Examples
Worked examples
- Is an instance
A principal investigator on an NIH-funded clinical trial holds $50,000 in stock options in the biotechnology company that manufactures the drug being tested -- a financial interest above 42 CFR Part 50's $5,000 significant-financial-interest threshold, requiring disclosure to the institution and evaluation for a management plan before award funds are spent.
- Is an instance
A journal editor is assigned to make the final decision on a manuscript submitted by their own doctoral advisor. No money changes hands, but the close personal and professional relationship is a non-financial conflict; ICMJE guidance requires the editor to disclose it and recuse from handling that manuscript.
- Is an instance
A university's technology-transfer office holds equity in a spinout company and is later asked to review, on the university's behalf, a sponsored-research agreement between that same company and one of the university's own faculty labs -- an institutional conflict of interest, because the stake belongs to the institution itself, not to any single investigator.
Counter-examples
Looks similar, but isn't
- Not an instance
A researcher receives a standard grant from a public funding agency or non-profit that has no stake in a particular study result. The funding relationship is still disclosed as a funding source, but it is not usually treated as a 'conflict' in the same sense as industry funding, because the agency has no interest in which specific outcome the research reaches.
Editorial commentary
A conflict of interest (COI) in research exists whenever a researcher’s, reviewer’s, official’s, or institution’s outside financial or personal interests could reasonably be seen to compromise — or actually do compromise — objective, unbiased conduct, review, or oversight of research. The operative test is not whether bias actually occurred; it is whether a reasonable person, aware of the secondary interest, could conclude it created a risk of undue influence over the primary interest (the integrity of the research itself, or the individual’s duty to their institution, funder, or journal). Having a conflict of interest is not, by itself, evidence of wrongdoing — financial relationships, consulting work, and institutional affiliations are common and expected in an active research career. What research-integrity frameworks treat as a problem is an undisclosed or unmanaged conflict, not the underlying relationship’s mere existence.
Financial vs. non-financial conflicts of interest
COI policies across funders, journals, and institutions consistently split conflicts into two categories, and most disclosure processes ask about both.
Financial conflicts involve money, equity, or anything convertible to it: employment or consulting income, honoraria, stock or stock options, patents and royalties, paid expert testimony, and research funding or in-kind support (equipment, study drug) from an entity with a stake in the outcome. Under the US Public Health Service’s financial conflict of interest (FCOI) regulations at 42 CFR Part 50, Subpart F, a “significant financial interest” is a specific, defined threshold, not a vague standard: for a publicly traded entity, disclosure is triggered once remuneration in the prior twelve months plus equity value exceeds $5,000; for a non-publicly-traded entity, disclosure is triggered above that same $5,000 remuneration threshold, or if the investigator holds any equity interest at all, regardless of value.
Non-financial conflicts involve relationships or commitments that carry no direct monetary value but could still shape judgment: a close personal relationship or long-standing rivalry with another researcher, serving on an advocacy organization’s board with a stake in a particular finding, academic competition toward the same result, or a strongly held prior public position on the specific question under study. Journal peer review makes this distinction operational — the ICMJE’s Uniform Disclosure Form asks authors, reviewers, and editors to report both categories, and treats a relationship as disclosable if it is the kind a reasonable reader might think could have influenced the work, whether or not it actually did.
Not every relationship rises to a conflict. A researcher funded by a public agency or non-profit still discloses that funding source, but it is not usually treated as a conflict in the same sense as industry funding, because the distinguishing question is whether the funder has a stake in a particular result — a public funder typically does not, even though the funding relationship itself is still reported. See CASRAI’s conflict of interest disclosure entry and Conflict of Interest Disclosure in Scholarly Publication guide for how this distinction plays out specifically in journal submission.
Individual vs. institutional conflicts of interest
Most COI policy and popular usage focuses on the individual researcher, but research-integrity frameworks separately recognize an institutional conflict of interest (ICOI): a situation where the institution itself — or a senior official acting within their institutional authority — holds a financial interest that could unduly affect, or appear to affect, the institution’s own decisions about research it is supposed to oversee impartially. The distinction matters because an individual COI management plan (recusing one investigator, for example) does not resolve an institutional one, and vice versa.
The Institute of Medicine’s (National Academies) 2009 consensus report, Conflict of Interest in Medical Research, Education, and Practice, frames institutional conflicts as arising from two related sources: the institution’s own financial interests (equity or patent positions in a company sponsoring research at that institution, licensing revenue tied to a discovery under study, or company gifts and endowed positions), and the personal financial interests of senior officials — a department chair, dean, or technology-transfer officer — whose institutional authority over hiring, lab space, purchasing, or contract approval could be shaped by their own outside stake. A commonly cited example of the first kind: a university’s technology-transfer office holds equity in a spinout company it licensed university-owned IP to, and that same office is later asked to review a sponsored-research agreement between the spinout and a university faculty lab — the conflict belongs to the institution, not to any single investigator, because it is the institution’s own equity stake creating the risk of undue influence over how it administers that agreement.
Because an institution cannot police a conflict that is its own, institutional COI management typically relies on independent, external review — an oversight body, a peer institution, or a designated compliance office with genuine separation from the interest in question — rather than the same in-house disclosure-and-recusal process used for individual investigators. AAU and AAMC’s joint reports on managing institutional conflicts (following the 2001 AAMC report and later joint work) similarly recommend that institutions maintain a standing institutional COI committee, structurally separate from the office or individual whose interest is under review.
How conflicts of interest are managed: disclosure, review, management, elimination
Across funders, institutions, and journals, COI management follows the same broad hierarchy, even though the specific mechanics differ by context:
- Disclosure. The individual (or, for an institutional COI, the responsible official) reports the relevant interest to the appropriate body — the institution, the journal, or both. Under 42 CFR 50.604, PHS-funded investigators disclose at the time of proposal or award, at least annually thereafter, and within 30 days of acquiring a new significant financial interest.
- Institutional review. A designated official or committee — someone other than the discloser — evaluates whether the disclosed interest is actually related to the research and whether it rises to the level of a conflict. Under 42 CFR 50.605, this designated official must complete that determination, and any resulting management plan, before the institution expends any PHS award funds.
- Management plan. If a conflict is confirmed, the institution documents specific conditions to reduce or eliminate its risk. Per NIH’s Grants Policy Statement and FCOI guidance, common management-plan elements include public disclosure of the interest, independent monitoring of the research’s design, conduct, and reporting, modification of the research plan, disqualification of the investigator from the affected portion of the work, and divestiture of the financial interest.
- Elimination, in cases the management plan cannot adequately address. Where a conflict is too significant to manage in place, the available options escalate to severing the underlying relationship entirely, full divestiture, or removing the individual from the research altogether — the same outer bound recognized by NIH’s FCOI framework and by journal-side handling of an unmanageable reviewer or editor conflict (recusal from the manuscript).
Scholarly publishing runs a parallel but distinct version of the same hierarchy: authors, reviewers, and editors disclose at submission (or upon invitation to review or handle a manuscript); the handling editor evaluates whether a disclosed relationship warrants action; management usually takes the form of published disclosure alongside the article rather than a formal written plan; and the “elimination” step is recusal — a conflicted reviewer or editor steps aside from that manuscript entirely. Per ICMJE’s recommendations, a purposeful failure to disclose a relationship the journal’s form specifically asks about is treated as a form of misconduct in its own right, independent of whether the underlying relationship affected the research. CASRAI’s Conflict of Interest Disclosure Form guide covers the institutional-governance version of this process in more detail, and the Conflict of Interest Disclosure in Scholarly Publication guide covers the journal-submission version.
Frequently asked questions
Is a conflict of interest the same thing as research misconduct?
No. Having a financial or personal interest that could bias a decision is common and, by itself, is not misconduct. What research-integrity frameworks and journals (per ICMJE) treat as a serious violation is the failure to disclose a conflict the applicable policy or form specifically asks about — the non-disclosure, not the underlying relationship.
Does every conflict of interest have to be eliminated?
No. Most confirmed conflicts are managed, not eliminated — disclosure, independent monitoring, or a modified research role are the more common outcomes. Elimination (recusal, divestiture, or severing the relationship) is reserved for conflicts a management plan cannot adequately address.
Can an institution have a conflict of interest even if no individual researcher does?
Yes. An institutional conflict of interest exists independently of any single investigator’s disclosures — it arises from the institution’s own financial stake (or a senior official’s stake exercised through institutional authority) in research the institution is supposed to oversee impartially. Resolving individual investigators’ conflicts does not resolve an unaddressed institutional one.
What’s the difference between “conflict of interest” and “conflict of interest disclosure”?
A conflict of interest is the underlying situation — the outside interest and the risk it creates. Disclosure is the first procedural step in managing it: the act of reporting that interest to the institution, funder, or journal. See CASRAI’s separate conflict of interest disclosure entry for the disclosure obligation itself.
References
- 42 CFR Part 50, Subpart F, “Promoting Objectivity in Research” (PHS financial conflict of interest regulations, 2011 revision)
- NIH Grants Policy Statement, Section 4.1.10, “Financial Conflict of Interest”; NIH FCOI policy guidance (grants.nih.gov/policy-and-compliance/policy-topics/fcoi)
- Institute of Medicine (National Academies), Conflict of Interest in Medical Research, Education, and Practice (2009)
- ICMJE, “Disclosure of Financial and Non-Financial Relationships and Activities, and Conflicts of Interest”
- Association of American Universities / Association of American Medical Colleges, joint reports on managing institutional financial conflicts of interest in human subjects research
Also known as
COI · competing interest · competing interests · conflicting interest
Machine-readable encodings
Use in your systems
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