Federal agencies are implementing heightened, agency-specific requirements governing international research collaboration, particularly co-authorship or joint activity involving PRC-affiliated or other restricted entities. To remain compliant with continuously evolving requirements, scientists should regularly review affiliations, keep DEPA forms current, and consult the CIRES Exports Team before initiating a potentially sensitive collaboration. For fundamental research collaborations, it is mainly institutional affiliations, rather than an individual’s nationality that is the key consideration, as restrictions are typically based on an individual's organizational affiliations. A collaboration with a scientist may be permitted while that scientist is employed and affiliated with a non-restricted entity, however once that scientist begins a new affiliation with a restricted party, that collaboration would no longer be allowed without approval from the CU Assistant Vice Chancellor of Research Integrity and Compliance. If you are a CU Boulder researcher working on a federally funded project, please see new campus guidance on international collaboration, with specific attention to new requirements from NASA, NIH and NSF. For additional information visit RIOs info page and Foreign Research Collaborations disclosure.

Each agency is enforcing its own distinct mechanism rather than a uniform standard, and this is a fast-moving compliance environment. 

NASA: Wolf Amendment

- Prohibits bilateral collaboration with China, Chinese-owned entities, or individuals affiliated with PRC-entities on NASA-funded work, funded or unfunded.

- Following a May 2026 House Select Committee report, NASA and Congress have reinforced enforcement, including scrutiny of co-authored publications with PRC-affiliated researchers.

- A publication acknowledging NASA funding with a PRC-affiliated co-author creates a strong presumption the research fell within the award's scope.

- See OCG's NASA Proposal Essentials for the internal China Assurance Form.

NIH: Foreign Component Policy

- Most foreign co-authorship now constitutes a reportable "foreign component" requiring prior approval, disclosure after the fact is not sufficient.

- Recent guidance (NOT-OD-26-084; June 2026 update reaffirms and expands oversight of foreign collaborations.

- See OCG's NIH Foreign Component Guidance.

NSF:  Forthcoming Restricted-Entity Prohibition

- A July 8, 2026 Dear Colleague Letter announced a new policy prohibiting collaboration with entities on 12 federal restricted-party lists.

- Senior/key personnel will be barred from any appointment with, or support from, a restricted entity for the award's duration.

- Expected to take effect FY2027 (October 1, 2026), researchers should begin reviewing current collaborations now.

Action Items for Researchers

• Consult the CIRES Exports and External Unfunded Research Agreements Team before initiating a potentially sensitive collaboration.  We can scan people and entities for you, and if they are on any restricted lists, we will find that out for you. There are a lot of different lists, let us check them for you. The CIRES Export team will work with the Office of Research Security and Export Controls (ORSEC) if necessary.
• Regularly review your affiliations and collaborators, and the affiliations of your collaborators. If there is a concern, have us help you investigate the situation.
• Keep your DEPA up to date and disclose all international collaborations and affiliations. The DEPA now asks about foreign collaborations. If you have any issues while filling out the DEPA, contact us, we are here to help negotiate the DEPA too.
• Disclose changes in a collaborator's institutional affiliation to the CIRES Exports Team and on the DEPA within 30 days (15 days if you have any DOD funding).
• For the first time, we have seen sponsors wanting us to verify that no key personnel on a project have any fundamental research collaborations with a prohibited entity, or an employee of a prohibited entity, prior to awarding the project funding.
• Concern for the Future: It appears that sponsors are going to be scanning publications, looking to see if the scientists they plan to fund have any concerning collaborations. For the sponsor, a publication with a co-author who is an employee of a prohibited entity will be a concern to be looked into, prior to awarding funding.
• From the CU Director of Research Security: [regarding collaborations with people affiliated with Restricted Entities] We generally say that it’s not advisable to proceed given the current approach within the federal government. We also point to the emerging restrictions and potential for future negative perception (as with NSF) and have outlined that in this current environment, we need to take a proactive security-minded approach.
• Please note that any fundamental Research Collaboration with an employee of a prohibited entity requires approval from the CU Assistant Vice Chancellor of Research Integrity and Compliance.
• Contact the CIRES Proposal team to discuss any NASA proposal that may involve a PRC-affiliated collaborator, or any NIH proposal that may involve a potential foreign component.
• Ensure publication acknowledgments cite specific award numbers and that co-author affiliations are accurate and current. See OCG's Disclosing Other Support guidance.

Contact us at: CIRES Export and Research Agreements Help Desk: ciresexporthelp@colorado.edu