projects Agency
• DOD – Department of Defense
• DOE – Department of Energy
• NASA – National Aeronautics and Space Administration
• NIH – National Institutes of Health
• NSF – National Science Foundation
• USDA – United States Department of Agriculture
• Understanding the National Perspective

Agency Guidance
DAPRA Risk Assessment Model: Fundamental Research Risk-Based Security Review Process (pdf) DARPA Countering Foreign Influence Program (pdf)

Agency Guidance
DOD Risk Assessment Model: Countering Unwanted Foreign Influence in Department-Funded Research at Institutions of Higher Education  (pdf) DOD Controlled Unclassified Information Guidance

Research Security Training

Who: Covered Individuals DOE defines a Covered Individual as someone who contributes in a substantive, meaningful way to the development or execution of the scope of work of a project funded by DOE or proposed for funding by DOE. The DOE may choose to designate others as covered individuals. When: Training must be completed before proposal submission. Your completion date must be within the last 12 months. Course required: Responsible Conduct of Research (RCR) All covered individuals paid by the DOE should self-enroll and complete the RCR course. Sponsor requirement: Financial Assistance Letter Research Security Training Requirements for all R&D Financial Assistance Awards

Agency Certifications and Disclosures
Pre-Award: – Submit Transparency of Foreign Connections (TFC) Disclosure and Certification Post-Award: – If information submitted on TFC has changed, submit an updated document. – Some awards require TFC as part of continuation application.

WashU Proposal Certifications
WashU General Assurance Statement WashU’s DOE 142.3b Foreign National Certification Form WashU’s DOE 486.1a FGTRP Certification Form

Prior Approval Guidance & Prohibitions
Foreign Government Sponsored Or Affiliated Activities and FAQs, Foreign Government Sponsored or Affiliated Activities: Individuals are prohibited from participating in Foreign Talent Programs of a Foreign Country of Risk Unclassified Foreign National Access Program: requires prior approval for foreign national requests for access to DOE sites, information, or technologies

Agency Guidance
DOE Office of Science Laboratory Policy Research Security  DOE Directive on Foreign Government Talent Recruitment Programs  DOE Directive on Unclassified Foreign National Access Program  DOE Request for Unclassified Foreign National Access  DOE Risk Assessment Model: DOE Approach to RTES Risk

Prior Approval Guidance & Prohibitions
Special Restrictions for Non-U.S. Organizations – see section 2.2.1: In general, research with foreign organizations shall not be conducted through grants or cooperative agreements; and according to section 526 of PL 117-103, NASA is prohibited from funding any work that involves the bilateral participation, collaboration, or coordination with China or any Chinese-owned company.

WashU Proposal Certifications
WashU General Assurance Statement WashU’s NASA GIC 12-01 Certification Form

Agency Guidance
Special Restrictions for Non-U.S. Organizations – see section 2.2.1

Research Security Training
Effective for applications submitted for due dates on or after May 25, 2026. Who: Individuals listed as senior/key personnel When: Training must be completed before proposal submission. Your completion date must be within the last 12 months. Course required: Responsible Conduct of Research (RCR) Sponsor requirement: Research Security Training Requirements for NIH (NOT-OD-26-017)

Certifications

Effective for for application due dates and RPPR submissions on or after January 25, 2026. Pre-Award: Each senior/key personnel member must certify that they are not party to a malign foreign talent recruitment program. This is collected on Biographical Sketch. Post-Award: Every year at the time of RPPR, senior/key personnel must upload a statement in Section G.1 that certifies participation or non-participation in a malign foreign talent recruitment program.  Sponsor requirement: NIH’s Implementation of Common Forms for Biographical Sketch and Current and Pending (Other) Support for Due Dates on or after January 25, 2026 (NOT-OD-26-018) Review the MFTRP section on the Guidance for Foreign Talent Programs page for more information on MFTRPs.

Prior Approval Requirements
Applications with Foreign Components: any activities that meet the definition of a foreign component, need prior approval

Agency Guidance
NIH Guidance on Investigator Disclosures of Foreign Financial Interest (NOT-OD-18-160) NIH Foreign Interference  NIH Risk Assessment Model: NIH Decision Matrix (pdf)

Research Security Training

Effective October 10, 2025. Who: Individuals listed as senior/key personnel When: Training must be completed before proposal submission. Your completion date must be within the last 12 months. Course required: Responsible Conduct of Research (RCR) All individuals paid by NSF are assigned the RCR course. Applicant senior/key personnel not currently funded by the NSF must self-enroll. This course also fulfils the NSF’s Responsible and Ethical Conduct of Research requirements. Sponsor requirement: Important Notice No. 149: Updates to NSF Research Security Policies

Certifications
Pre-Award: Each senior/key personnel member must certify that they are not party to a malign foreign talent recruitment program. Post-Award: PIs and Co-PIs on awards made on or after May 20, 2024 must complete an annual certification about involvement in a malign foreign talent recruitment program.

Agency Guidance
NSF Research Security NSF Report on Fundamental Research Security  NSF Report Safeguarding the Research Enterprise NSF Risk Assessment Model: NSF TRUST Risk Assessment/Mitigation Framework

Research Security Training

Who: The latest USDA guidance specifies that the requirements apply to applicants. When: – Initial training must be completed before proposal submission. Your completion date must be within the last 12 months. -Training is required annually for the duration of the award. Course required: Responsible Conduct of Research (RCR) All individuals paid by USDA should self-enroll and complete the RCR course. This course also fulfils the USDA’s Responsible and Ethical Conduct of Research requirements. Sponsor requirement: America First Memorandum for USDA Arrangements and Research Security

Certification and Disclosures

Pre-Award – Research security training has been completed no more than one year prior to application date. – Not party to malign foreign talent recruitment program. – Many other certifications and disclosures are required by the USDA. Review the sponsor requirement for full details. Post-Award: – Annual certification required to confirm they are not party to a malign foreign talent recruitment program. – Annual update of additional certifications and disclosures.

Agency Guidance
America First Memorandum for USDA Arrangements and Research Security

Understanding the National Perspective

Legislative and agency guidance on efforts to address this challenge.

Office of Science and Technology Policy 

• Guidelines for Research Security Programs at Covered Institutions
• Enhancing the Security and Integrity of America’s Research Enterprise Presentation 
• Critical and Emerging Technologies List 

Joint Committee on the Research Environment 

• Recommended Practices for Strengthening the Security and Integrity of America’s Science and Technology Research Enterprise 

Foreign Influence Legislation 

• Presidential Memorandum 33 (NSPM-33) is intended to strengthen protections of U.S. Government-supported R&D against foreign government interference and misappropriation
• CHIPS & Science Act of 2022, section 10634, establishes a framework for Research Security Programs
• National Defense Authorization Act 2019: Section 889, includes prohibitions from purchasing or using telecommunications equipment and services from certain foreign companies. 

National Counterintelligence and Security Center (NCSC)

• Safeguarding Science
• Federal Funding Agency Requirements and Guidance
• Federal Funding Agency Prior Approval Requirements or Prohibitions
• Foreign Component Reporting