Agency Training Requirements

Grant Information Circular issued by NASA on February 5, 2026 to implement the research security training (RST) and certification requirements mandated by Section 10634 of the CHIPS and Science Act of 2022 for all research grant and cooperative agreement proposals submitted to the agency. Covered individuals (PIs, Co-PIs, and Co-Is proposing 10 percent or more effort) must certify on their Biographical Sketch and Current and Pending (Other) Support forms that they completed RST within the 12 months prior to proposal submission, with applicant entities certifying via NSPIRES. Requirements take effect August 5, 2026, and NASA recognizes the NSF SECURE Center's Consolidated Training Module (CTM) as a compliant option.

Issued on October 7, 2024, this document outlines DOE's implementation of research security training requirements for covered individuals on financial assistance applications and for organizations applying for an award. The requirement was effective immediately but not mandatory until May 1, 2025. The training requirement is satisfied either by completion of the four training modules created by NSF, completion of the SECURE Center CTM (as indicated per DOE post FAL), or by a custom training program that is aligned with the CHIPS and Science Act Section 10634(b). Per DOE the training must be completed within the 12 months immediately preceding the application submission, consistent with the CHIPS Act requirements, and any covered individuals added to the project must certify that they have completed the training within 30 calendar days of joining the project.

The Department of Energy's official page describing its research security training requirement for R&D financial assistance awards. Effective May 1, 2025, covered individuals (PI, PD, Co-PI, Co-PD, project manager, and any individual functionally performing such roles, with possible expansion via NOFO terms and conditions) must complete research security training within 12 months prior to proposal submission. DOE accepts the SECURE Center Condensed Training Module (CTM).

Effective October 1, 2025, recipient institutions must train senior/key personnel on the requirement to disclose all research activities and affiliations in Other Support and maintain a 'written and enforced policy on requirements for the disclosure of other support to ensure Senior/Key Personnel fully understand their responsibility to disclose.'

On December 2, 2025, NIH released NOT-OD-26-017 notifying the extramural community that, effective for applications submitted for due dates on or after May 25, 2026, each individual listed as senior/key personnel must certify they have completed research security training (RST) within 12 months of the date of application submission. The certification is collected via the Biographical Sketch in SciENcv. Applicants may use any RST addressing topics mandated under the CHIPS and Science Act, and NIH recognizes completion of the SECURE Center condensed training module (CTM) as compliant.

Published July 10, 2025. Includes NSF implementation of three new requirements (and three existing ones) in alignment with the CHIPS and Science Act and NSPM-33. The requirements, effective October 10, 2025, include: a. Recipient institutions must maintain supporting documentation for foreign activities reported as current and pending (other) support, b. Senior/key personnel must certify they have completed research security training (RST) within 12 months prior to proposal submission; Recipient institutions' Authorized Organizational Representative (AOR) must certify that all senior/key personnel have completed required RST and that the institution has a plan to provide appropriate training, c. AORs at institutions of higher education (IHEs) must certify that, absent a waiver granted by the NSF Director, the IHE does not maintain a contract or agreement between the institution and a Confucius Institute.

On November 25, 2025, the National Science Foundation (NSF) released an update to the agency's Important Notice No. 149. The update states that the requirements originally slated to take effect in October 2025 instead take effect on December 2, 2025 as a result of the recent government shutdown. The impacted requirements include: certifications of research security training for senior/key personnel; institutional certifications regarding contracts or agreements with Confucius Institutes; and recipient institutions providing supporting documentation for senior/key personnel activities reported as current and pending (other) support (e.g., contracts, grants, appointment letters) to NSF, upon request.

On December 5, 2025, NSF notified the research community that it is offering a grace period for enforcement of Important Notice No. 149 for proposals submitted between December 2 and December 31, 2025, to accommodate programs with deadlines near the December 2, 2025 effective date. NSF will continue to accept proposals using the previous Biographical Sketch and Current and Pending (Other) Support forms until December 31, 2025; after that date, all proposals must incorporate the new senior/key personnel certifications (research security training within the past 12 months and not being a party to a malign foreign talent recruitment program) required under Important Notice No. 149.

On December 31, 2025, the USDA released a Secretary's Memorandum ordering all USDA agencies and staff to implement new USDA General Terms and Conditions (T&Cs), effective immediately, for all future USDA awards. The new General T&Cs include several research security-related requirements, including institutional certification regarding foreign ownership, control, or influence by a country of concern, institutional malign foreign talent recruitment program certification, institutional research security training certification, and institutional certification of Common Form information.

On December 31, 2025, USDA released a Secretary's Memorandum ordering all USDA agencies and staff to implement new USDA General Terms and Conditions (T&Cs), applied effective immediately to all future USDA awards. The new General T&Cs include several research security-related requirements: institutional certification regarding foreign ownership, control, or influence by a country of concern; institutional malign foreign talent recruitment program (MFTRP) certification; institutional research security training certification; and institutional certification of Common Form information.