Emil Michael, Under Secretary of War for Research and Engineering at the U.S. Department of War (DoW) issued a directive on January 8, 2026, implementing additional research security measures to further strengthen DoW-funded fundamental research and counter foreign influence, intellectual property (IP) theft, and exploitation as “adversaries continue to adapt.”  The memo cites a December 14, 2022 memo on National Security Presidential Memorandum-33 Implementation and outlines key actions to strengthen DoW’s June 2023 Policy for Risk-based Security Reviews of Fundamental Research.  Actions include:
 

• Prohibiting DoW funding to entities listed on the 1260H list of Chinese military companies operating in the U.S., “as well as entities with a documented history of patent and IP theft.”  Per the memo, this action will be effective within 60 days of updates to the fundamental research risk review matrix.  Clarity will be sought on how the latter entities will be identified and may be provided through the matrix updates.

• Implementing annual compliance checks on “at least 25%” of all fundamental research awards with mitigation measures and providing semi-annual reports of enforcement measures.  Additional details will be sought on this process.

• Identification of a “Component Office” from each of the DoW Components (e.g., Army, DARPA, Navy and others), and the establishment of a Department-wide Fundamental Research Risk Review Repository, with a minimum viable product in the second quarter of 2026.  Per the memo, DoW Components must submit disclosure forms, documented risk-based reviews, mitigation plans, and compliance documentation (presumably from the annual compliance checks).  Additional details will be provided as available.

• DoW Component Offices will: provide information on their research security activities including the number of proposals requiring mitigation and the number including controlled unclassified information; nominate entities to be included in the agency’s 1286 list (high risk entities); and provide annual training for research security personnel to improve the quality and consistency of research security analysis.

• Component heads will be required to issue a Grant Instruction Notice requiring the inclusion of grant numbers in all publications to be implemented within 45 days of signature of the January 8 memorandum and may develop a common research grant database.  Further details are not provided.  An issue that frequently arises with grant citations in the context of research security is that DoW or other federally funded research conducted only in the U.S. may be attributed to foreign institutions due to the gap in time between students/scholars returning to their home or other countries following graduation or completion of their U.S. research, and the date when the work is published. This issue has yet to be resolved.

• Component Offices will assist the Basic Research Office in a “damage assessment of selected cases” within 45 days of the memo, including cases identified in reports from the U.S. House Select Committee on the Chinese Communist Party (CCP) on the strategic competition between the U.S. and the CCP.

• The Department’s Chief Digital and Artificial Intelligence Office will assist in the identification and development of automated and continuous monitoring capabilities with a report of findings within 180 days of the January 8th memo.
   

Prohibiting DoW funding to entities listed on the 1260H list of Chinese military companies operating in the U.S., “as well as entities with a documented history of patent and IP theft.”  Per the memo, this action will be effective within 60 days of updates to the fundamental research risk review matrix.  Clarity will be sought on how the latter entities will be identified and may be provided through the matrix updates.

Implementing annual compliance checks on “at least 25%” of all fundamental research awards with mitigation measures and providing semi-annual reports of enforcement measures.  Additional details will be sought on this process.

Identification of a “Component Office” from each of the DoW Components (e.g., Army, DARPA, Navy and others), and the establishment of a Department-wide Fundamental Research Risk Review Repository, with a minimum viable product in the second quarter of 2026.  Per the memo, DoW Components must submit disclosure forms, documented risk-based reviews, mitigation plans, and compliance documentation (presumably from the annual compliance checks).  Additional details will be provided as available.

DoW Component Offices will: provide information on their research security activities including the number of proposals requiring mitigation and the number including controlled unclassified information; nominate entities to be included in the agency’s 1286 list (high risk entities); and provide annual training for research security personnel to improve the quality and consistency of research security analysis.

Component heads will be required to issue a Grant Instruction Notice requiring the inclusion of grant numbers in all publications to be implemented within 45 days of signature of the January 8 memorandum and may develop a common research grant database.  Further details are not provided.  An issue that frequently arises with grant citations in the context of research security is that DoW or other federally funded research conducted only in the U.S. may be attributed to foreign institutions due to the gap in time between students/scholars returning to their home or other countries following graduation or completion of their U.S. research, and the date when the work is published. This issue has yet to be resolved.

Component Offices will assist the Basic Research Office in a “damage assessment of selected cases” within 45 days of the memo, including cases identified in reports from the U.S. House Select Committee on the Chinese Communist Party (CCP) on the strategic competition between the U.S. and the CCP.

The Department’s Chief Digital and Artificial Intelligence Office will assist in the identification and development of automated and continuous monitoring capabilities with a report of findings within 180 days of the January 8th memo.
 

The memo suggests these actions will better equip the DoW to anticipate emerging threats, adapt to evolving tactics, and maintain global leadership in defense, innovation and research.  Additional information and clarification on these actions will be sought and provided, as available, in future SECURE Center Research Security Briefings.

On December 31, 2025, the U.S. Department of Agriculture (USDA) released a Secretary’s Memorandum ordering all USDA agencies and staff to implement new USDA General Terms and Conditions (T&Cs) to be applied, effective immediately, to all future USDA awards.  Details can be found in the January 9, 2026, edition of the SECURE Center Research Security Briefing.  Representatives from USDA, including the National Institute of Food and Agriculture (NIFA) are scheduled to present during the Federal Agency Updates session of the upcoming virtual FDP meeting.

On January 13, 2026, the Council on Government Relations (COGR) held the virtual forum, COGR Forum VI: Adapting to Change, Policy Shifts & Research Impact, that included updates from federal agency staff as well as briefings from COGR staff and committee leaders.  While the presenters spoke to a number of sponsored research areas, the following is a summary of the research security-related topics discussed.
 

National Institutes of Health (NIH)

Michelle Bulls, Director of the NIH Office of Policy and Extramural Research Administration
 

Research Security Training

NIH reminded the community that NIH’s research security training requirement, to comply with the CHIPS and Science Act, goes into effect for applications submitted on or after May 25, 2026.  Covered individuals (for NIH, this is defined as senior/key personnel) will complete this certification on their Biosketch, via SciENcv.  Authorized Organization Representatives (AORs) will complete this certification via their signature on the face page of the application.  (See NIH NOT-OD-26-017 for additional information.)
 

Common Forms Implementation

Use of the Common Forms, via SciENcv, for Biosketches, Current and Pending (Other) Support, and NIH Biosketch Supplements will be required for all NIH applications due on or after January 25, 2026, as well as any Just in Time (JIT), Research Performance Progress Report (RPPR) and Prior Approval submissions on or after that date.  When completing their NIH Common Forms, covered individuals will also certify that they are not a party to a malign foreign talent recruitment program.  (See NIH NOT-OD-26-018 for additional information.)
 

Beginning in February, current SciENcv validation warnings will become errors instead.  There is currently a backlog of helpdesk tickets regarding documents generated from SciENcv that should pass system validation checks but are not.  NIH will not be delaying the transition of warning messages to errors but will handle delayed submissions on a case-by-case basis.  Institutions that encounter errors that delay their ability to submit should log a helpdesk ticket for the issue and include the ticket number when corresponding with NIH.  NIH is aware of the current system issue that prevents covered individuals from entering “0.0” calendar months of effort where appropriate (e.g., for outside consulting engagements) and anticipates that this issue will be resolved soon.
 

With regard to the new category “Monetary Donations” included in NIH’s Disclosure Table with associated examples, the agency will be developing examples of how monetary donations that are not “true gifts” should be reported as part of Current and Pending (Other) Support.
 

NIH intends to post a number of FAQs within the next few weeks to address repeated questions or concerns on both the Common Forms and research security training topics.
 

NIH is also continuing to work with other agencies to develop a central approach to the implementation of research security program requirements.
 

Department of Energy (DOE)

Jeannette Singsen, Senior Advisor, Office of Research, Technology, and Economic Security (RTES)
 

Use of Common Forms

DOE reminded the community that DOE requires the use of the Common Forms for Biosketches and Current and Pending (Other) Support via SciENcv for all notices of funding opportunities (NOFOs) published on January 1, 2026, or later.  For existing awards, the previous format for these documents is still acceptable (provided the terms and conditions of the award are not updated indicating otherwise), though the Common Forms are DOE’s preferred format. DOE’s Common Form for Current and Pending (Other) Support includes covered individuals’ certification that they are not a party to a malign foreign talent recruitment program.  It also includes an Addendum section with additional questions regarding the covered individual’s foreign activities.  DOE is taking a risk-based approach to its use of the Addendum section, and it is only required in a subset of NOFOs.
 

Research Security Training

DOE’s Common Form for Current and Pending (Other) Support also includes certification from the covered individual that they have completed research security training within the past 12 months.  DOE recognizes the SECURE Center Consolidated Training Module as meeting this requirement, though other forms of training are acceptable provided they meet the requirements under 42 USC 19234(c).  As RTES receives questions regarding the research security training requirement, answers are posted to the office’s FAQ page.
 

Transparency of Foreign Connections

Certain DOE NOFOs and awards also require applicants, recipients, and subrecipients to submit Transparency of Foreign Connections disclosures.  DOE has provided a suggested template to meet this requirement.
 

Entity of Concern Prohibition

DOE NOFOs and awards continue to require confirmation that no proposal/award participants, including subrecipients, appear on the 1260H or BIS Entity List, and immediate notification of DOE if an existing participant is found to be on either list.
 

Department of War (DoW)

Jason Day, Research Policy Director
 

DoW has not yet finalized their research security training requirement, but the Department’s goal is to implement the requirement by the beginning of June, to correspond roughly with NIH’s May 25th implementation date.  When DoW does implement this requirement, it plans to accept completion of the SECURE Center Condensed Training Module as fulfilling it.  Concurrent with the research security training requirement, the Department also anticipates issuing new guidance on disclosure of DoW funding (i.e., inclusion of grant numbers) in publications.
 

In response to the January 8 Fundamental Research Security Initiatives and Implementation memorandum (see above), DoW expects there will be few direct impacts on recipient institutions.  While the Department has previously used the 1260H list in its risk mitigation reviews, the January 8 memo fully prohibits them, and DoW’s risk matrix will be updated to reflect this.  The memo also requires DoW Components to complete annual spot-checks on all awards that have research security risk mitigation measures in place and at least 25% of their other fundamental research awards.  The Department may reach out to recipient institutions if questions arise as a result of these reviews.  Forum participants requested that these questions be communicated through AORs and not solely principal investigators.
 

While they are not using the SciENcv platform, DoW is implementing the Common Form formats through the SF424 versions hosted by NSF.  DoW has looked at implementing SciENcv and that remains a long-term goal.  The Department is also looking at consolidating IT systems, with respect to grants and cooperative agreements, across its various research Components.
 

DoW also continues to work with other agencies on harmonized research security program requirements and expects to sign on to them once finalized.
 

National Science Foundation (NSF)

Jason Bossie, Office of Budget, Finance, and Award Management
 

Foreign Financial Disclosure Reporting (FFDR)

NSF noted that the December 8, 2025 Supplement to the Proposal & Award Policies & Procedures Guide (PAPPG) includes the clarification for FFDRs that satellite, branch, or regional campuses that are not direct recipients of NSF funding must report any financial support via the main campus of the recipient institution.
 

Per the request of forum participants, NSF will provide additional messaging to the community when it makes future updates to the FFDR FAQ page.
 

Additional Updates

Kris West, COGR Director for Research, Ethics, and Compliance, noted that COGR is aware of the recent release of USDA’s Standardized Terms and Conditions (see above) and will be following up with the community as they learn more.

Across three major higher-education associations’ responses to the White House Office of Science and Technology Policy’s request for information on “Accelerating the American Scientific Enterprise” initiative, there is strong consensus that federal research security policy must both protect sensitive research and avoid unnecessary burdens on researchers. Each group emphasizes the need for harmonized, risk-based, and clearly communicated federal requirements to ensure institutions can meet national-security objectives without undermining scientific productivity.
 

The Association of American Universities (AAU) recommends continued implementation and greater harmonization of NSPM-33 requirements, arguing that aligned disclosure, cybersecurity, and training expectations would strengthen national safeguards while preventing duplicative, inconsistent processes that slow research progress.
 

The Association of Public and Land-grant Universities (APLU) similarly recommends “rightsized” research security requirements that maintain appropriate protections while eliminating conflicting agency-specific rules that increase administrative workload. It urges full standardization of disclosure forms, consistent use of platforms such as SciENcv and iEdison, and clearer federal guidance so institutions can comply efficiently and uniformly.
 

COGR’s letter emphasizes that effective research security must be risk-proportionate and aligned across agencies, warning that the current state of overlapping and sometimes inconsistent foreign-engagement reviews, reporting obligations, and cybersecurity standards create significant administrative strain. COGR urges reaffirmation of NSDD-189, reduction of duplicative requirements, and practical implementation guidance that preserves openness and international collaboration.

Agence France-Presse reports that China is increasingly attracting top global research talent not only through state-backed recruitment programs like the Thousand Talents Plan, but also through the growing strength, funding, and prestige of its institutions. Academics cite generous resources, rapid infrastructure development, access to large and fast-moving industries, and opportunities for applied, high-impact research as major draws—especially for early-career researchers. While tighter research security and political scrutiny in the United States are reported to have pushed some China-born scientists to return, challenges remain, including concerns over academic freedom, geopolitical sensitivities, and cultural differences. Even so, many researchers say China’s research environment has become highly competitive with leading Western institutions, making it an increasingly attractive destination for building ambitious research programs. (more)

Irish Taoiseach (Prime Minister) Micheál Martin has said there is no national security risk from closer links between Irish universities and Chinese institutions during a visit to China, despite recent warnings from an Irish military intelligence official about potential influence. Martin argued most collaborative research isn’t sensitive, that proper “guardrails” are in place, and that academic autonomy and freedom remain intact. He also described partnerships with Chinese colleges as long-standing and beneficial, and supported wider EU-China trade engagement to tackle issues such as rare minerals and agricultural exports. (more)

Registration is now open for the Federal Demonstration Partnership (FDP) virtual meeting, January 26-28, 2026.  The preliminary agenda includes a number of research security-related sessions:
 

Monday, 1/26/2026

• 1:15 – 3:00 PM (ET):  Federal Agency Updates

  • Moderator/Hosts: Michelle Bulls, Director, Office of Policy for Extramural Research Administration, NIH

  • Speakers:

    • Kimberly Whittet, NIFA

    • Chelsea Cole, USDA

    • Kasima Garst, NIH

    • Jason Bossie, NSF
       

• 3:15 – 5:00 PM (ET):  Foreign Influence Federal Panel

  • Moderator/Hosts: Jim Luther, Yale University
     

1:15 – 3:00 PM (ET):  Federal Agency Updates

• Moderator/Hosts: Michelle Bulls, Director, Office of Policy for Extramural Research Administration, NIH

• Speakers:

  • Kimberly Whittet, NIFA

  • Chelsea Cole, USDA

  • Kasima Garst, NIH

  • Jason Bossie, NSF
     

Moderator/Hosts: Michelle Bulls, Director, Office of Policy for Extramural Research Administration, NIH

Speakers:

• Kimberly Whittet, NIFA

• Chelsea Cole, USDA

• Kasima Garst, NIH

• Jason Bossie, NSF
   

Kimberly Whittet, NIFA

Chelsea Cole, USDA

Kasima Garst, NIH

Jason Bossie, NSF
 

3:15 – 5:00 PM (ET):  Foreign Influence Federal Panel

• Moderator/Hosts: Jim Luther, Yale University
   

Moderator/Hosts: Jim Luther, Yale University
 

Tuesday, 1/27/2026

• 11:00 AM – 12:30 PM (ET):  Research Security & Subawards Working Group

  • Speakers:

    • Taren Ellis Langford, Executive Director, Research Security& Responsible Outside Interests, The University of Arizona

    • Jennifer J. Ford, Research Compliance and Integrity (RCI) Operational Executive Director, University of California San Diego
       

• 1:00 – 2:15 PM (ET):  Research Security Requirements Deep Dive

  • Moderator/Hosts: Lisa Nichols, University of Notre Dame
     

• 3:55 – 5:00 PM (ET):  DOJ Bulk Data Rule (Tentative)

11:00 AM – 12:30 PM (ET):  Research Security & Subawards Working Group

• Speakers:

  • Taren Ellis Langford, Executive Director, Research Security& Responsible Outside Interests, The University of Arizona

  • Jennifer J. Ford, Research Compliance and Integrity (RCI) Operational Executive Director, University of California San Diego
     

Speakers:

• Taren Ellis Langford, Executive Director, Research Security& Responsible Outside Interests, The University of Arizona

• Jennifer J. Ford, Research Compliance and Integrity (RCI) Operational Executive Director, University of California San Diego
   

Taren Ellis Langford, Executive Director, Research Security& Responsible Outside Interests, The University of Arizona

Jennifer J. Ford, Research Compliance and Integrity (RCI) Operational Executive Director, University of California San Diego
 

1:00 – 2:15 PM (ET):  Research Security Requirements Deep Dive

• Moderator/Hosts: Lisa Nichols, University of Notre Dame
   

Moderator/Hosts: Lisa Nichols, University of Notre Dame
 

3:55 – 5:00 PM (ET):  DOJ Bulk Data Rule (Tentative)

Wednesday, 1/28/2026

• 2:30 – 3:45 PM (ET):  SciENcv

  • Moderator/Hosts: Lori Schultz, Colorado State University

2:30 – 3:45 PM (ET):  SciENcv

• Moderator/Hosts: Lori Schultz, Colorado State University

Moderator/Hosts: Lori Schultz, Colorado State University

Registration is now open for COGR’s virtual membership meeting, taking place February 24-27, 2026.  Information regarding dates and times of research security-related sessions will be included in future SECURE Research Security Briefings as details become available.

Registration is now open for the 2026 Academic Security and Counter Exploitation (ASCE) Program. Next year is the 10th anniversary of the largest research security conference in the world: February 24 - 26, 2026. (more)

Texas A&M University’s Research and Innovation Security and Competitiveness (RISC) Institute disseminates weekly RISC Media Bulletins, covering topics related to research security, foreign influence, and the intersection of science, technology, and national security.  To join the distribution list for the RISC Bulletin or view previous editions, access this link for more info.

Faculty Researchers at universities, non-profits or other research institutions, who have received federal funding and are working in quantum computing, computer science, and related fields are invited to volunteer for short virtual information-gathering sessions.  The sessions, organized by the NSF-funded SECURE Center, aim to gather researchers’ perspectives on challenges related to research security and international collaboration, with a focus on developing practical, low-burden resources to address these challenges. Participation will directly inform future guidance, training, and tools intended to reduce administrative workload and impediments to international collaborations while safeguarding research. Sessions originally planned for January are now scheduled for:
 

• Wednesday, February 4, 2026, 12-1:00 pm ET

• Friday, February 6, 2026, 10-11:00 am ET

• Wednesday, February 11, 2026, 1-2:00 pm ET

• Friday, February 20, 2026, 11:00 am-12:00 pm ET

• Friday, February 20, 2026, 2-3:00 pm ET
   

Wednesday, February 4, 2026, 12-1:00 pm ET

Friday, February 6, 2026, 10-11:00 am ET

Wednesday, February 11, 2026, 1-2:00 pm ET

Friday, February 20, 2026, 11:00 am-12:00 pm ET

Friday, February 20, 2026, 2-3:00 pm ET
 

Faculty researchers are encouraged to share this opportunity with research colleagues who may be interested. Questions or interest to participate should be directed to SECURE Center staff at researchsecurity@nd.edu.

2026 issues of the Research Security Briefing are available on the SECURE Center website.

A combined, searchable version of all 2025 issues of the Briefing is also available.

Looking to participate in NSF SECURE Center co-creation activities or contribute to weekly briefings?

Contact info@secure-center.org or sign up here.

The information provided by the NSF SECURE Center is intended for general research and educational purposes only. While we strive to ensure the accuracy and reliability of our content, we do not guarantee its completeness, timeliness, or applicability to specific circumstances. Each user is responsible for conducting their own risk assessments and making decisions based on independent judgment.

Further, the NSF SECURE Center does not provide professional or legal advice, and users are encouraged to consult qualified professionals before making decisions based on the information found here. The NSF SECURE Center shall not be liable for any damages or costs of any type arising out of or in any way connected with your use of this information. External links are provided for convenience and do not constitute an endorsement of the content or services offered by any third-party resources.

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