The U.S. Department of Energy (DOE) has revised its financial conflict of interest requirements, effective August 17, 2026.
Under the proposed reporting requirements, individuals who would qualify as “covered individuals” on a funding opportunity will be required at proposal to identify any actual, apparent or potential conflicts of interest (COI) or conflicts of commitment (COC) if the institution is awarded financial assistance under that opportunity. See 89 FR 51460 and 51467.
As a result of annual COI and COC reporting and periodic training, the DOE expects that individuals participating in an application for financial assistance will be able to readily ascertain whether an award would create an actual, apparent or potential COI or COC. DOE recognizes that changes may occur after application.
What does this mean for MU researchers?
- The university's Conflict of Interest office will need to conduct a review of DOE proposals before Sponsored Programs Administration submits them.
- This will require the principal investigator and research administration team to submit an Investigator Form including all covered individuals and Statement of Work in advance of the proposal deadline to allow time for review.
- More details will be available soon about this change in process.
It is crucial for the DOE to be aware of possible COIs and COCs that would arise under the award and that could or could not be mitigated. For example, identifying a COI or COC that can or cannot be mitigated for the covered individuals listed on an application affects DOE's evaluation of the personnel on a proposed project. Identifying such COIs and COCs as part of the application process will facilitate submission of applications that are more representative of a project if it is awarded.
Additionally, as part of DOE's ongoing research security responsibilities it is crucial to be aware of possible COIs and COCs involving any foreign governments, their instrumentalities or any other entities owned, funded or otherwise controlled by a foreign government, were DOE to award the applicant project. Identification of COIs and COCs that cannot be mitigated and COIs and COCs related to foreign governments at the application process reduces the likelihood of selected projects not proceeding to award because of such conflicts. DOE is adopting the reporting requirements applicable to applicants and recipients as proposed.
Read notice.