NASA Research Security Training (GIC 26-02)

NASA Research Security Training, issued as Grant Information Circular (GIC) 26-02 in February 2026, is NASA’s implementation of the government-wide push toward standardized research security training for federally funded researchers — the same policy family that produced NIH’s Research Security Training (RST) requirement under NOT-OD-26-017. GIC 26-02 requires ‘covered individuals’ named on NASA grants and cooperative agreements to certify completion of qualifying research security training, with the requirement taking effect for proposals and progress reports due on or after August 5, 2026. This page covers who is covered, what training satisfies the requirement, and how certification is documented; for the broader national-security policy framework this and NIH’s parallel requirement implement, see NSPM-33.

What GIC 26-02 requires

GIC 26-02 applies to NASA financial assistance awards — grants and cooperative agreements — rather than to NASA procurement contracts, which sit under separate acquisition-regulation coverage. It directs covered individuals to complete an approved research security training course and to certify that completion through NASA’s standard proposal and reporting documentation, rather than through a separate compliance filing. Reporting on this requirement, corroborated across several university sponsored-programs offices, situates it within the same statutory and policy lineage as NIH’s and NSF’s parallel research security training mandates: the National Security Presidential Memorandum 33 (NSPM-33) research-security disclosure and training standardization directive, and Section 10634 of the CHIPS and Science Act of 2022. Because GIC 26-02 is a narrow, fast-moving agency notice rather than a codified regulation, institutions should confirm current wording directly against NASA’s published circular before treating any secondary summary — including this one — as final.

Who counts as a “covered individual”

Under GIC 26-02, a covered individual is:

• Any Principal Investigator (PI) on a NASA-funded grant or cooperative agreement, regardless of level of effort;
• Any Co-PI, regardless of level of effort; and
• A Co-Investigator (Co-I) only if proposing to commit 10% or more of their time in a given year to the NASA-funded award.

NASA funding organizations may designate additional personnel categories as covered individuals on a project-by-project basis; where that happens, the designation is stated explicitly in that opportunity’s Notice of Funding Opportunity (NOFO), so institutions should not assume the three categories above are exhaustive without checking the specific solicitation. A person who joins a NASA-funded project as a covered individual after an award has already been issued is still subject to the requirement: they must submit updated Biographical Sketch and Current and Pending (Other) Support forms and attest to having completed the training, even though they were not part of the original proposal.

Accepted training

Two training pathways are reported as satisfying GIC 26-02: the four online modules published on NSF’s Research Security Training website, or a condensed version of the same four modules offered through the SECURE Center (the NSF-funded Safeguarding the Entire Community of the U.S. Research Ecosystem center). Institutions with their own CITI Program or equivalent research-security training already in place should verify against NASA’s own published circular, rather than assume automatic equivalency, since GIC 26-02 names specific accepted providers rather than a generic training standard.

How certification works

NASA does not appear to require a separate standalone certificate or portal submission. Instead, covered individuals demonstrate completion through NASA’s existing proposal and reporting forms:

• An updated NASA Biographical Sketch, and
• An updated NASA Current and Pending (Other) Support form,

submitted with the proposal itself, or — for individuals already named on an active award — with an annual progress report due on or after August 5, 2026. This mirrors the certification mechanism NIH uses for its own Research Security Training requirement, though the two agencies’ covered-individual definitions and accepted-training lists are not identical, and institutions managing awards across both agencies should not assume one agency’s certification satisfies the other’s.

Effective date

GIC 26-02 takes effect August 5, 2026: covered individuals named on proposals submitted on or after that date, and on annual progress reports due on or after that date for already-active awards, must have their training certification in place. Sponsored-programs offices should treat any proposal deadline in the weeks immediately after August 5, 2026 as requiring the certification to already be resolved well before submission, not arranged at the last minute — training completion windows and internal routing/certification steps both take real lead time.

Scope limits and what remains unclear

Because GIC 26-02 is a recently issued agency circular rather than a codified federal regulation, several details reported by secondary sources — including whether NASA civil servants and NASA contractors (as distinct from grant/cooperative-agreement personnel) are exempt, and the precise statutory citation NASA relies on — are not yet independently confirmed here against the primary circular text with full certainty. Research administrators should verify current, binding wording directly against NASA’s published GIC 26-02 circular and their own NASA program officer or grants officer before finalizing institutional compliance procedures, particularly given how quickly agency-level research security guidance has been revised across NIH, NSF, and now NASA over 2025-2026.

How this differs from NIH’s and NSF’s requirements

NASA’s GIC 26-02, NIH’s NOT-OD-26-017 (see NIH Research Security Training), and NSF’s own research security training mandate all trace back to the same NSPM-33/CHIPS and Science Act policy lineage, but each agency has written its own covered-individual definition, accepted-training list, and certification mechanism. A researcher holding awards from more than one of these agencies should not assume that satisfying one agency’s requirement automatically satisfies another’s — each agency’s own current guidance controls for its own awards. See also NASA’s broader research security policy context and the JASON report on research security that helped shape this policy area nationally.

Frequently asked questions

Who is a “covered individual” under NASA GIC 26-02?

Any PI or Co-PI on a NASA grant or cooperative agreement at any level of effort, and any Co-Investigator proposing 10% or more annual effort on the award — plus any additional personnel categories a specific NASA funding organization names in its NOFO.

When does NASA’s research security training requirement take effect?

August 5, 2026, for proposals and annual progress reports due on or after that date.

What training satisfies NASA’s requirement?

Reported acceptable options are NSF’s four online Research Security Training modules or the SECURE Center’s condensed version of the same four modules; confirm current accepted providers against NASA’s published circular.

Does GIC 26-02 apply to NASA contracts, or only grants?

It applies to NASA financial assistance awards — grants and cooperative agreements — not to procurement contracts, which are governed separately.

How is completion certified on a NASA proposal?

Through updated NASA Biographical Sketch and Current and Pending (Other) Support forms submitted with the proposal or progress report, rather than a separate certificate.