Executive Summary
New U.S. Department of Defense (DoW) research security rules—effective by May 8, 2026—may directly affect your eligibility for funding or require mitigation if you have certain international collaborations or co-authors. In addition, foreign equipment from certain international organizations may be prohibited on your next DoW project. You are most likely impacted if you:
- Collaborate or have published (in the past 5 years) with entities on a now expanded group of U.S. restricted lists;
- Have equipment you use in your research from a foreign organization on these lists
Why this matters: DoW fundamental research proposals can now be flagged for risk, require mitigation, or be denied funding based on these factors. In some cases, use of certain equipment or collaborations will be prohibited at the project level. If any of the above may apply to you, please review the details below and the matrix carefully. If you have questions please reach out to ORS.
Details
Recent updates to the DoW Decision Matrix to inform risk assessments and mitigation decisions for fundamental research proposals can impact how your proposal is assessed and the equipment you can use on funded projects. The changes will be effective within 60 days of the March 9, 2026 release date (by May 8, 2026).
The department issued its first centralized decision matrix and process in June 2023 and has updated it annually since that time. This updated matrix brings more substantial changes than previous versions following the DoW’s January 2026 memo, “Fundamental Research Security Initiatives and Implementation”.
The Decision Matrix notes that: “Funds appropriated for the DoW may not be used for grants, contracts, other transactions or other assistance to an institution of higher education if the purpose is to conduct fundamental research in collaboration with, or using equipment from [emphasis added], any entity named on any of the ‘Prohibited Entity Lists’…This funding prohibition also extends to the employees of such institutions.”
“Prohibited Entity Lists” refers to a compilation of 13 U.S. Government (USG) lists, now included in the DoW Decision Matrix, a significant increase from the four lists previously included and also used in other agency risk assessments such as the Department of Energy and National Science Foundation. During a late-February research security meeting, and in response to subsequent outreach, DoW representatives confirmed that the prohibition on equipment was at the project level, not applicable to universities broadly, and that it applied to future awards. This means that equipment from foreign sources included on the Prohibited Entity Lists may not be used on the proposed/awarded project.
In the updated Decision Matrix, the mitigation categories available for DoW Components has been reduced from five to the following three:
1. Prohibited factors;
2. Mitigation measures required; and
3. No mitigation needed.
The four risk factors remain the same:
- Foreign Talent Recruitment Programs: the focus is on “malign” programs as defined in section 10638(4) of the CHIPS and Science Act of 2022 and this DoW document. Individuals currently participating in a malign program are prohibited from applying for or receiving DoW—and any federal—funding. Mitigation measures, which are project specific and defined by the agency or in concert the institution (e.g., reporting international travel), are required if there are indicators of participation in the last five years.
- Funding Sources: mitigation is required if covered individuals (senior/key personnel) received funding in the last five years from a foreign country or entity of concern. Foreign countries of concern (FCOC) include China, Russia, North Korea and Iran. For DoW, China includes Hong Kong and Macau.
- Patents: patents filed resulting from USG-funded research that were first filed in a FCOC or on behalf of an FCOC entity, in a non-FCOC and not disclosed, or with an individual affiliated with an entity on the Prohibited Entity Lists.
- Entity Lists: collaboration with entities on the 13 prohibited lists identified in the updated matrix.
Notably, risk factors that now require mitigation measures include:
- Within the past five years, the covered individual’s co-author(s) on publications in science and engineering journals are affiliated with an entity on any Prohibited Entity List at the time of review. [Emphasis added]
- Within the past five years, the covered individual’s co-author(s) on publications in scientific and engineering journals are participants in a malign foreign talent recruitment program meeting any of the criteria defined in the CHIPS and Science Act.
Co-authors: Regarding co-authorship, the cited January 8, 2026 DoW memo indicates that DoW component heads will be required to issue a Grant Instruction Notice requiring inclusion of grant numbers in all publications, to be implemented within 45 days of signature of the memo. Important considerations for co-authorship and grant citations in publications include:
- Performance of significant elements of a U.S. Government-funded project outside the U.S. must be disclosed and approved by the funding agency in advance.
- When citing a grant in a publication, link the grant to the appropriate author (e.g., “D.E.F. was funded by NIH grant AI123456”).
- Cite only grants that supported the conduct of the study and if the work was in-scope.
- If a student, postdoctoral scholar, or visiting scholar has subsequently moved to another institution, cite the (home/grantee) institution where the work was conducted and not the current affiliation of the co-author. Otherwise, if the current affiliation is on a Prohibited Entity List, this will impact the risk assessment of your proposal, including with other agencies. However, if the work was conducted at another institution that must be cited.
Per the introductory text “Collaborations between covered individuals and international researchers do not require mitigation if they do not involve any of the factors described in [the Matrix].”