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ARTICLE · 30 JULY 2026

New NSF Policy On Collaborations With Restricted Entities Raises Significant Compliance Risks

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The US National Science Foundation has introduced a sweeping new policy prohibiting the use of NSF funds for research collaborations with organizations on federal restricted-party lists, raising critical compliance questions for universities and research institutions. With certification requirements expected to take effect in Fiscal Year 2027, organizations face potential False Claims Act liability and other enforcement consequences if they fail to identify and address prohibited relationships. The policy's

United StatesGovernment, Public Sector
Tyler Evans
Tyler Evans
Patrick F. Linehan
Patrick F. Linehan
Alex Wolf
Alex Wolf
Matthew Steinway
Matthew Steinway

On July 8, 2026, the US National Science Foundation (NSF) issued a Dear Colleague Letter, titled "Prohibition on Collaborations with Restricted Entities," which announces a new policy that prohibits the use of NSF funds for "research in collaboration with" organizations identified on certain US government restricted-party lists. NSF states that this policy is necessary to protect national security and foreign policy interests, because current policies are, in its view, insufficient to address the risks posed by collaborations with such restricted entities. Given the potential for False Claims Act liability and other noncompliance consequences, all NSF recipients should review their partnerships, affiliations, outside activities of senior/key personnel, and other relationships to prepare for the new certification and compliance requirements expected to take effect in Fiscal Year 2027, which begins on October 1, 2026. Although the full scope of the policy has yet to be detailed,

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