UPDATED Dec. 5, 2025 – The National Science Foundation announced today it had implemented a grace period for enforcement of NSF Important Notice No. 149 for proposals submitted between Dec. 2 and Dec. 31.
“We have been made aware of challenges for NSF programs with deadlines that fall close to the December 2, 2025 effective date of NSF IN-149,” stated the notice from the NSF Office of the Chief of Research Security Strategy and Policy. “We understand the tight turnaround may make it difficult for some senior/key personnel to submit the updated Biographical Sketch and Current and Pending (Other) Support forms in time.”
According to the notice, the NSF will accept proposals that include the earlier version of the Biographical Sketch and Current and Pending Support form between Dec. 2 and Dec. 31. Proposals submitted after Dec. 31 must be fully compliant with NSF IN-149.
Editor’s Note: The following post was originally published on Nov. 26, 2025.
The National Science Foundation (NSF) informed organizations on Tuesday that key research security policy updates originally slated to go into effect on Oct. 10 will now begin on Dec. 2. These updated policies – outlined in Important Notice No. 149: Updates to NSF Research Security Policies – align with the CHIPS and Science Act of 2022 and National Security Presidential Memorandum-33. According to the NSF, they are intended to strengthen the integrity and security of U.S.-funded research. Key changes include:
- Mandatory research security training: Senior and key personnel must complete approved research security training within 12 months prior to proposal submission. Organizations must certify completion at submission.
- Expanded documentation requirements: Institutions must maintain detailed supporting documents – such as foreign appointments, contracts, employment agreements and current and pending support – for all senior and key personnel and provide them to NSF upon request.
- Risk-based reviews: NSF may review proposals and awards to identify undisclosed foreign activities or conflicts.
The new requirements apply to proposals submitted on or after Dec. 2. Notice No. 149 also reemphasizes a number of existing NSF policies related to research security, including:
- Restrictions on participation in Malign Foreign Talent Recruitment Programs (MFTRPs): Individuals participating in MFTRPs may not serve as senior or key personnel on NSF proposals or awards. Certification of non-participation is required both before and during an award.
- Foreign financial disclosure reporting: Universities and colleges receiving NSF funds must report annual foreign gifts or contracts totaling $50,000 or more from countries of concern.
- Confucius Institute provisions: Universities and colleges with contracts or agreements supporting a Confucius Institute are ineligible for NSF funding unless strict waiver criteria are met.
A detailed FAQ is available on the NSF website. For questions, contact the NSF Office of the Chief of Research Security Strategy and Policy at [email protected].