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. For additional information visit RIOs info page.
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
- Keep your DEPA current and disclose all international collaborations and affiliations.
- Screen prospective collaborators and institutions against restricted-entity lists before engaging. Contact the CIRES Exports Team for any potentially sensitive collaborations, and the CIRES Export team will work with the Office of Research Security and Export Controls (ORSEC) if necessary.
- 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.
- 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).
- Ensure publication acknowledgments cite specific award numbers and that co-author affiliations are accurate and current. See OCG's Disclosing Other Support guidance.
