Compliance Timeline
Key deadlines and effective dates for federal research security requirements.
Anticipated / TBD
Dates not yet finalized
September 30, 2025
NIH
NIH anticipates implementing new foreign subaward structure
Updated NIH Policy on Foreign Subawards (NOT-OD-25-104)→Early 2026
Federal
Federal agencies anticipated to issue RSP requirements to awardee institutions
Final Guidelines for Research Security Programs at Covered Institutions→Past
Completed deadlines
May 1, 2025
DOE
PID requirement becomes mandatory for DoE financial assistance applications
DoE Financial Assistance Letter (FAL): Digital Persistent Identifier Requirements for Certain Individuals for Research and Development→May 1, 2025
DOE
DoE research security training requirement becomes mandatory
DoE Financial Assistance Letter (FAL): Research Security Training Requirements for all R&D Financial Assistance Awards→June 7, 2025
NSF
NSF begins rolling out annual MFTRP certification for PIs/co-PIs
NSF Important Notice No. 149→October 1, 2025
NIH
NIH Other Support disclosure training requirement takes effect
NIH Announces a New Policy Requirement to Train Senior/Key Personnel on Other Support Disclosure Requirements (NOT-OD-25-133)→October 24, 2025
NIH
NIH biospecimens security policy takes effect
NIH Policy on Enhancing Security Measures for Human Biospecimens (NOT-OD-25-160)→