National Aeronautics and Space Administration (NASA) Research Security Guidance

Overview 

The National Aeronautics and Space Administration (NASA) supports scientific research and international collaboration while protecting U.S. national interests and complying with statutory and federal research security requirements applicable to NASA-funded research.

NASA implements research security requirements through funding opportunities, grant and cooperative agreement requirements, research security training and certifications, disclosure requirements, and statutory restrictions applicable to certain international activities.

The Office of Research Security (ORS) assists investigators throughout the NASA award lifecycle by helping identify research security requirements, reviewing proposed international activities and relationships, and providing guidance on foreign appointments and affiliations, foreign talent recruitment programs, NASA's restrictions involving China, export controls, and other NASA research security considerations.

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How NASA Evaluates Research Security

NASA research security requirements emphasize transparency, compliance with federal research security requirements, and review of international activities that may be restricted by law or NASA policy.

Research security considerations may include:

• International research relationships and collaborations
• Foreign appointments and affiliations
• Foreign research support and in-kind resources
• Foreign talent recruitment programs
• Malign Foreign Talent Recruitment Programs (MFTRPs)
• Completeness and consistency of required sponsor disclosures
• Research security training and certifications
• Export-controlled equipment, software, technology, or technical information
• International transfers of research assets
• Activities subject to NASA's statutory restrictions involving China
• Other circumstances that may present research security concerns

The requirements applicable to a particular project depend on the funding opportunity, award terms and conditions, individuals and organizations involved, and proposed research activities.

Restrictions on Bilateral Activities with China

Federal appropriations law restricts NASA from using appropriated funds for certain bilateral participation, collaboration, or coordination with China or Chinese-owned companies or entities.

NASA-funded proposals and awards must not include prohibited bilateral participation, collaboration, or coordination with China or Chinese-owned companies or entities at the prime recipient or subrecipient level, including activities performed under a no-exchange-of-funds arrangement.

These restrictions can affect:

• Research collaborations
• Participating organizations
• Subrecipient relationships
• Research agreements
• Data-sharing arrangements
• Access to nonpublic research resources
• Other activities conducted as part of a NASA-funded project

The restriction applies to the activity and organizational relationship, not simply to an individual's citizenship or national origin. An individual's Chinese citizenship does not, by itself, prohibit participation in NASA-funded research.

Investigators should contact ORS before including a Chinese organization, Chinese-owned company or entity, or individual affiliated with such an organization in a NASA-funded activity.

ORS can assist investigators in evaluating proposed activities and coordinating with Sponsored Programs and other University offices, as appropriate.

Research Security Training

NASA requires research security training for covered individuals participating in applicable NASA grants and cooperative agreements.

Beginning August 5, 2026, covered individuals must certify completion of research security training before submission of applicable NASA financial assistance proposals.

NASA defines covered individuals for this requirement to include:

• Principal Investigators
• Co-Principal Investigators
• Co-Investigators proposing to devote 10 percent or more of their time in any year to the NASA-funded award

Researchers should complete required training sufficiently in advance of proposal submission and ensure that required certifications are accurate.

ORS can assist investigators with questions regarding NASA research security training requirements.

Foreign Talent Recruitment Programs

NASA implements federal requirements concerning foreign talent recruitment programs and Malign Foreign Talent Recruitment Programs.

Participation by covered individuals in a Malign Foreign Talent Recruitment Program may be prohibited under applicable federal research security requirements and may affect eligibility to participate in federally funded research.

Other foreign appointments, affiliations, research support, contractual obligations, or foreign talent recruitment activities may require disclosure or institutional review.

Investigators should contact ORS before accepting or participating in a foreign talent recruitment program or when uncertain whether a proposed activity presents research security concerns.

Proposal Development

Research security considerations should be identified early in NASA proposal development.

Investigators should contact ORS before proposal submission when a proposed project involves:

• International collaborators or foreign organizations
• China, Chinese organizations, or Chinese-owned companies or entities
• Foreign appointments or affiliations
• Foreign research support or in-kind resources
• Foreign talent recruitment programs
• Export-controlled equipment, software, technology, or technical information
• International transfers of research materials, software, technology, or technical information
• International data-sharing arrangements that may involve research security or export control requirements
• Other international activities that may present NASA research security concerns

ORS can assist investigators in determining whether additional institutional review or NASA requirements apply.

Award Management

Research security responsibilities continue throughout the life of a NASA award.

Investigators should consult ORS before:

• Establishing a new international research collaboration.
• Adding a foreign organization or collaborator to a NASA-funded activity.
• Establishing an activity involving China or a Chinese-owned company or entity.
• Accepting a new foreign appointment or affiliation.
• Receiving new foreign research support or in-kind resources.
• Participating in a foreign talent recruitment program.
• Providing international collaborators access to export-controlled equipment, software, technology, or technical information.
• Making other significant changes that may affect NASA research security requirements.

Changes during an active award may require updated sponsor disclosures, certifications, institutional review, sponsor notification, or other action before the proposed activity begins.

Activities That May Require Additional Institutional Review

Examples include:

• New international collaborations
• Activities involving China or Chinese-owned companies or entities
• Foreign appointments or affiliations
• Foreign research support or in-kind resources
• Foreign talent recruitment program participation
• Export control or sanctions concerns
• International transfers of controlled research equipment, software, technology, or technical information
• Other activities that may affect NASA research security requirements

The need for review depends on the individuals and organizations involved, the research activity, applicable NASA requirements, and other project-specific circumstances.

Activities That Are Prohibited or May Affect Funding Eligibility

Certain activities or circumstances may be prohibited or affect eligibility for NASA funding.

Examples include:

• Prohibited bilateral participation, collaboration, or coordination with China or Chinese-owned companies or entities under a NASA-funded activity.
• Participation in a prohibited Malign Foreign Talent Recruitment Program.
• Materially incomplete or inaccurate information required by NASA.
• Failure to complete required research security training or certifications.
• Failure to comply with applicable NASA research security requirements.
• Failure to comply with applicable NASA award terms and conditions.

Because NASA requirements may change and may vary by funding opportunity or award, investigators should consult ORS when questions arise regarding a proposed international activity or relationship.

How ORS Can Help

ORS assists investigators in identifying and addressing NASA research security requirements throughout the proposal and award lifecycle.

ORS can assist with:

• International collaboration reviews
• NASA China restriction reviews
• Foreign appointment and affiliation reviews
• Foreign talent recruitment program reviews
• Malign Foreign Talent Recruitment Program questions
• Research security training requirements
• Export control and sanctions reviews
• International research activities
• NASA research security consultations
• Coordination with Sponsored Programs and other University offices, as appropriate

Early consultation helps identify applicable requirements before proposal submission or before new activities begin during an active NASA award.

Related ORS Guidance

Federal Resources

For current NASA grant and cooperative agreement requirements, policies, forms, and guidance, visit NASA's Grant Operations Management resources.

NASA requirements may change over time and may vary by funding opportunity or award. Investigators should review the requirements applicable to each proposal and award.

Need Assistance?

Questions regarding NASA research security requirements should be discussed with ORS as early as possible during proposal development, before initiating new international research activities, or whenever circumstances change during an active award.

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