National Science Foundation (NSF) Research Security Guidance
Overview
The National Science Foundation (NSF) supports open scientific collaboration while promoting transparency, responsible stewardship of federally funded research, and protection of the U.S. research enterprise.
NSF implements research security requirements through its research security policies, proposal and award requirements, certifications, training requirements, and risk-based review processes. These requirements address areas such as international research relationships, foreign appointments and affiliations, foreign talent recruitment programs, disclosure of research support, and other activities that may present research security concerns.
The Office of Research Security (ORS) assists investigators throughout the NSF 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, restricted entities, export controls, and other NSF research security considerations.
How NSF Evaluates Research Security
NSF's Office of the Chief of Research Security Strategy and Policy administers the agency's research security activities.
NSF uses the Trusted Research Using Safeguards and Transparency (TRUST) framework to assess proposals for potential national security risks while supporting openness and international scientific collaboration.
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)
- Organizations or individuals subject to U.S. Government restrictions
- Research involving critical and emerging technologies
- Completeness and consistency of required sponsor disclosures
- Other circumstances that may present research security concerns
NSF may conduct research security risk assessments of proposals and awards and may request supporting documentation related to foreign appointments, employment, foreign talent recruitment programs, research support, or other disclosed activities.
Depending on the circumstances, NSF may determine that additional information, institutional review, or other measures are necessary.
TRUST Framework
NSF's TRUST framework is designed to support risk-based review of NSF-funded research while preserving the openness and international collaboration that are fundamental to scientific research.
The framework emphasizes three complementary areas:
Transparency
NSF relies on complete and accurate information regarding professional appointments, research support, affiliations, collaborations, and other relationships relevant to federally funded research.
Transparency allows NSF to evaluate potential research security concerns and determine whether additional review is appropriate.
Compliance
Investigators and recipient institutions must comply with applicable NSF research security requirements, including required certifications, research security training, disclosure requirements, and award conditions.
Foreseeable National Security Considerations
NSF may evaluate whether particular research activities, technologies, relationships, or circumstances present foreseeable national security considerations requiring additional review.
Research involving critical or emerging technologies or certain international relationships may receive additional scrutiny depending on the circumstances.
Foreign Talent Recruitment Programs
NSF prohibits individuals who are current participants in a Malign Foreign Talent Recruitment Program (MFTRP) from serving as Senior/Key Personnel on NSF proposals or applicable NSF awards.
NSF also requires certifications regarding MFTRP participation at proposal submission and annual certifications for applicable Principal Investigators and co-Principal Investigators with active NSF awards.
Participation in other foreign talent recruitment programs is not necessarily prohibited. However, appointments, affiliations, compensation, research support, contractual obligations, or other activities associated with a foreign talent recruitment program may be subject to 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 meets the federal definition of an MFTRP.
Collaborations with Restricted Entities
NSF has announced a forthcoming research security policy prohibiting certain activities involving organizations appearing on specified U.S. Government restricted-party lists.
Under the announced policy, NSF intends to prohibit Senior/Key Personnel from:
- Collaborating with restricted entities or their employees on research funded by an NSF award.
- Holding an appointment or position with a restricted entity during the period of an NSF award.
- Receiving research support from a restricted entity while serving as Senior/Key Personnel on an NSF award.
NSF has announced that it intends to implement these requirements in Fiscal Year 2027 in conjunction with updated NSF financial assistance guidance.
Investigators should contact ORS before establishing new relationships with foreign organizations when restricted-entity concerns may apply.
ORS can conduct Restricted Entity Screening and assist investigators in determining whether an organization or proposed activity is subject to applicable U.S. Government or NSF restrictions.
Proposal Development
Research security considerations should be identified early in NSF proposal development.
Investigators should contact ORS before proposal submission when a proposed project involves:
- International collaborators or foreign organizations
- Foreign appointments or affiliations
- Foreign research support or in-kind resources
- Foreign talent recruitment programs
- Organizations that may appear on U.S. Government restricted-party lists
- Research involving critical or emerging technologies
- Export-controlled technology, software, equipment, or technical information
- International transfers of research materials, software, technology, or technical information
- Other international activities that may present research security concerns
ORS can assist investigators in determining whether additional institutional review or sponsor requirements apply.
Award Management
Research security responsibilities continue throughout the life of an NSF award.
Investigators should consult ORS before:
- Establishing a new international research collaboration.
- Accepting a new foreign appointment or affiliation.
- Receiving new foreign research support or in-kind resources.
- Participating in a foreign talent recruitment program.
- Establishing a relationship with an organization that may be subject to U.S. Government restrictions.
- Providing international collaborators access to export-controlled technology, software, equipment, or technical information.
- Beginning other international activities that may affect NSF research security requirements.
Changes during an active award may require updated sponsor disclosures, certifications, institutional review, or notification to NSF.
Activities That May Require Additional Institutional Review
Examples include:
- New international collaborations
- Foreign appointments or affiliations
- Foreign research support or in-kind resources
- Foreign talent recruitment program participation
- Relationships involving restricted entities
- Research involving critical or emerging technologies
- Export control or sanctions concerns
- International transfers of controlled research equipment, software, technology, or technical information
- Other activities that may affect NSF research security requirements
The need for review depends on the individuals and organizations involved, the research activity, applicable NSF 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 NSF funding.
Examples include:
- Participation by Senior/Key Personnel in a prohibited Malign Foreign Talent Recruitment Program.
- Materially incomplete or inaccurate information required by NSF.
- Failure to complete required research security training or certifications.
- Failure to comply with applicable NSF research security requirements.
- Activities involving restricted entities when prohibited under applicable NSF policy.
- Failure to comply with applicable NSF award terms or agreed-upon research security measures.
Because NSF requirements may change, investigators should consult ORS when questions arise regarding the permissibility of a proposed international activity or relationship.
How ORS Can Help
ORS assists investigators in identifying and addressing NSF research security requirements throughout the proposal and award lifecycle.
ORS can assist with:
- International collaboration reviews
- Foreign appointment and affiliation reviews
- Foreign talent recruitment program reviews
- Malign Foreign Talent Recruitment Program questions
- Restricted Entity Screening
- Research security training requirements
- NSF research security consultations
- Export control and sanctions reviews
- International research activities
- 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 NSF award.
Related ORS Guidance
| Resource | Description |
|---|---|
| Federal Sponsor Risk Matrices | Overview of sponsor-specific research security risk considerations and guidance for federally sponsored research. |
| Federal Sponsor Disclosure Requirements | Guidance regarding Biographical Sketches, Current and Pending (Other) Support, Common Forms, certifications, and other sponsor disclosure requirements. |
| Foreign Talent Recruitment Programs | Guidance regarding foreign talent recruitment programs, Malign Foreign Talent Recruitment Programs, applicable federal prohibitions, and institutional review. |
| Countries of Concern | Information about countries subject to federal research security requirements or heightened institutional review. |
| Restricted Entity Screening | Guidance regarding screening individuals and organizations against U.S. Government restricted party and restricted entity lists. |
| Research Activities & Guidance | Activity-based guidance for international collaborations, foreign-sponsored research, international travel, visitors, agreements, information sharing, and other research activities. |
| Export Controls | Information about U.S. export control requirements applicable to research equipment, software, technology, technical information, international transfers, and foreign person access. |
| Research Security Training | Information about University and federally required research security training. |
Federal Resources
For current NSF research security policies, requirements, training, and related guidance, visit the NSF Research Security website.
NSF 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 NSF 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.