The document presents a detailed overview of current and forthcoming federal research security requirements as they pertain to federally funded research activities and institutions. It summarizes both federal-wide mandates and agency-specific implementations regarding disclosure of biographical and research support information, risk assessment processes, financial conflicts of interest (FCOI), conflicts of commitment (COC), training and certification obligations, and requirements for institutional research security programs. Central to these requirements are recent policy instruments such as NSPM-33, the CHIPS Act, and FY 2021 NDAA, which emphasize accurate and comprehensive personal and institutional disclosures, enhanced risk mitigation processes, strict prohibitions on participation in malign foreign talent recruitment programs (MFTRPs), and the establishment of robust training and research security programs for institutions with significant federal funding.
The summary tabulates how major federal research agencies—including DARPA, Army Research Lab, Department of Defense, Department of Energy, EPA, NASA, NIST, NIH, NSF, and USDA—are responding to and implementing these mandates. It highlights the transition to standardized disclosure forms, the gradual rollout of risk assessment and research security frameworks, and evolving training and certification requirements, some of which remain under development or recently revised. The document notes particular variations between agencies in the timing and details of compliance, especially regarding standalone COC policies and the finalization of central certifications and training standards. Institutions are urged to monitor agency communications closely for updates, as many requirements are currently being phased in or subject to further revision, most notably at NIH, which recently rescinded earlier implementation guidance in favor of forthcoming standards. Overall, the document serves as a comprehensive reference for understanding the increasingly stringent federal expectations around research security, disclosure, and integrity in the academic and scientific enterprise.
