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.
National Science Foundation (NSF)
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.
United States Department of Agriculture (USDA)
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
Certifications and Disclosures
Pre-Award
- Research security training has been completed no more than one year prior ro 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
Department of Energy (DOE)
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
Certifications and Disclosures
Pre-Award:
Post-Award:
- If information submitted on TFC has changed, submit an updated document.
- Some awards require TFC as part of continuation application
National Institutes of Health (NIH)
The NIH previously announced research security requirements, then rescinded the notice. It is still expected that NIH will implement research security training requirements in the future.