DoD Component Decision Matrix: 2026 Foreign-Influence Risk Review

On March 9, 2026, the Department of Defense — now also operating under the name Department of War (DoW), a designation adopted by the department in 2025 that is used interchangeably with “DoD” in current official material — released an updated Component Decision Matrix to Inform Fundamental Research Proposal Mitigation Decisions. The document tells DoD/DoW components and program managers how to evaluate foreign-influence risk factors in fundamental research proposals before funding them, and it changed substantially from the version it replaced: the compiled “Prohibited Entity Lists” the matrix screens against grew from four government lists to thirteen, the number of possible mitigation outcomes was collapsed from five categories to three, and a new restriction bars using equipment sourced from prohibited-list entities on DoD/DoW-funded fundamental research projects. This guide explains what the matrix does, what changed in the 2026 revision, and what it means for institutions and investigators applying for or holding DoD/DoW fundamental research funding.

What the Component Decision Matrix Is For

Fundamental research — basic and applied research whose results are ordinarily intended for open publication, as distinct from research restricted for proprietary or national-security reasons under NSDD-189 — is not normally subject to export-control licensing. That does not mean DoD/DoW funders treat it as risk-free. Since fundamental research still trains graduate students, builds international co-authorship relationships, and can shape a foreign government’s access to expertise and know-how even without a controlled export occurring, DoD/DoW components have built a separate screening layer aimed specifically at foreign-influence risk: who is on the proposal, who has funded or employed them, and which entities they are affiliated or publishing with.

The Component Decision Matrix is the standardized tool that layer runs on. Program managers and component research-security staff use it when reviewing fundamental research proposals — whether submitted through a Broad Agency Announcement, grant, or cooperative agreement — to decide whether a proposal can proceed as submitted, needs a mitigation plan before award, or is prohibited outright because of a disqualifying risk factor. It is reviewed and reissued periodically; the current version is the 2026 DoW Component Decision Matrix, succeeding a 2025 edition.

What Changed in the 2026 Revision

According to university research-security offices that track the matrix closely for their own DoD/DoW-funded investigators, the 2026 release (effective within 60 days of its March 9, 2026 publication date) made more substantial changes than prior annual revisions:

• Prohibited Entity Lists expanded from four to thirteen. The matrix compiles multiple separate US government lists — covering different categories of export-control, sanctions, and national-security risk — into one reference set that reviewers check proposal personnel and collaborators against. The 2026 version increased that compiled set from four component lists to thirteen, substantially widening the population of entities and affiliations that can trigger a mitigation requirement or prohibition. The current compiled list is set out directly in the matrix document itself rather than in secondary summaries; institutions should consult the current matrix, not a description of it, before making a proposal-level determination, since the underlying component lists can also change independently of the matrix’s own revision cycle.
• Mitigation outcomes reduced from five categories to three. Earlier versions of the matrix sorted findings into five graduated categories; the 2026 version simplifies this to three: the factor is prohibited outright, the factor requires a mitigation plan before or during award, or the factor requires no mitigation.
• A new equipment-sourcing restriction. The 2026 matrix explicitly bars using equipment sourced from an entity on the Prohibited Entity Lists on a DoD/DoW-funded fundamental research project — a project-level procurement requirement that did not appear as a distinct matrix factor in the prior version.
• A longer co-authorship lookback. Co-authorship with an individual affiliated with a Prohibited Entity List organization within the preceding five years now triggers a mitigation requirement, broadening the affiliation-and-collaboration factor beyond current affiliations alone.

The Four Risk Factor Categories

Across both the 2025 and 2026 versions, the matrix organizes its screening around four recurring risk factors, applied to each proposal’s Covered Individuals — generally, senior/key personnel:

1. Malign Foreign Talent Recruitment Program (MFTRP) participation. A Covered Individual currently participating in a program that meets the statutory MFTRP definition is prohibited from receiving DoD/DoW funding outright — this factor allows no mitigation path. See CASRAI’s guide to the Malign Foreign Talent Recruitment Program for the full statutory test and certification requirements shared across federal funders.
2. Funding from a Foreign Country of Concern (FCOC). If a Covered Individual received funding, within the preceding five years, from an FCOC — defined consistently with other federal research-security rules as China (including Hong Kong and Macau), Russia, North Korea, and Iran — a mitigation plan is required before or during award.
3. Foreign-filed patents or patents naming prohibited-list individuals. Patent applications or issued patents filed outside the United States, or naming an individual on a Prohibited Entity List as an inventor or assignee, trigger review and, depending on severity, mitigation or prohibition.
4. Affiliation or co-authorship with a Prohibited Entity List organization or individual. Current affiliation with, or co-authorship (within the five-year lookback) involving, an entity or person on the compiled Prohibited Entity Lists requires mitigation; some affiliations rise to the level of an outright prohibition depending on the specific list involved.

Mitigation Outcomes

Where a factor triggers a finding, the 2026 matrix sorts the outcome into one of three tiers:

• Prohibited. The proposal cannot proceed with that individual, affiliation, or arrangement in place — MFTRP participation is the clearest example, since the statute itself bars funding regardless of any proposed mitigation.
• Mitigation required. The proposal can proceed only with a component-approved mitigation plan in place, which can range from removing a specific individual from the funded effort to restricting a collaboration’s scope, adding independent verification of results, or ending a specific foreign appointment before award.
• No mitigation needed. The disclosed factor does not, on its own, present a risk the component needs to manage.

Institutions should expect DoD/DoW program offices to mandate annual participant verification and risk-based reviews under the matrix, consistent with how the broader federal research-security framework already operates for continuing awards.

What This Means for Institutions and Investigators

• Screen senior/key personnel and named collaborators against the current compiled Prohibited Entity Lists before submitting a DoD/DoW fundamental research proposal, not just at the point a program officer raises a question — the expanded 4-to-13 list scope means affiliations that cleared prior screening may not clear the 2026 matrix.
• Review the preceding five years of funding, co-authorship, and patent activity for every Covered Individual on the proposal, since both the FCOC-funding factor and the affiliation/co-authorship factor now look back that far.
• Confirm equipment provenance for instrumentation and components proposed for use on the funded project, given the new equipment-sourcing restriction.
• Route findings through the institution’s research-security or sponsored-programs office early so a mitigation plan, where one is available, can be negotiated with the DoD/DoW component before award rather than after a proposal is flagged.

How This Fits the Broader Federal Research-Security Landscape

The Component Decision Matrix is DoD/DoW’s own implementation of a broader federal push toward standardized foreign-influence screening that runs through NSPM-33 and the CHIPS and Science Act of 2022. Parallel mechanisms exist at other agencies covering overlapping but not identical ground — see CASRAI’s guides to NIH research security training requirements and NSF research security training requirements, and the DARPA Countering Foreign Influence Program, which runs its own senior/key-personnel risk rubric for DARPA proposals specifically rather than DoD/DoW fundamental research broadly. The FCOC definition and MFTRP prohibition the matrix relies on are the same statutory concepts underlying research-security rules at NSF, DOE, and NIH; for the history that shaped why this screening exists at all, see CASRAI’s guides to the Thousand Talents Program and US-China research collaboration concerns. For the funding landscape the matrix applies within, see CASRAI’s guide to DoD research funding: DARPA, ONR, AFOSR, and ARO.

Frequently Asked Questions

What is the DoD Component Decision Matrix?

It is a standardized tool DoD/DoW components and program managers use to screen fundamental research proposals for foreign-influence risk factors — malign foreign talent recruitment program participation, funding from a Foreign Country of Concern, foreign-filed patents, and affiliation or co-authorship with entities on compiled Prohibited Entity Lists — and to decide whether a proposal can proceed, needs a mitigation plan, or is prohibited.

When did the 2026 update take effect?

The 2026 matrix was released March 9, 2026, with changes taking effect within 60 days of that date.

How many Prohibited Entity Lists does the 2026 matrix include?

Thirteen compiled US government lists, up from four in the prior version — the largest single change in the 2026 revision. The specific component lists are set out in the matrix document itself rather than enumerated here, since they are subject to change independent of the matrix’s own revision cycle.

Does the matrix apply only to research classified or subject to export control?

No. It applies to fundamental research — research intended for open publication and not normally subject to export-control licensing under NSDD-189. The matrix is a foreign-influence and research-security screen layered on top of, not a substitute for, ordinary export-control review.

What is a Foreign Country of Concern under the matrix?

China (including Hong Kong and Macau), Russia, North Korea, and Iran — the same definition used consistently across other federal research-security rules tied to the CHIPS and Science Act of 2022.

Is the Department of War the same as the Department of Defense?

Yes, as used in current DoD/DoW documents, including this matrix. The department began also operating under the name Department of War in 2025, and the two names currently refer to the same department; the matrix and the university research-security offices that track it use “DoD” and “DoW” interchangeably.