TL;DR: On July 8, 2026, NSF published Dear Colleague Letter NSF 26-022, “Prohibition on Collaborations with Restricted Entities”, announcing that NSF award funds may not be used for research collaboration with entities appearing on any of seven federal restricted-party lists. NSF intends to implement the prohibition in Fiscal Year 2027, timed to the effective date of a separate, related OMB rulemaking. The letter does not name China or any other country — it works entirely by reference to existing federal lists, several of which are China-specific and several of which are not.
What NSF 26-022 actually says
NSF 26-022 states that “NSF appropriated funds shall not be used for grants, contracts, other transactions or other assistance to an organization if the purpose is to conduct research in collaboration with restricted entities,” and separately that “senior/key personnel are prohibited from collaborating with a restricted entity, or employee thereof, on research funded by their NSF award.” The letter’s own text implies the prohibition also reaches senior/key personnel who hold a position with, or receive research support from, a restricted entity, though NSF does not spell that out as a formal, itemized list of prohibited activities.
This is narrower and more mechanical than it may sound: NSF is not creating a new list of its own. It is cross-referencing seven restricted-party lists that already exist under other federal authorities, and prohibiting NSF-funded collaboration with any entity that appears on them.
Which restricted-party lists NSF 26-022 references
Per the DCL text, the prohibition draws on lists maintained by six different federal bodies:
- Department of War (the former Department of Defense, renamed in 2025) — entities identified under Sections 1260H and 1286 of successive National Defense Authorization Acts.
- Commerce Department, Bureau of Industry and Security (BIS) — the Entity List, the Military End-User (MEU) list, and the Denied Persons List.
- Treasury Department, Office of Foreign Assets Control (OFAC) — the Executive Order 14032 Annex and the Non-SDN Chinese Military-Industrial Complex Companies List.
- State Department — debarred parties and nonproliferation sanctions designations.
- Federal Communications Commission (FCC) — covered equipment and services designated under the Secure Networks Act.
- Department of Homeland Security (DHS) — the Uyghur Forced Labor Prevention Act (UFLPA) Entity List.
- Customs and Border Protection (CBP) — Withhold Release Orders and Findings.
This is a materially different, and broader, mechanism than a single “China list.” Two of the seven — the OFAC Non-SDN Chinese Military-Industrial Complex Companies List and the DHS UFLPA Entity List — are explicitly China-focused. The rest (BIS’s Entity List and Denied Persons List, State’s debarred-parties and nonproliferation designations, OFAC’s EO 14032 Annex, the FCC’s covered list, and CBP’s Withhold Release Orders) are country-agnostic and include entities tied to Russia, Iran, North Korea, and other jurisdictions alongside Chinese entities. The candidate framing of this as a “China collaboration ban” captures part of the practical effect — a large share of currently listed entities across these lists are Chinese universities, state-owned enterprises, and technology firms — but the DCL’s actual legal mechanism is list-based and country-neutral on its face.
What counts as “collaboration”
This is the area where NSF 26-022 is least precise, and institutions should not assume more clarity exists than NSF has actually published. The DCL does not enumerate specific activities (it does not, for example, separately address subawards, formal co-investigator agreements, personnel exchanges, or co-authorship as distinct categories). What the letter’s own language establishes is:
- NSF funds cannot support an award — grant, contract, cooperative agreement, or other transaction — where the underlying purpose is to conduct research in collaboration with a restricted entity.
- Senior/key personnel on an NSF award are individually prohibited from collaborating with a restricted entity or an employee of one, on the research funded by that award.
- The scope, on the DCL’s own wording, implicitly extends to a senior/key person holding a position with a restricted entity or receiving research support from one — not only to formal institution-to-institution partnerships.
Research offices should treat “collaboration” as intentionally broad until NSF issues implementing guidance with more precise definitions or examples (comparable to the FAQ NSF eventually published for Important Notice No. 149‘s research-security provisions). Until then, the safest reading covers subawards to and from restricted entities, formal collaboration agreements, and senior/key personnel with an appointment, consulting relationship, or funded role at a restricted entity.
Compliance mechanics: certification, not pre-clearance
NSF 26-022 states that, once effective, “organization Authorized Organizational Representatives (AORs) and senior/key personnel will be required to certify to this effect at the time of proposal submission.” NSF is also placing the burden of ongoing monitoring on the institution: “organizations will be responsible for ensuring that senior/key personnel are aware of and comply with this prohibition and for identifying and addressing prohibited activities before NSF funds are expended.” In practice, that means the compliance model mirrors NSF’s existing Malign Foreign Talent Recruitment Program (MFTRP) certifications under CHIPS Act Section 10632: certify at proposal submission, then remain responsible for identifying and remediating violations across the life of the award, rather than NSF pre-screening every senior/key person against every list before award.
Effective date: tied to a separate, still-pending rule
NSF’s own language is conditional rather than a fixed calendar date: NSF “intends to implement this prohibition in Fiscal Year 2027 along with the effective date of the Draft Guidance on Financial Assistance…or the effective date of Acquisition Policy issued by the Senior Procurement Executive.” That “Draft Guidance on Financial Assistance” reference points to the White House Office of Management and Budget’s May 2026 proposed government-wide rewrite of the Uniform Guidance (2 CFR 200) — covered in detail in CASRAI’s piece on OMB’s 2026 proposed rule and “covered foreign countries”. That means NSF 26-022’s actual effective date is not yet fixed independently of OMB’s separate rulemaking timeline; it will land in FY2027 once one of those two triggering actions is finalized, not on a specific date NSF has committed to today.
What NSF 26-022 does not say
To avoid overstating the DCL, it is worth being explicit about what is not yet addressed in the published text:
- No grandfathering language. The DCL does not state whether collaborations already underway when the prohibition takes effect must be wound down, can continue to a natural end point, or need a case-by-case waiver.
- No itemized activity list. As above, there is no enumerated list distinguishing, say, co-authorship of a paper from a funded subaward — both plausibly fall under “collaboration” as written, but NSF has not confirmed that reading.
- No waiver process described. Unlike the Confucius Institute funding bar under CHIPS Act Section 10339A, which has an explicit Director-level waiver pathway, NSF 26-022 as published does not describe an equivalent exception mechanism.
Institutions should watch for a follow-up implementation notice or FAQ, which is how NSF has handled comparable ambiguity in its other recent research-security actions.
How this fits with NSF’s other 2025-2026 research-security actions
NSF 26-022 is the latest in a run of NSF research-security measures rather than a standalone action. It sits alongside: the research-security training certification and Malign Foreign Talent Recruitment Program certifications formalized in NSF’s Important Notice No. 149; the Confucius Institute funding bar under CHIPS Act Section 10339A; and Foreign Financial Disclosure Reporting for gifts and contracts of $50,000 or more from countries of concern under CHIPS Act Section 10339B. It also runs in parallel with the government-wide, list-based approach research offices already track for export control purposes — see CASRAI’s guides on restricted party screening, OFAC’s embargoed countries list, and export control (EAR/ITAR) in international research collaboration. Institutions with a NSPM-33 research security program already built around restricted-party screening for export-control purposes will find NSF 26-022’s mechanism familiar in structure — it is a funding-eligibility prohibition layered on top of lists most research security offices already screen against, not a wholly new compliance regime.
What research offices should do now
- Confirm current restricted-party screening actually covers all seven referenced sources — not every institution’s existing screening tool checks the FCC covered-equipment list, CBP Withhold Release Orders, or OFAC’s EO 14032 Annex by default; those are less commonly screened than the BIS Entity List and OFAC SDN List.
- Inventory active international collaborations and subawards involving senior/key personnel, ahead of an effective date that is likely to land partway through FY2027 rather than at its start.
- Track the linked OMB rulemaking, since NSF has explicitly tied its own effective date to that rule’s finalization.
- Watch for an NSF implementation FAQ defining “collaboration” and addressing grandfathering, following the pattern set by Important Notice No. 149.
Frequently asked questions
Is NSF 26-022 specifically about China?
No, not as written. It cross-references seven federal restricted-party lists maintained by six agencies. Two of the seven (OFAC’s Non-SDN Chinese Military-Industrial Complex Companies List and DHS’s UFLPA Entity List) are China-specific; the others are country-agnostic and include Russian, Iranian, North Korean, and other listed entities. In practice, a large share of currently listed entities across these lists are Chinese, which is likely the source of the “China ban” framing, but the DCL’s legal mechanism does not name any country.
When does the prohibition take effect?
NSF states its intent to implement the prohibition in Fiscal Year 2027, tied to the effective date of either OMB’s pending Financial Assistance guidance or a related Acquisition Policy from the Senior Procurement Executive — not a fixed calendar date NSF has committed to independently.
Does this replace NSF’s existing Malign Foreign Talent Recruitment Program restrictions?
No. It is an additional, separate prohibition. The Malign Foreign Talent Recruitment Program restrictions under CHIPS Act Section 10632 continue to apply on their own terms; NSF 26-022 adds a distinct, list-based collaboration prohibition on top of them.
Does subawarding to a foreign university automatically trigger this prohibition?
Only if that university, or the specific personnel involved, appears on one of the seven referenced restricted-party lists. NSF 26-022 does not prohibit international subawards or collaboration generally — only collaboration with listed entities.
This page summarizes NSF Dear Colleague Letter 26-022 as published July 8, 2026. NSF has indicated further implementation guidance is likely before the prohibition’s Fiscal Year 2027 effective date; check NSF’s DCL page directly for updates.
