Scotland’s New Research Integrity Policy: What UK Institutions Must Do Before September 2026

• What the Scottish Funding Council’s new policy requires
• How it fits the UK-wide Concordat to Support Research Integrity
• Scotland versus the rest of the UK: a comparison
• What pre-award and research offices must change before September 2026
• Questions institutions are asking
• Implications beyond Scotland
• What to watch next

The Scottish Funding Council (SFC) approved a new research integrity policy in May 2026, and it takes effect on 1 September 2026 for every Scottish higher education institution that receives SFC research and innovation funding. The policy is not a rewrite of institutional codes of conduct — those remain the responsibility of individual universities — but it introduces a mandatory reporting relationship between institutions and their funder that did not previously exist in Scotland, and it gives research offices a firm compliance deadline to work against.

For pre-award, governance and research integrity teams, the practical question is not whether the policy is welcome — it broadly restates principles already embedded in the UK-wide Concordat to Support Research Integrity — but what operational changes are needed before the start date, and how Scotland’s approach compares with the mechanisms already in place across the rest of the UK.

What the Scottish Funding Council’s new policy requires

The SFC policy defines research integrity in terms consistent with UK Research and Innovation’s (UKRI) own framing: research that is trustworthy, ethical and responsible, guided by five principles — honesty, rigour, transparency and open communication, care and respect, and accountability. Those five principles mirror the commitments set out in the revised Concordat to Support Research Integrity, so institutions already aligned with the Concordat are not starting from zero.

The operative change is procedural. Under the new policy, institutions receiving SFC research and innovation funding must notify the Council of the outcome of any formal investigation into research misconduct, with a benchmark turnaround of no more than one month following the investigation’s conclusion. This is a step beyond the general expectation, long established through the Concordat, that funded organisations simply maintain “appropriate structures, policies and procedures” to support integrity — it creates a specific, time-bound reporting obligation tied to SFC funding.

Three scope points matter for compliance planning:

• The policy applies to Scottish higher education institutions that receive SFC research and innovation funding, and to research activity the Council funds directly.
• The SFC will not act as an appeals body for individual misconduct cases, will not support individuals through investigations, and will not grant ethical clearance for research projects — those functions stay with the institution and, where applicable, research ethics committees.
• The Council reserves the right to act where misconduct is reported, which may include action relating to individuals or a review of an institution’s own processes and systems — a lever that raises the stakes of a weak or slow internal investigation process.

How it fits the UK-wide Concordat to Support Research Integrity

The Scottish policy is explicitly framed as complementary to, not a replacement for, the Concordat to Support Research Integrity — the UK-wide framework signed by universities, funders and sector bodies and refreshed in April 2025. The revised Concordat broadened its recognition of contributors to research beyond principal investigators to include research-enabling staff such as technicians, data managers and research development professionals, and it updated its language on questionable research practices.

The UK Research Integrity Office (UKRIO) updated its own UKRIO Code of Practice for Research to Version 3.5 in July 2025 specifically to align with the revised Concordat, adding new guidance on the responsible use of AI and other emerging technologies in research, and deliberately softening language around misconduct procedures to reduce the stigma that UKRIO’s own 2024 research found was discouraging staff from reporting concerns. Scotland’s new policy sits on top of this existing architecture: it does not change what “good research conduct” means, but it changes who has to be told when conduct falls short, and how quickly.

Scotland versus the rest of the UK: a comparison

No other UK funding council currently mandates misconduct-outcome reporting on the same timetable as the SFC. The table below sets out how the main frameworks compare for a Scottish, UK-wide and cross-border institution.

The practical effect for cross-border institutions — a Scottish university with UKRI grants, for example, or a UK-wide research group with a Scottish node — is that the SFC clock now runs in parallel with, not instead of, existing UKRI grant conditions and Concordat commitments. Research offices need a single misconduct-tracking process that can satisfy the tightest of the applicable deadlines, rather than separate parallel logs.

What pre-award and research offices must change before September 2026

With roughly two months between SFC approval and the effective date, research integrity and governance teams have a narrow window to close gaps. The priority actions are:

• Map the reporting chain. Confirm who in the institution is authorised to notify the SFC of an investigation outcome, and build the one-month clock into the misconduct investigation procedure itself, not as an afterthought once a case closes.
• Audit investigation timelines. If current misconduct procedures routinely run beyond a month from conclusion to formal sign-off, the reporting deadline effectively compresses the institution’s own internal process.
• Update the annual statement on research integrity. Institutions already produce a Concordat-aligned annual statement; this is the natural place to reference the new SFC notification duty and evidence compliance.
• Brief research ethics committees and REI managers. The SFC has been explicit that it will not adjudicate individual cases or grant ethical approval, so institutions cannot rely on the Council to absorb any of that governance load.
• Cross-check against UKRI and other funder conditions. Where a case involves UKRI or other funding alongside SFC money, confirm which reporting obligation applies first and ensure both are met.

Questions institutions are asking

What is a research integrity policy?

A research integrity policy is an institutional or funder document setting out the standards of honesty, rigour, transparency, care and accountability expected in research, alongside the roles, training and procedures — including misconduct investigation — that put those standards into practice across the research lifecycle.

What is the Concordat to Support Research Integrity?

The Concordat to Support Research Integrity is a UK-wide sector agreement, signed by universities, funders and representative bodies, committing signatories to five shared responsibilities for maintaining rigour, transparency and accountability in research, most recently revised in April 2025.

Who investigates research misconduct in the UK?

Individual institutions investigate research misconduct allegations under their own procedures, informed by the UKRIO Code of Practice for Research; funders such as UKRI and, from September 2026, the SFC in Scotland, set reporting conditions but do not conduct the investigations themselves.

What happens if an institution breaches its research integrity policy?

Consequences depend on the framework: internally, breaches can trigger disciplinary action up to dismissal; externally, funders including the SFC can review an institution’s processes and systems, and in serious cases reconsider its funding relationship, though the SFC has stated it will not act as an appeals body.

Implications beyond Scotland

Scotland’s move is likely to be watched closely by the other UK nations’ funding bodies as a test case for whether time-bound, funder-mandated misconduct reporting improves transparency without overwhelming research offices. For institutions operating research programmes across borders — a common pattern for Russell Group and consortium-led projects — the immediate implication is administrative: misconduct-case tracking systems built around a single national timetable now need to accommodate a jurisdiction-specific clock for any Scottish-funded strand of work.

There is also a signalling effect for research culture more broadly. Mandatory outcome reporting, even where the funder is explicit that it will not re-adjudicate cases, tends to raise the internal profile of misconduct procedures and can influence how quickly institutions resource investigation teams. Given UKRIO’s own 2024 finding that fear of stigma was a barrier to reporting concerns, institutions would do well to pair procedural compliance with the destigmatising language changes UKRIO built into Version 3.5 of its Code, rather than treating the SFC deadline as a purely administrative exercise.

What to watch next

Three things are worth tracking as the September 2026 start date approaches: whether the SFC publishes supporting guidance or a template notification form ahead of the deadline; whether other UK funders signal an intention to introduce comparable time-bound reporting; and how the first wave of notified outcomes, likely to surface in aggregate through SFC or Universities Scotland reporting during 2027, shapes the sector’s view of whether mandatory reporting changes behaviour or simply changes paperwork. Research offices that treat the current window as a chance to audit and tighten investigation timelines — rather than a compliance box to tick in August — will be best placed regardless of how the policy evolves.