The U.S. National Science Foundation (NSF) has announced a sweeping new research security policy that will prohibit NSF-funded researchers from collaborating with organisations appearing on U.S. restricted party lists. The policy, outlined in a Dear Colleague Letter issued on 8 July 2026, represents a significant shift from the agency's previous risk-based approach and is expected to take effect during Fiscal Year 2027.
Although the policy is framed as applying to entities on multiple U.S. government restricted lists rather than any specific country, many of the listed organisations are Chinese universities, national laboratories, research institutes, and technology companies. As a result, the new rules are expected to substantially reduce research collaboration between U.S. scientists supported by NSF funding and a large number of Chinese institutions.
A shift from risk management to prohibition
For several years, the NSF sought to balance research security concerns with the benefits of international scientific collaboration. In 2024, the agency introduced its Trusted Research Using Safeguards and Transparency (TRUST) framework, which aimed to assess national security risks while allowing appropriate international partnerships to continue.
The new policy marks a clear departure from that approach. In its Dear Colleague Letter, the NSF stated that it has concluded that "research security risk mitigation for NSF-funded projects involving these restricted entities is not sufficient." Consequently, rather than assessing collaborations on a case-by-case basis, the agency intends to prohibit them altogether when they involve organisations appearing on designated U.S. restricted lists.
According to Science, the decision aligns the NSF more closely with the U.S. Department of Defense's research security policy and reflects growing congressional pressure to tighten scientific engagement with China.
What the new policy requires
Once the policy comes into force, NSF appropriated funds may not be used for research conducted in collaboration with restricted entities or their employees.
The restrictions extend beyond institutional partnerships. Senior and key personnel participating in NSF-funded projects will also be prohibited from:
- Collaborating with restricted entities or their employees on NSF-funded research;
- Holding appointments or positions with restricted entities during the period of an NSF award; and
- Receiving research funding or support from restricted entities while participating in an NSF-funded project.
Universities submitting NSF proposals will be required to certify compliance with these requirements. Authorised Organizational Representatives (AORs) and principal investigators will be expected to confirm that prohibited collaborations do not exist, while institutions will be responsible for ensuring ongoing compliance before NSF funds are expended.
Restricted lists cover hundreds of organisations
The policy applies to entities appearing on multiple U.S. government restricted party lists maintained by agencies including the Department of War, Department of Commerce, Department of the Treasury, Department of State, Department of Homeland Security, Federal Communications Commission, and U.S. Customs and Border Protection.
These include the Bureau of Industry and Security's Entity List, Military End-User Entities, Denied Persons List, the Non-SDN Chinese Military-Industrial Complex Companies List, the UFLPA Entity List, and several others.
According to reporting by Science, these combined lists contain hundreds of leading Chinese universities, national laboratories, research institutes, and technology organisations. However, not every prominent Chinese university is currently included. For example, Tsinghua University is not among the restricted entities covered by the NSF policy at present.
Questions remain over the scope of "collaboration"
Despite the announcement, universities are still awaiting detailed implementation guidance.
One of the principal uncertainties concerns the definition of "research collaboration." It remains unclear whether the prohibition will extend beyond jointly funded research projects to include activities such as co-authoring academic papers, informal discussions at international conferences, data sharing, or other scholarly interactions.
Research policy experts have noted that other U.S. federal agencies, including the National Institutes of Health (NIH) and NASA, have adopted relatively broad interpretations of collaboration in certain contexts. Whether the NSF will adopt a similarly expansive interpretation is expected to become clearer when its final guidance is issued.
The NSF has invited comments from the research community before the policy is formally incorporated into its grant guidance.
Mixed reactions across the research community
The announcement has received strong support from policymakers who argue that scientific collaboration with certain foreign institutions presents unacceptable national security risks.
Representative John Moolenaar, Chair of the U.S. House Select Committee on China, described the NSF's decision as "commendable and commonsense" and encouraged other federal agencies to adopt similar restrictions.
However, many researchers have expressed concern that the policy may significantly reduce international scientific cooperation. Some scientists argue that collaboration with Chinese researchers has contributed substantially to advances in areas including physics, chemistry, engineering, medicine, and climate science, and that blanket restrictions could slow scientific progress.
Observers also note that the White House Office of Management and Budget (OMB) has proposed broader Uniform Guidance reforms that would prohibit federally funded collaborations with entire "countries of concern," including China, Russia, Iran, and North Korea. If adopted, those regulations would go beyond the NSF's entity-based approach and further reshape the landscape of international research collaboration.
Implications for universities worldwide
The forthcoming NSF policy is expected to have significant implications not only for U.S. universities but also for institutions around the world that participate in NSF-funded research.
Universities engaged in international research partnerships may need to conduct more rigorous due diligence, review joint appointments, examine collaborative research agreements, and strengthen internal research security compliance procedures. Institutions with extensive partnerships involving U.S. funding and Chinese collaborators are likely to face particularly complex compliance challenges.
More broadly, the policy reflects a continuing evolution in U.S. research policy, where national security considerations are increasingly influencing international scientific collaboration. For universities seeking to maintain global research partnerships, navigating these changing regulatory requirements is likely to become an increasingly important aspect of research governance in the years ahead.
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