Special COI and COC Requirements for DOE Researchers

On July 16, 2026, the Department of Energy (DOE) issued updated regulations regarding conflicts of interest (COI) and conflicts of commitment (COC) applicable to applicants and recipients of DOE awards. The new rule has a short implementation timeline and takes effect on August 17, 2026. 

The full DOE policy may be found here.

Key Changes

• Conflicts of Commitment Are Now Covered 

In addition to financial interests, disclosures now include outside professional commitments. Outside professional commitments include: (i) titled academic or professional positions/appointments with outside domestic or foreign entities (such as visiting or honorary roles, whether remuneration is paid), (ii) participation in foreign talent recruitment programs, and (iii) agreements with problematic data-sharing requirements or restrictions.  

• Mandatory Reporting of Foreign Government-Related Conflicts 

DOE now requires the University to identify and explicitly report any actual, potential, or apparent conflicts involving foreign governments, foreign state-owned entities, or foreign-funded programs directly within proposals submitted to DOE. 

• Disclosures Must Be Reviewed BEFORE Proposal Submission 

Due to the new reporting rule, the University (including offices beyond Sponsored Programs) is required to review all covered investigator disclosures prior to submitting a proposal to DOE.  

• COI/COC Requirements Apply to Subrecipients 

The University is working to understand the full policy and develop updated guidance for the research community. We will send a communication once that is finalized.  

In the interim, if you are planning to submit a DOE proposal on or after August 17, 2026, please reach out to Renna Lilly (rolilly@bu.edu) in Sponsored Programs and Sarah Porter (sbporter@bu.edu) in Research Compliance as soon as possible to discuss next steps.