Notice: New DOE Conflict of Interest and Conflict of Commitment Rule – Effective August 17, 2026

Last month, the Department of Energy (DOE) issued updated regulations regarding conflicts of interest and conflicts of commitment. The new federal rule has a short implementation timeline and takes effect on August 17, 2026.

The full DOE policy may be found at the following link:

The Office of Research actively updating our campus policy and refreshing our electronic disclosure system (ORCOI) to align with these requirements. UCOP is working on training updates and revisions to the UC system policy.

Because the new rule expands what must be reviewed and when, this update directly impacts how and when covered individuals submit disclosures, especially prior to grant proposal submissions.

Key Changes

  1. Conflicts of Commitment Are Now Covered
    In addition to financial interests, disclosures now include outside professional commitments. This includes titled academic or professional positions with outside entities (such as visiting or honorary roles at foreign institutions), participation in foreign talent recruitment programs, and agreements with problematic data-sharing restrictions.
     
  2. 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.
     
  3. Disclosures Must Be Reviewed BEFORE Proposal Submission
    Due to the new reporting rule, the University is required to review all investigator disclosures prior to submitting a proposal to DOE. To prevent delays in submitting your grant applications, covered individuals with reportable interests will need to complete or update their ORCOI disclosures with sufficient lead time before the proposal deadline.

What You Need to Do

  • Planning a DOE Proposal Soon?
    If you or your key personnel are submitting a DOE proposal on or after August 17, please plan to log into ORCOI and complete your updated disclosure as early in the proposal preparation window as possible. Proposals cannot be submitted to DOE until required screening reviews are completed.
     
  • Watch for System Updates
    We will send a brief notification as soon as the updated DOE disclosure form is live in ORCOI.
     
  • Training
     UCOP is working on updating the Ethics and Compliance Briefing for Researchers training module within the campus Learning Center to cover the new DOE requirements.
     

DOE's 2021 interim COI Policy

In December 2021, the Department of Energy (DOE) published an interim Conflict of Interest Policy, modeled on the existing Public Health Service financial conflict of interest regulation. The disclosure requirements of this policy are effective as of June 18, 2022 and apply to new funding or proposals received or submitted as of that date. In cases where DOE modifies the terms and conditions of existing awards, the new disclosure will also apply.

Applicability

These conflict of interest requirements apply to Investigators participating in DOE-funded projects. Anyone meeting the definition below must be listed in the Key-Personnel section of ORBiT for the relevant proposals or awards.

Investigator means the principal investigator (PI) and any other person, regardless of title or position, who is responsible for the purpose, design, conduct, or reporting of a project funded by DOE or proposed for funding by DOE. 

Training

Investigators must complete conflict of interest training prior to engaging in new or continuing awards. The mandatory University of California - Ethics Briefing for Researchers is being updated to satisfy this training requirement. For compliance with DOE requirements, training must be completed every four years.

Initial Disclosure

Investigators must disclose all Significant Financial Interests that relate to their Institutional Responsibilities. It is important to note that this process differs from NSF's policy, where the Investigator is only required to disclose Significant Financial Interests that relate to their NSF-funded projects. The DOE policy requires that Investigators broadly disclose and that the institution determine whether each reported financial interest is related to the DOE-funded project. The definition of a Significant Financial Interest can be found in UCSB's campus policy.

Disclosures must be filed annually for each Investigator proposing or receiving DOE funding. Investigators will be notified by email if they are required to submit an annual disclosure through our electronic disclosure submission system (ORCOI).

PIs are expected to notify our office if a new Investigator will be added to the project. Any new Investigator is required to submit a disclosure prior to beginning participation in the DOE-funded project. The PI may notify our office by emailing coi@research.ucsb.edu

Updating Disclosures

Investigators are required to update their annual disclosure within 30 days of acquiring or discovering a new significant financial interest. Similarly, you must notify the COI office if you have reduced or eliminated a previously reported significant financial interest that is subject to management conditions. 

Sponsored or Reimbursed Travel

DOE-funded Investigators are required to disclose sponsored or reimbursed travel that is related to their institutional responsibilities. Reimbursed travel involves instances where the Investigator is directly reimbursed by a non-UCSB entity for the Investigator’s travel expenses. Sponsored travel involves situations where an Investigator’s travel is paid directly by the external sponsoring entity and is not reimbursed to the Investigator.

There are a number of exceptions to the travel disclosure requirement. Please note, the following exceptions do not apply to foreign travel. You are not required to disclose travel that is reimbursed or sponsored by a domestic:

  1. Federal, state, or local government agency;
  2. institution of higher education as defined at 20 U.S.C. 1001 (a);
  3. academic or teaching hospital;
  4. medical center; or
  5. research institution that is affiliated with an institution of higher education.

 

 

Differences from PHS Requirements

While the DOE interim COI Policy is modeled after the PHS COI requirements, there are several differences between the two sets of requirements. Investigators that receive funding from both a PHS-agency and DOE should be aware of the following differences. This is not a comprehensive list of differences, and is limited to differences that are most relevant to Investigators.  Note: Since the DOE interim COI Policy is not final, these differences are subject to change.

  1. Certification statement: Investigators must certify that each disclosure is true, complete, and accurate. DOE requires that specific certification language be used, which has been incorporated into our electronic disclosure form.
     
  2. Investigator definition: The DOE definition of Investigator includes anyone responsible for the purpose, design, conduct, or reporting of the DOE-funded research. The term “purpose” is not included in the corresponding PHS definition. Clarification from DOE indicates that the term “purpose” is intended to apply to businesses receiving DOE funding and is unlikely to apply in the university context. 

    Additionally, DOE program offices are permitted to expand the definition of Investigator to include persons who merely participate in a project, rather than those with a responsibility for the design, conduct, or reporting of a DOE-funded project. It is not anticipated that program offices will apply the expanded definition to basic research projects.
     
  3. Sponsored or reimbursed travel: While NIH allows for a $5,000 threshold for the reporting of sponsored or reimbursed travel, the DOE interim COI Policy requires that travel be disclosed regardless of value. However, DOE does not require reporting of travel that was reported in the Investigator's Current and Pending or Other Support disclosures to DOE.

 

 

Policy and References