NSF guidance on Collaborations with Restricted Entities
Purpose. This guidance is intended as a quick reference for researchers regarding NSF's July 2026 Dear Colleague Letter (DCL) announcing a forthcoming prohibition on certain collaborations involving entities appearing on specified U.S. Government restricted-party lists. Researchers should consult their institution's research administration or export control office whenever questions arise.
1. Scope of the NSF Prohibition
The prohibition applies to entities appearing on one of U.S. Government restricted-party lists identified by NSF—not to institutions based solely on country of origin. Many listed entities are universities, research institutes, companies, laboratories, or their affiliates located in various countries worldwide. The lists are updated regularly, so researchers should not rely on prior knowledge or informal internet searches. Reach out to exportcontrol@rpi.edu to ensure you are adequately vetting all international collaborations.
2. Examples of well-known universities that appear on U.S. restricted-party lists
Researchers are sometimes surprised that internationally recognized universities appear on one or more of the referenced federal lists. Examples include:
- Harbin Institute of Technology (HIT)
- Harbin Engineering University
- Beihang University (Beijing University of Aeronautics and Astronautics)
- Northwestern Polytechnical University
- University of Electronic Science and Technology of China (UESTC)
- Sichuan University (certain listings/affiliated entities)
These examples are illustrative only and not a comprehensive list. Researchers should not assume that an institution is permissible simply because it is not listed above.
3. What does "collaborate" generally mean?
Although NSF has not yet published exhaustive examples, researchers should assume that a collaboration includes activities such as:
- Co-authoring manuscripts or conference papers arising from NSF-funded research with researchers employed by, appointed at, or representing a restricted entity.
- Conducting joint NSF-funded research projects or sharing research responsibilities.
- Serving as co-investigators, subawardees, or formal research partners.
- Sharing NSF-funded research data, materials, software, or unpublished results as part of a joint research effort.
- Participating in formal research activities where investigators represent a restricted entity as collaborators.
Researchers should also remember that the DCL separately prohibits senior/key personnel from holding appointments or positions with, or receiving research support from restricted entities while participating on an NSF award. Any such appointments or support from outside sources must be disclosed in RPI’s annual conflict of interest cycle.
4. Publication acknowledgments
Publication questions are likely to require case-by-case review.
For example, if an NSF-funded publication includes co-authors whose institutional affiliation is a restricted entity, or if the publication acknowledges support involving such an entity, investigators should consult their institution before submission. Until NSF issues additional implementation guidance, investigators should not assume that longstanding publication practices remain permissible under the new policy.
When in doubt, ask first. Faculty should not be expected to independently review all twelve separate, frequently updated federal restricted-party lists referenced in the NSF DCL before every collaboration. If you are considering a new collaboration with an unfamiliar institution or have questions regarding an existing collaborator, contact RPI’s Research Security and Export Control Team for assistance. Consultation with RPI’s Research Security and Export Control Team is strongly encouraged before initiating or continuing any international collaborations. Please contact exportcontrol@rpi.edu with any questions.