National Policies
NSPM-33: An update on Research Security
COGR Matrix of Science and Security Laws, Regulations and Policies
OSTP- Guidelines for Research Security at Covered Institutions
Guidelines for Federal Research Agencies Regarding Foreign Talent Recruitment Programs
Safeguarding Science Toolkit, Office of the Director of National Intelligence
Background on Regulations
DOD: The DoD Fundamental Research Decision Matrix prohibits the use of DoD funds for fundamental research conducted in collaboration with, or using equipment from, entities appearing on DoD Prohibited Entity Lists. The restriction applies not only to new purchases but also to equipment already owned and used on DoD-funded projects, requiring researchers to stop using this equipment or work with DOD to develop transition or mitigation plans. Additional research security restrictions apply to collaborations (even co-authorship) with Prohibited Entities, foreign funding from countries of concern, and participation in malign foreign talent recruitment programs.
NSF: NSF announced on July 8, 2026, in its "Dear Colleague" letter, its intent to implement in Fiscal Year 2027 a new policy prohibiting (1) use of NSF funds on collaborations with entities on certain U.S. restricted parties lists, lists, and (2) senior/key personnel on NSF-funded projects from holding an appointment or position with, or receiving research support from, these restricted entities for the duration of their NSF award. Although the policy is scheduled for full implementation in FY2027, NSF has already begun incorporating these restrictions into certain award and proposal review processes.
Other Agencies: While other major federal research funding agencies, such as NSF, NIH, DOE, and USDA have implemented similar risk review processes and/or rely on U.S. restricted party lists (including the 1260H list) to assess international affiliations and collaborations, they are progressing on their imposed prohibitions—like those of the DoD—on the use of equipment from listed entities.
However, the BIOSECURE Act, enacted on December 18, 2025, does broadly restrict procurement involving biotechnology products or services over the course of several years. While not effective in the immediate-term, under this Act, federal agencies and entities that receive federal funds cannot “procure or obtain any biotechnology equipment or service produced or provided by a biotechnology company of concern,” (BCC) and agencies and grantees are also prohibited from entering, extending, or renewing a contract with an entity that uses equipment or services provided by a BCC.
Entities are automatically designated as a BCC through inclusion on the 1260H list. In addition, the Office of Management and Budget has been directed to determine which additional entities should be classified as BCCs by December 18, 2026, and to publish a list annually. The prohibition is anticipated to become effective in Summer/Fall 2028. What is not known is whether individual federal agencies will, like DoD, implement their own prohibitions on equipment from 1260H listed entities in advance of BIOSECURE Act implementation.