NSPM-33 Disclosure Guidance

A Presidential Memorandum issued in January 2021 to strengthen protections of U.S. Government-supported R&D against foreign government interference and exploitation. It focuses on ensuring full disclosure of potential conflicts of interest and commitment by recipients of federal R&D and requires research institutions receiving over $50 million in federal R&D funding to certify they operate a research security program covering cybersecurity, foreign travel security, insider threat awareness, and export control training. As of November 2025, federal agencies continue to coordinate and work to implement this requirement for awardee institutions.

A supplement to NSPM-33 outlining recommendations for research organizations to enhance research security and integrity. Categories include: Demonstrate organizational leadership and oversight; Establish an expectation of openness and transparency; Provide and share training, support, and information; Ensure effective mechanisms for compliance with organizational policies; and Manage potential risks associated with collaborations and data.

A January 2022 report by the White House OSTP/NSTC Research Security Subcommittee providing additional details on 1.) Disclosure Requirements and Standardization 2.) Persistent Identifiers 3.) Consequences for Violation of Disclosure Requirements 4.) Information Sharing and 5.) Research Security Programs. Largely superseded by the final July 9, 2024 guidelines.

A summary document issued by COGR in January 2022 that highlights key points of the Guidance for Implementing NSPM-33 Provisions.

A November 2023 supplement to the NSPM-33 Implementation Guidance that provides definitions of terms used throughout the guidance and related policy documents.

Published September 3, 2025, a National Academies Committee conducted an expedited study to examine federal research regulations and identify ways to improve regulatory processes and administrative tasks, reduce or eliminate unnecessary work, and modify and remove policies and regulations that have outlived their purpose while maintaining necessary and appropriate integrity, accountability, and oversight. Research security specific options include: implement the NSPM-33 common disclosure forms and disclosure table without deviation; establish common principles for agency research security risk reviews for fundamental research; continue prior efforts to streamline and clarify export controls; and adapt cybersecurity requirements for university settings.