NSF Research Security Requirements

All senior/key personnel listed on an NSF proposal submitted on or after December 2, 2025 are required to have taken research security training.

To complete this training requirement, log in to LMS and take the Research Security at the University of California training. 

NSF stipulates that all PIs and co-PIs named on an NSF award made on or after May 20, 2024 must annually certify in Research.gov that they are not a party to a MFTRP.

What this Means

Individuals who are currently a party to a MFTRP are not eligible to serve as senior/key personnel on an NSF proposal or on any NSF award made on or after May 20, 2024. 

If you are a PI or co-PI who is impacted by this requirement, you will be prompted to complete the MFTRP certification after signing into Research.gov using the Sign in link at the top of the page. 

PIs and co-PIs are only required to certify once per year on the Research.gov website. 

It is anticipated that this certification requirement will be expanded to all senior/key personnel roles at a future date. 

The sharing of individual Research.gov credentials is strictly prohibited. All required certifications and attestations must be completed personally by the designated Senior/Key Personnel. 

Frequently Asked Questions, instructions and MFTRP contract examples can be found on the MFTRP section (click + for dropdown of information) of the NSF’s Office of the Chief of Research Security Strategy and Policy website.

UCSF Policy

Reminder: MFTRPs often create unmanageable conflicts of commitment. Applying to or participating in a Foreign Talent Recruitment Program (FTRP) or a MFTRP is classified as a Category I Outside Activity and requires prior institutional review and approval. All UCSF researchers must disclose any involvement in a FTRP or MFTRP as part of their annual Conflict of Interest Disclosure in Research Gateway. 

For details on the distinction between FTRPs and MFTRPs, please visit the Foreign Talent Recruitment Programs page on the Office of Ethics and Compliance website. Additional training associated with this and other research security issues can be found in the UC Learning Center (search for “Research Security at the University of California”).

In July 2026, the National Science Foundation (NSF) announced a forthcoming research security policy that will prohibit certain relationships with entities and individuals appearing on specified U.S. government restricted-party lists. NSF intends to implement the policy in Fiscal Year 2027.

NSF has stated that research security risk mitigation is not sufficient for NSF-funded projects involving these restricted entities. Once the policy becomes effective:

• NSF funds may not be used to conduct research in collaboration with a restricted entity or its employees.
• Senior/key personnel may not collaborate with a restricted entity or its employees on research funded by their NSF award.
• Senior/key personnel may not hold an appointment or position with a restricted entity for the duration of the NSF award.
• Senior/key personnel may not receive research support from a restricted entity for the duration of the NSF award.
• Authorized Organizational Representatives (AORs) and senior/key personnel will be required to certify compliance at proposal submission.
• Recipient organizations will be responsible for ensuring that senior/key personnel are aware of and comply with the prohibition and for identifying and addressing prohibited activities before NSF funds are expended.

The policy will apply to entities appearing on the U.S. proscribed-party lists identified in Appendix A of the NSF Dear Colleague Letter, including certain Department of War, Department of Commerce, Department of the Treasury, Department of State, FCC, DHS, and CBP lists.

NSF has stated that this approach is intended to align its research security requirements with the Department of War's approach to collaborations with entities on U.S. restricted-party lists.

This policy is not yet effective. UCSF is monitoring NSF's implementation and will update this guidance as additional requirements and effective dates are announced.

Read the NSF Dear Colleague Letter: Prohibition on Collaborations with Restricted Entities