Forthcoming NSF Research Security Policy on Collaborations with Restricted Entities

We want to make you aware of a Dear Colleague Letter (NSF 26-022) issued by the National Science Foundation (NSF) on July 8, 2026, signaling a forthcoming NSF policy that would prohibit NSF-funded collaboration with entities on various U.S. government-restricted parties lists (including lists maintained by the Departments of Commerce, Treasury, State and War). The restricted entity lists may be found on Appendix A of the Dear Colleague Letter. NSF is UK’s second largest federal funding agency ($37.3 million in FY26) and compliance will be required to ensure continued funding.

Under the anticipated policy, senior/key personnel on NSF awards will be prohibited from collaborating with these restricted entities or their employees, holding appointments or positions with them or receiving research support from them for the duration of an award. In addition, senior/key personnel on NSF awards will be required to certify compliance with these requirements at the time of proposal submission. NSF has indicated this may have implications for co-authorship and other forms of research collaboration and appears to be taking a broad interpretation of collaboration, though the agency has not yet defined precisely what activities will count as collaboration under the policy.

Though this policy is not yet in effect, NSF intends to implement it alongside its forthcoming replacement for the Proposal and Award Policies and Procedures Guide (PAPPG), with an anticipated effective date in FY27 (which could be as early as October 1, 2026), and has invited public comment before finalizing the guidance.

We are sharing this now so you can begin reviewing any active or planned collaborations, appointments or positions, or research support that might be affected by these new requirements to ensure compliance once they become effective. We’ll follow up with more specific guidance as it becomes available. UK researchers with current international collaborations as part of a project sponsored by NSF should reach out to SECURE at UK-SECURE@uky.edu to screen the foreign entities against the lists referred to in Appendix A.