NIH Tightens Foreign Influence Disclosure: What Applicants Need to Know (2024)

Hook

If you’re seeking or managing NIH funding, prepare for new compliance hurdles: NIH has rolled out significantly tighter guidance around disclosure of foreign affiliations and support. As of 2024, all NIH grant applicants and awardees must adhere to new government-wide “research security” rules, including a standardized Foreign Disclosure Form process in eRA Commons. The expectation for thorough, ongoing disclosure is higher—and the stakes for oversight, enforcement, and institutional risk have never been clearer.

Context

The new guidance operationalizes federal initiatives such as National Security Presidential Memorandum-33 (NSPM-33) and the July 2024 OSTP Research Security Program Guidelines. For years, NIH and other federal agencies have pushed for greater transparency around international collaborations and foreign funding. These moves come amid intensifying concerns in Congress and the broader policy community over foreign influence, especially from adversarial countries, in U.S. biomedical research.

NIH has updated its eRA Commons User Guide to include explicit instructions for submitting the Foreign Disclosure Form. This form is now a required part of the grant application, post-award reporting, and specific compliance reviews. The forms go far beyond previous requirements. Investigators must disclose not just current or pending funding, but also any foreign appointments, contracts, gifts, lab support, and even participation in foreign talent programs. Institutions are receiving new Notices of Policy Change (e.g., NOT-OD-26-018, effective January 25, 2026) that formalize these requirements and signal further changes ahead.

Concerned? You aren’t alone. University research offices, compliance professionals, and professional societies are warning about increased administrative burden, possible chilling effects on international collaboration, and confusion stemming from fast-moving and varied agency expectations. Nevertheless, the policy momentum is clear: standardized, detailed disclosure—and the institutional procedures needed to support it—are here to stay.

Impact

Researchers, PIs, and Investigators

If you submit to NIH, you’ll soon notice a new, mandatory Foreign Disclosure Form requirement for all roles—not just PI or key personnel. Expect to be asked for:

• Foreign positions, affiliations, and advisory roles
• Foreign funding, gifts, or in-kind support (including equipment or personnel)
• Participation in non-U.S. talent programs

Submission will be through eRA Commons, both at proposal and post-award. Responding quickly to Foreign Disclosure Requests for Additional Materials will become routine.

Importantly, retroactive scrutiny is intensifying. Errors or omissions—even if unintentional—can now trigger investigations and enforcement actions. Past lapses will be less likely to escape notice, especially if you’ve held multiple international appointments or collaborations.

Grant Administrators and Institution Leaders

Research offices are facing pressure to implement robust review procedures for all NIH submissions. Proactive pre-submission checks of biosketches, Other Support, and Foreign Disclosure Forms are becoming the norm. Compliance, export control, and sponsored programs staff will need updated training and closer coordination to ensure nothing slips through the cracks, especially with the new NOT-OD-26-018 notice looming for 2026.

Many institutions are rolling out training sessions titled “Understanding Other Support, Disclosures & Foreign Influences” to clarify exactly what must be reported and how. Centralized disclosure review, documentation of compliance, and even mandatory attestation procedures are in development to address the new expectations.

Nonprofits and Small Businesses (SBIR/STTR Applicants)

SBIR/STTR proposals must also now answer the Foreign Disclosure Form and related requests. This specifically includes a SBIR/STTR Foreign Disclosure Form—Request for Additional Materials. Foreign venture capital, overseas subsidiaries, or technical advisory relationships must be disclosed—even informal ones. This is crucial, as federal scrutiny of small business research is climbing, particularly where cross-border interests exist.

Actionable Steps

Here’s what you should do now:

1. Review and update disclosure practices. Immediately review your NIH grant application process to ensure all foreign affiliations, support, and relationships are fully captured. Institute a pre-submission compliance review checklist and educate your PIs.
2. Familiarize yourself with new forms. Download the latest eRA Commons User Guide and examine the new Foreign Disclosure Form interface. Pay special attention to triggers for “Requests for Additional Materials.”
3. Attend training and update policies. Join institution or agency-led webinars on research security and the new NIH rules. Update internal templates and faculty resources—as well as recordkeeping practices.
4. If in doubt, disclose. The threshold for required disclosure is broad; if you’re unsure whether to report an international relationship or support, err on the side of transparency.
5. Plan for continuity. These rules will keep evolving. Dedicate staff to track compliance updates and coordinate with legal or sponsored research offices as necessary.

Outlook

Expect further federal tightening—across NIH, NSF, and other agencies—on research security and foreign influence disclosures. There may be additional clarifications or changes before the 2026 deadline for NOT-OD-26-018 compliance, and the political environment suggests limited likelihood of rollback. Watch for agency updates, especially regarding harmonization of requirements across federal research funders.

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