The National Institutes of Health has announced research security requirements, effective for applications submitted on or after January 25, 2026.
Covered individuals (i.e., each individual identified as a senior/key person) will certify that they have completed the requisite research security training that meets the research security training requirements within 12 months prior to application submission. IU’s Research Security Training (based on NSF’s modules) will satisfy both NIH requirements and is now required for submission of all proposals involving federal funding.
Research Security Training Requirements
Individual Certification at the time of application: In accordance with Section 10634 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19234) each individual identified as a senior/key person must certify that they have completed the requisite research security training that meets the research security training requirements within 12 months prior to application submission. NIH is exploring system solutions to collect this certification. As an interim solution, applicants must provide a certification, electronically signed by each individual identified as a senior/key person, as a flattened PDF in the ‘Other Attachment’ field of the R&R Other Project Information form of the application . The file for each senior/key person must be named ‘ResearchSecurities_[Name].pdf’ without quotations, where ‘[Name]’ is the name of the senior/key person.
Annual Certification at the time of the Research Performance Progress Report (RPPR): Individuals serving as senior/key personnel must continue to certify annually that they have completed training within the past 12 months. As an interim solution, a certification, electronically signed by each senior/key personnel must be uploaded in RPPR Section G.1., Special Notice of Award and Funding Opportunity Announcement Reporting Requirements section as a flattened PDF file. The file for each senior/key person must be named ‘ResearchSecurities_[Name].pdf’ without quotations, where ‘[Name]’ is the name of the senior/key person.
Malign Foreign Talent Recruitment Program Prohibition: Effective September 12, 2025, individuals who are a current party to a Malign Foreign Talent Recruitment Program (MFTRP) are not eligible to serve as a senior/key person on an NIH grant or cooperative agreement.
Malign Foreign Talent Recruitment Program Certification: NIH will require MFTRP certifications from applicants and individuals identified as senior/key personnel with its implementation of the Common Forms for Biographical Sketch and Current/Pending (Other) Support (anticipated November 2025).
Individual Certification at the time of the application: In accordance with Section 10632 of the CHIPS and Science Act of 2022 (42 U.S.C. § 19232), each individual identified by the applicant as a senior/key person must certify on their Biographical Sketch Common Form, attached on the R&R Senior/Key Person Profile (Expanded) Form, that they are not a party to a malign foreign talent recruitment program.
Annual Certification at the time of the RPPR: For NIH awards with Research Performance Progress Reports (RPPRs) due on or after January 25, 2026, individuals serving as senior/key personnel must certify annually to their participation or non-participation in an MFTRP by uploading a certification statement in Section G.1, Special Notice of Award and Funding Opportunity Announcement Reporting Requirements as a flattened PDF file. The file for each senior/key person must be named ‘ResearchSecurities_[Name].pdf’ without quotations, where ‘[Name]’ is the name of the senior/key person. NIH is exploring long-term system solutions to capture this certification.
In addition to the aforementioned certifications, IU must also certify as an institution for research security requirements and MFTRP requirements. For additional information, please review the NIH Notice NOT-OD-25-154.
For questions, please email ora@iu.edu.