A conflict of interest (COI) disclosure form is the document an organization uses to collect, on a recurring basis, the outside financial interests, relationships, and positions held by the people who make or influence its decisions — board members, officers, and employees in a position to affect a contract, hire, grant, or purchase. It is the operational instrument of a conflict-of-interest policy; the policy sets the rule, the form is how the organization actually finds out who might be affected by it.
This guide covers two related but distinct instruments: the general institutional-governance disclosure form used by nonprofit boards and employers, and — in far more regulatory depth — the financial conflict of interest (FCOI) disclosure, threshold, and management-plan process federal research sponsors require of investigators. If you’re looking for the form journals require from manuscript authors before publication, see Conflict of Interest Disclosure in Scholarly Publication, which covers the ICMJE Disclosure Form and journal-submission requirements specifically.
What counts as a conflict of interest, for this form’s purposes
The governing definition most US nonprofits work from comes from the IRS’s own guidance on Form 990 (the annual information return tax-exempt organizations file) and Form 1023 (the application for 501(c)(3) recognition). Per the IRS, a conflict of interest arises when a person in a position of authority over the organization — an officer, director, or key employee — may benefit financially from a decision they could make in that capacity, including indirect benefit to a family member or a business with which they’re closely associated. That definition, or something close to it, is what most disclosure forms operationalize into specific questions.
See CASRAI’s dictionary definition of conflict of interest disclosure for the research-specific operational definition, and Conflict of Interest (COI) in Research for the broader concept this form operationalizes.
Why organizations require a disclosure form, not just a policy
A written policy states the principle; it doesn’t, by itself, tell the organization who actually has a conflict. That’s the specific gap the form closes:
- IRS Form 990, Part VI asks tax-exempt organizations whether they have a written conflict-of-interest policy, whether officers, directors, trustees, and key employees are required to disclose annually any interests that could give rise to conflicts, and whether the organization regularly monitors and enforces compliance. Adopting a policy and disclosure form isn’t legally mandatory for tax-exempt status, but the IRS attaches significance to how an organization answers these governance questions.
- IRS Form 1023 instructions include a sample conflict-of-interest policy as Appendix A, structured around exactly the two pieces covered in this guide: a policy describing how conflicts are identified and handled, and an annual disclosure statement each covered individual signs.
- Nonprofit governance practice — per guidance from BoardSource and the National Council of Nonprofits — treats an annual signed disclosure statement, refreshed whenever a new conflict arises, as standard practice.
Financial conflict of interest (FCOI) disclosure in federally funded research
A meaningful share of search demand for “conflict of interest disclosure form” and “financial conflict of interest research” reflects a narrower, federally regulated instrument: the disclosure investigators complete under the Public Health Service (PHS) financial conflict of interest regulations at 42 CFR Part 50, Subpart F (“Promoting Objectivity in Research”), which governs PHS grants and cooperative agreements — including all NIH-funded research — with a parallel rule, 45 CFR Part 94, governing PHS contracts. Both require an institution receiving PHS funding to maintain a written FCOI policy and to collect a disclosure from every “Investigator” on the award, defined broadly as anyone responsible for the design, conduct, or reporting of the research, not just the PI — co-investigators, collaborators, and senior/key personnel are all in scope.
The significant financial interest (SFI) threshold — the number readers come here for
Per 42 CFR 50.603, an Investigator (and their spouse and dependent children) has a significant financial interest requiring disclosure when:
- Publicly traded entity: the value of any remuneration received from the entity in the twelve months preceding the disclosure, plus the value of any equity interest in the entity as of the date of disclosure, aggregated together, exceeds $5,000. Remuneration includes salary and any payment for services not otherwise identified as salary — consulting fees, honoraria, paid authorship. Equity interest includes stock, stock options, or other ownership interest.
- Non-publicly traded entity: remuneration received in the prior twelve months exceeds $5,000, or the Investigator holds any equity interest at all, regardless of value — there is no dollar floor for equity in a private company.
- Intellectual property: any income received from IP rights and interests (patents, copyrights) related to the PHS-funded research.
- Reimbursed or sponsored travel connected to the Investigator’s institutional responsibilities must also be disclosed (purpose, sponsor/organizer, destination, duration) — except travel reimbursed or sponsored by a federal, state, or local government agency, or by a US institution of higher education, academic teaching hospital, medical center, or affiliated research institute, which is specifically excluded from this disclosure requirement.
This $5,000 figure is a different number from the $1,000,000 Single Audit expenditure threshold and the federal $10,000 equipment-capitalization threshold used elsewhere in grants administration — don’t conflate them when citing dollar figures.
What is explicitly excluded from “significant financial interest”
42 CFR 50.603 carves out several categories that do not count as an SFI, even though they involve money changing hands. Readers researching whether a specific interest needs disclosing most often need this list, not the threshold itself:
- Salary, royalties, or other remuneration paid by the Investigator’s own institution — including intellectual property rights the Investigator has assigned to the institution and any agreement to share in royalties on those rights.
- Any ownership interest in the institution itself, if the institution is a commercial or for-profit organization (e.g., an Investigator who is also a part-owner of a for-profit research institute that employs them).
- Income from investment vehicles the Investigator doesn’t control — mutual funds, retirement accounts, and similar diversified vehicles, as long as the Investigator does not directly control the individual investment decisions made within them.
- Income from seminars, lectures, or teaching engagements sponsored by a federal, state, or local government agency, a US institution of higher education, an academic teaching hospital, a medical center, or a research institute affiliated with a university.
- Income from service on advisory committees or review panels for the same categories of government and non-profit academic/medical entities listed above.
The practical effect: a $2,000 honorarium for guest-lecturing at a state university, or income from a 403(b) mutual fund the Investigator doesn’t actively trade, is not an SFI no matter how large the balance grows — but a $2,000 consulting fee from a private biotech company is, once combined with any other remuneration or equity from that same company crosses the $5,000 line.
Worked example: an SFI that is an FCOI, and one that isn’t
The following is an illustrative composite, not an account of any real individual, institution, or investigation — constructed to show how the same dollar threshold plays out differently depending on relatedness to the funded research.
- Is an FCOI: An investigator on an NIH R01 studying a novel anticoagulant compound discloses $8,000 in consulting fees received in the past twelve months from the pharmaceutical company that manufactures a competing anticoagulant already on the market. The institution’s designated official reviews the disclosure, determines the interest is related to the PHS-funded research (the consulting company’s competing product is scientifically adjacent to the study’s subject matter), and determines it constitutes a financial conflict of interest. A management plan is required before any award funds can be spent.
- Is an SFI but not an FCOI: The same investigator also discloses $6,000 in board-membership compensation from a company that manufactures agricultural irrigation equipment — comfortably over the $5,000 SFI threshold, so it must be disclosed. But the designated official determines this interest has no reasonable relationship to the anticoagulant research; it is disclosed and on record, but it is not an FCOI, and no management plan is triggered for it.
- Is not an SFI at all: The investigator also reports $3,500 in royalty income the institution itself pays out under an existing technology-license agreement, plus $1,200 in honoraria for guest lectures at a public state university. Neither counts toward the SFI threshold — the first is institution-paid remuneration, the second is government/academic teaching income — so neither appears as a disclosable SFI in the first place.
This is the sequence every FCOI review follows: (1) is it an SFI at all, applying the threshold and exclusions above; (2) if so, is it related to the PHS-funded research; (3) if related, does it constitute a conflict. A large financial interest unrelated to the research is disclosed but not managed as an FCOI; a modest one directly tied to the research subject matter can still trigger a full management plan.
Disclosure timing
Per 42 CFR 50.604, Investigators must submit an FCOI disclosure at each of these points:
| Trigger | Deadline | Regulatory basis |
|---|---|---|
| Initial disclosure | At the time of proposal submission, and before the institution accepts a PHS award on the Investigator’s behalf | 42 CFR 50.604(c) |
| Ongoing/annual disclosure | At least annually for the life of the PHS-funded project, on the schedule the institution’s policy sets | 42 CFR 50.604(c) |
| New SFI discovered or acquired | Within 30 days of discovering or acquiring the interest (purchase, marriage, inheritance, new outside role, etc.) — cannot wait for the next annual cycle | 42 CFR 50.604(e) |
| FCOI training | Before engaging in PHS-funded research, then at least every four years, with immediate retraining if the institution’s FCOI policy changes substantively, a new investigator joins mid-project, or the institution finds an investigator out of compliance | 42 CFR 50.604(f) |
| Institutional review of a new/updated disclosure | Within 60 days of the institution becoming aware of a new or previously unreviewed SFI, including on an interim basis | 42 CFR 50.605(a)(2)-(3) |
How the institution determines whether an SFI is an FCOI
Per 42 CFR 50.605(a), before the institution spends any PHS award funds, its designated official(s) must: review every Investigator disclosure of significant financial interests; determine whether each SFI relates to the PHS-funded research; determine whether a financial conflict of interest actually exists; and, if it does, develop and implement a management plan. When a new SFI surfaces mid-project — a new investigator joins, or an existing one acquires a new interest — the same review must happen within 60 days, with interim management measures implemented while the full review is completed. If the institution discovers an SFI that was not timely disclosed or reviewed (including one missed by a subrecipient), it must also complete a retrospective review of whether the undisclosed conflict biased the research already conducted, and report any bias found to the PHS awarding component with a mitigation plan.
What a management plan actually contains
A management plan is not a form field — it’s a documented set of specific actions the institution commits to, matched to the nature of the conflict. 42 CFR 50.605(a)(1) lists the conditions or restrictions an institution may impose, including but not limited to:
- Public disclosure of the financial conflict of interest (for example, in presentations or publications arising from the research).
- For human subjects research specifically, disclosure of the FCOI directly to research participants.
- Appointment of an independent monitor with authority to protect the design, conduct, and reporting of the research from bias caused by the conflict.
- Modification of the research plan itself.
- Change of personnel or personnel responsibilities, or disqualification of the conflicted individual from all or part of the research.
- Reduction or elimination of the financial interest (for example, divestiture of the equity stake).
- Severance of the outside relationship that creates the conflict.
The institution monitors the Investigator’s compliance with the management plan on an ongoing basis until the PHS-funded project ends — a plan is not a one-time sign-off.
Public accessibility requirements
Before spending any award funds, the institution must ensure public accessibility — via a public website or a written response to any requester within five business days — of information about any SFI that meets three criteria simultaneously: it was disclosed and is still held by senior/key personnel; the institution determined it relates to the PHS-funded research; and the institution determined it constitutes a financial conflict of interest (42 CFR 50.605(a)(5)). In practice, most institutions default to maintaining a public FCOI web page rather than fielding individual written requests.
Reporting to the PHS awarding component
Before spending award funds, the institution must send the PHS awarding component (for NIH, this is the relevant Institute or Center) an FCOI report for any SFI it has determined to be conflicting, alongside confirmation that a management plan is in place (42 CFR 50.605(b)). If the institution eliminates the conflict before spending any funds, no FCOI report is required at all. Any conflict identified later in the project — a new investigator, a newly acquired interest — triggers a fresh FCOI report within 60 days. Annual FCOI reports continue for the life of the award wherever a managed conflict remains in place.
NIH vs. NSF: where the FCOI rules diverge
NIH-funded research (and PHS-funded research generally) follows 42 CFR Part 50 Subpart F exactly as described above. NSF-funded research follows a materially different framework, set out in PAPPG (Proposal & Award Policies & Procedures Guide) Chapter IX.A, and the differences matter for any investigator or research administrator who holds awards from both agencies:
- Dollar threshold: NSF’s significant financial interest threshold is $10,000 in aggregated salary/royalties/other payments over the prior twelve months, or an equity interest that both exceeds $10,000 in value and represents more than 5% ownership of a single entity — a materially higher bar than PHS’s flat $5,000, and one where NSF’s equity test requires both the dollar and percentage conditions to be met, unlike PHS’s dollar-only equity test for non-public entities.
- Who reviews it: PHS regulation is prescriptive down to the institutional process; NSF instead requires any recipient organization with more than 50 employees to maintain its own written, enforced conflict-of-interest policy meeting NSF’s minimum standard, and leaves more of the review-and-management mechanics to the institution.
- Reporting to the agency: this is the biggest practical difference. PHS/NIH requires the institution to proactively report every FCOI determination to the awarding component before spending funds. NSF does not require routine FCOI reporting to the agency at all — the institution manages, reduces, or eliminates conflicts internally, and only needs to keep NSF’s Office of the General Counsel informed if the institution finds it cannot satisfactorily manage a conflict, or if research will proceed without conditions being imposed despite an unresolved conflict.
- Disclosure updates: NSF requires disclosures at proposal submission and updates “either on an annual basis, or as new reportable significant financial interests are obtained” — functionally similar in practice to PHS’s annual-plus-30-day structure, though NSF’s own regulatory text does not specify a fixed 30-day window the way 42 CFR 50.604(e) does.
- Exclusions: NSF’s exclusion list closely mirrors PHS’s (institution-paid salary/royalties, income from public/nonprofit teaching or advisory-panel service) but also separately excludes any ownership interest in the recipient organization itself when that organization is an SBIR/STTR applicant — a carve-out specific to NSF’s small-business programs.
The practical takeaway for an investigator with both NIH and NSF funding: the same outside financial interest can be disclosable and manageable under one agency’s rules while falling under the other’s threshold entirely, and an institution’s single COI policy has to satisfy both regimes at once — which is why most research institutions write their FCOI policy to the stricter PHS $5,000 threshold across the board, rather than maintaining two parallel disclosure forms.
Core elements a disclosure form should include
Across the IRS Form 1023 sample, BoardSource’s sample policies, and the disclosure forms used by research institutions, the same structural elements recur. A well-built form includes:
- Identifying information — name, role, department or program area, and the disclosure period covered.
- Financial interests — ownership or investment interest in any entity that does business with, competes with, or seeks to do business with the organization.
- Compensation arrangements — any compensation, consulting fee, honorarium, or other payment received from an entity that transacts with the organization.
- Positions held elsewhere — directorships, officerships, trusteeships, or employment at another organization that could compete with, supply, or benefit from decisions of the disclosing organization.
- Family and close-relationship interests — whether a family member or close personal relationship holds any of the above interests.
- Gifts, travel, and hospitality — anything of material value received from a party doing business with the organization, above whatever de minimis threshold the policy sets.
- A general/catch-all question — an open item asking whether any other situation exists that a reasonable person could view as a conflict.
- Certification and signature — a statement that the individual has read the policy, that the disclosures are complete and accurate, and a dated signature.
- An update trigger — language requiring disclosure of any new conflict as soon as it arises, not just at the next annual cycle.
Sample structure
The outline below reflects the common shape of the forms described above — not a reproduction of any single organization’s actual form, which you should adapt to your organization’s specific policy and legal counsel’s review before use.
- Header — organization name, form title (“Annual Conflict of Interest Disclosure Statement”), the disclosure year it covers.
- Instructions — a short paragraph defining what counts as an interest to disclose, and clarifying that disclosure does not automatically bar someone from serving; it triggers a review process.
- Part 1 — Identifying information — name, role, date.
- Part 2 — Disclosure questions — the financial interest, compensation, outside positions, family-relationship, and gifts/travel items above, each phrased as a yes/no question with a required explanation field if “yes.”
- Part 3 — General disclosure — the catch-all question.
- Part 4 — Certification — the acknowledgment-of-policy statement, signature, and date.
- Part 5 (internal use) — a section completed by the board chair, compliance officer, or COI committee documenting how a disclosed conflict was reviewed and what management action, if any, was taken.
Board member forms vs. employee forms
The core structure above is shared, but what the form actually needs to surface differs by role:
- Board member disclosure forms focus on governance-level decisions: related-party transactions the board itself will vote on, other board or advisory-committee memberships, and any financial relationship with the organization beyond standard board compensation.
- Employee disclosure forms focus on operational decisions: relationships with vendors the employee influences selecting, outside employment or consulting that could compete for the employee’s time, and hiring or supervisory relationships involving family members.
Per BoardSource’s governance guidance, when a director discloses a conflict, standard practice is that the director notifies the board chair in writing and is excused from the room during deliberation and voting — not merely asked to abstain while remaining present. Employee-level conflicts are more often managed through a documented mitigation plan than a formal recusal-from-a-vote process.
What happens after someone discloses
Disclosure is the first step of a process, not the end of one. A disclosed interest is typically reviewed by the board chair, a designated compliance officer, or (in research institutions) a standing conflict-of-interest committee, which determines whether the interest is material and, if so, how it will be managed — commonly through recusal, additional independent review, or, in rarer cases, a determination that the individual cannot participate in a broader area of the organization’s work. A disclosed and properly managed conflict is normal and expected. The failure mode governance frameworks are designed to catch is an undisclosed conflict discovered after the fact, which is treated far more seriously — up to referral for institutional review (see CASRAI’s research misconduct definition for how undisclosed conflicts intersect with broader integrity findings).
How this differs from a journal-submission COI form
A search for “conflict of interest disclosure form” surfaces both an institutional-governance/FCOI form (covered here) and a manuscript-submission form. They differ in every practical respect:
- Who completes it: governance/FCOI forms are completed by investigators, board members, and employees about their own outside interests relative to the organization or the funded research; journal COI forms are completed by manuscript authors about interests relative to the specific paper being submitted.
- Who reviews it: governance/FCOI forms go to a designated institutional official, compliance officer, or COI committee; journal forms go to an editor and, on publication, become a public statement attached to the article.
- Consequence of non-disclosure: FCOI failures can trigger a retrospective bias review and agency reporting under federal regulation; undisclosed COI in a published paper is addressed through correction, expression of concern, or retraction under COPE’s guidelines.
See Conflict of Interest Disclosure in Scholarly Publication for the publishing-specific version of this process, and Faculty Conflict of Interest in Startups and Does My Stipend Count as a Conflict of Interest? for two common edge cases this framework applies to. For the broader taxonomy of COI types this financial-interest framework sits within, see Types of Conflict of Interest, and for training-cadence specifics see FCOI Training Frequency: The 4-Year PHS Rule.
Frequently asked questions
What is a conflict of interest disclosure form?
It’s the document an organization uses to collect outside financial interests, relationships, and positions from board members, officers, and employees (or, in research, from investigators), so the organization can identify and manage situations where personal interest could affect an institutional decision or the integrity of funded research.
How much money triggers a financial conflict of interest disclosure?
Under 42 CFR 50.603 (PHS/NIH), a significant financial interest in a publicly traded entity is triggered once combined remuneration (prior 12 months) and equity value exceed $5,000. For a non-publicly-traded entity, the threshold is $5,000 in remuneration, or any equity interest at all, regardless of value. NSF’s PAPPG uses a different, higher threshold: $10,000 in aggregated payments, or equity exceeding both $10,000 in value and 5% ownership of a single entity.
Is salary from my own university a significant financial interest?
No. 42 CFR 50.603 explicitly excludes salary, royalties, or other remuneration paid by the Investigator’s own institution, including IP rights already assigned to that institution, from the definition of a significant financial interest.
Do I have to disclose my mutual fund or retirement account?
Not if you don’t control the individual investment decisions within it. Income from mutual funds, retirement accounts, and similar diversified investment vehicles is excluded from the SFI definition specifically because the investigator has no direct control over what the fund holds.
What’s the difference between an FCOI report to the agency and a management plan?
A management plan is the institution’s internal set of actions (monitoring, modification of the research plan, disqualification, divestiture, etc.) to control a determined financial conflict of interest. An FCOI report is what the institution sends to the PHS awarding component confirming a conflict was found and that a management plan is in place — the report is the notification; the plan is the substance.
Is FCOI disclosure information public?
For any significant financial interest the institution has determined both relates to the PHS-funded research and constitutes a financial conflict of interest, 42 CFR 50.605(a)(5) requires the institution to make that information publicly accessible — via a website or within five business days of a written request — before spending any award funds.
Does NSF require the same FCOI reporting to the agency that NIH does?
No. NIH/PHS institutions must proactively report every determined FCOI to the awarding component before spending funds. NSF does not require routine agency reporting at all — conflicts are managed internally under the institution’s own policy, and NSF’s Office of the General Counsel only needs to be informed if a conflict can’t be satisfactorily managed.
Is there a standard conflict of interest disclosure form template or PDF?
There’s no single universal template. The most widely used nonprofit-governance starting point is the sample policy in Appendix A of the IRS Form 1023 instructions; BoardSource also publishes sample disclosure forms. For FCOI specifically, most research institutions build their own form directly from 42 CFR 50.603’s disclosure categories, customized to the institution’s own policy and reviewed by legal counsel or the sponsored-programs office.
What happens if an investigator doesn’t disclose a significant financial interest on time?
If the institution later discovers an SFI that wasn’t disclosed timely, 42 CFR 50.605(a)(3) requires it to implement a management plan going forward and, if the FCOI wasn’t identified or managed in a timely manner, complete a retrospective review of whether the research conducted before the conflict was managed was biased — and, if bias is found, notify the PHS awarding component and submit a mitigation report.
Last verified against 42 CFR Part 50 Subpart F (law.cornell.edu/eCFR) and NSF PAPPG 24-1, Chapter IX.A (nsf.gov) on 2026-08-16.
