FDP Research Security Subcommittee Co-authorship and Foreign Components: A Discussion with NIH Extramural Leadership

In collaboration with the Federal Demonstration Partnership (FDP) Research Security Subcommittee, NIH has released a FAQ document on Co-authorship and Foreign Components. The FAQs are based on questions and answers provided during the session "Co-authorship and Foreign Components: A Discussion with NIH Extramural Leadership" held on September 15, 2026, as part of FDP's virtual meeting. The FAQs use a variety of scenarios to clarify when foreign co-authorship or collaboration would likely be considered a "foreign component," requiring NIH prior approval. NIH notes that most foreign co-authorship represents a foreign component, and that if a foreign engagement is expected to result in co-authorship, the institution should seek prior approval. The FAQs list exceptions that are not foreign components or collaborations, including informal scientific conversations, one-way transfers of data or materials, peer review, conference participation, and editing conducted by a former U.S. postdoc who has moved abroad.