Important Notice No. 149: Implementation of Updates to NSF Research Security Policies

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Questions

  1. What does NSF Important Notice No. 149 do?

    The U.S. National Science Foundation Important Notice No. 149 (NSF IN-149) implements several research security-related requirements mandated under the "CHIPS and Science Act of 2022." NSF IN-149 establishes new requirements for institutions to maintain supporting documentation on information reported as current and pending (other) support for senior/key personnel1 and for senior/key personnel to complete the requisite research security training2. NSF IN-149 updates the existing prohibition on participation in malign foreign talent recruitment programs3, 4 and the annual Foreign Financial Disclosure Requirement (FFDR)5. Finally, NSF IN-149 prohibits institutions of higher education (IHEs) from maintaining agreements or contracts with a Confucius Institute6.

    These changes strengthen NSF's and the research community's capacity to detect and mitigate evolving research security risks.

  2. Why has the implementation been delayed from the Oct. 10, 2025, date announced in the original notice?

    Due to a lapse in appropriations lasting from Oct. 1, 2025, to Nov. 12, 2025, NSF was unable to put the NSF IN-149 requirements in place.

  3. What happens to proposals submitted between Oct. 10, 2025, and the delayed effective date set forth below?

    Proposals submitted during the appropriations lapse are not subject to the new requirements that were set to take effect on Oct. 10, 2025. Compliance is required for those policies in effect prior to the shutdown, namely the MFTRP certifications and FFDR submissions.

  4. What certifications are required for researchers and organizations?

    All items in NSF IN-149 save Item 1 require certifications.

    1. NSF IN-149 Item 1: Research Security Assessment and Required Documentation
      No certification is required.
    2. NSF IN-149 Item 2: Research Security Training
      1. Senior/key personnel must certify at the time of proposal submission that they have completed the required research security training within 12 months prior to proposal submission.
      2. Organizations must certify at the time of proposal submission that all senior/key personnel have completed the above research security training.
      3. Institutions of higher education (IHEs) must also certify at the time of proposal submission to having an updated Responsible and Ethical Conduct in Research (RECR) plan that addresses mentor training and mentorship, training to raise awareness of potential research security threats, and federal export control, disclosure and reporting requirements.
    3. NSF IN-149 Items 3 and 4: Malign Foreign Talent Recruitment Program
      1. Senior/key personnel must certify at the time of proposal submission that they are not a party to an MFTRP.
      2. Individuals serving as a principal investigator (PI) or co-PI on at least one active NSF award made on or after May 20, 2024, must certify annually that they are not a party to an MFTRP.
      3. Organizations must certify at the time of proposal submission that all senior/key personnel have been made aware of and have complied with the requirement to certify that they are not a party to an MFTRP.
    4. NSF IN-149 Item 5: Foreign Financial Disclosure Requirement
      IHEs must certify and annually report all current foreign financial support from a foreign source associated with a country of concern, the value of which is $50,000 or more per source7. The covered annual reporting period of July 1 through June 30 of the subsequent year is not affected by the government's lapse in appropriation.
    5. NSF IN-149 Item 6: Confucius Institutes
      Absent a waiver, IHEs must certify at the time of proposal submission that they do not maintain a contract or agreement with a Confucius Institute.

  5. How are certifications documented in NSF proposal submissions?

    NSF IN-149 certifications occur within the proposal Cover Sheet, the Biographical Sketch, the Current and Pending (Other) Support form and Research.gov.

    1. Cover Sheet: Organizational certifications regarding research security training and the prohibitions on MFTRPs and Confucius Institutes.
    2. Biographical Sketch: Senior/key personnel certifications regarding research security training and the prohibition on participation in MFTRPs.
    3. Current and Pending (Other) Support: Senior/key personnel certifications regarding research security training and the prohibition on participation in MFTRPs.
    4. Research.gov: PI and co-PI annual certification regarding the prohibition on participation in MFTRPs and organizational certification regarding annual FFDR submission.

  6. Are certifications included as part of the proposal applicable to any other awards or proposals?

    The certifications made at the time of proposal submission apply only to the proposed project. Awards made before the effective date are not subject to the NSF IN-149 requirements.

  7. When will these changes take effect?

    These changes are effective as of Dec. 2, 2025.

  8. If I have additional questions, who should I contact?

    Please contact the NSF Office of the Chief of Research Security Strategy and Policy at researchsecurity@nsf.gov for more information. System-related questions should be directed to the NSF IT Service Desk at 1-800-381-1532 (7 a.m.-9 p.m. ET; Monday - Friday except federal holidays) or rgov@nsf.gov.

     

    Footnotes

    1 NSF IN-149 Item 1: Research Security Assessment and Required Recipient Documentation.

    2 NSF IN-149 Item 2: Research Security Training.

    3 NSF IN-149 Items 3 and 4: Malign Foreign Talent Recruitment Prohibition and Malign Foreign Talent Recruitment Program Certification.

    4 See NSF OCRSSP website for the definition of and additional information about Malign Foreign Talent Recruitment Program.

    5 NSF IN-149 Item 5: Foreign Financial Disclosure Reporting (FFDR).

    6 NSF IN-149 Item 6: Certification Regarding IHEs Hosting or Supporting Confucius Institutes.

    7 See NSF OCRSSP website for additional information on the Foreign Financial Disclosure Requirement.

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