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Department of Defense Issues Updated Risk Matrix for Fundamental Research

Executive Summary

New U.S. Department of Defense (DoD) research security rules—effective March 9, 2026—may directly affect your eligibility for funding or require mitigation if you have certain international collaborations, activates or co-authors. In addition, foreign equipment from certain international organizations may be prohibited on your next DoD 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 foreign equipment you use in your research from an organization on these lists
  • Foreign talent recruitment program participation, foreign funding from foreign countries of concern (FCOC) or certain foreign patent activities (FCOC or undisclosed)

Why this matters: DoD 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 you have DoD funding or plan to apply to the DoD,  please review the following information and matrix carefully, as it outlines new compliance requirements that could affect your proposals and future projects.

Details

Overview:  Recent updates to the DoD/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 new funded projects. The changes will be effective within 60 days of the March 9, 2026 release date.

  • 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 DoD/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. During a late-February research security meeting, and in response to subsequent outreach, DoD 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.

Mitigation Categories:  In the updated Decision Matrix, the mitigation categories available for DoD 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 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 DoD, 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: collaborations with entities on the 13 restricted or prohibited lists identified in the updated matrix. The following are prohibited on the DoW matrix:  Active collaboration for the specific purpose of fundamental research between a covered individual and any academic institution or entity, or employee of such entity, on the current Prohibited Entity Lists.  Or  Funding of or to an entity on any of the Prohibited Entity Lists, or employees of such entities.

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 (MFTRP) meeting any of the criteria defined in the CHIPS and Science Act.

Co-authorship:  Regarding co-authorship, the cited January 8, 2026 DOW memo  indicates that 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 is being conducted at another institution that must be cited and if outside the country likely approved in advance by the funding agency.

What can you do to prevent issues?

  • Do not participate in malign foreign talent recruitment programs or related activities.
    If you are unsure whether an opportunity qualifies, contact the Export Controls & International Compliance (ECIC) team for assistance.
  • Provide full and accurate disclosures in all required documents (e.g., biosketch, Other Support, proposal disclosures, and project updates).
    This includes but is not limited to:
    • Appointments or affiliations (paid, unpaid, visiting, honorary)
    • Funding or in‑kind support (research, travel, materials, equipment)
    • Patent filings, invention disclosures, and IP agreements
    • International collaborators and co-authors
    • Any current or past involvement with talent recruitment program
  • Carefully vet current or planned collaborators and co‑authors, especially in science and engineering fields and particularly if individuals are affiliated with a Foreign Country of Concern. The ECIC team can help review and vet collaborators or co‑authors.
  • Request restricted party screenings through the ECIC team.
    ECIC can verify whether any collaborators, co‑authors, institutions, or companies appear on Prohibited Entity Lists.
  • For any U.S. government–funded research:  Do not file patent applications in foreign jurisdictions before filing in the United States. Ensure all related IP activity is fully disclosed to the university and in sponsor documentation.
  • Ensure that any equipment you plan to use is not sourced from an entity on a Prohibited Entity List. The ECIC team can conduct screenings to confirm equipment providers are not restricted parties.
  • Ask questions early and often. If something is unclear—or if you think an issue might be a concern—contact the Export Controls & International Compliance (ECIC) team for guidance.