This page provides guidance for researchers and department staff managing proposals, awards, and foreign disclosures funded by the U.S. Department of Energy (2 CFR Part 910, Subpart C). The Department of Energy made significant revisions to their policy in 2026.

What You Should Know At-a-Glance

Disclose Actual, Apparent, or Potential Conflicts:
Federal rules require reporting any outside relationship, financial interest, or sponsored travel that could even appear to influence your research or create competing loyalties. When in doubt regarding an outside commitment or trip, err on the side of overdisclosure. 

Non-Financial Commitments (COCs) Are Reportable: 
The DOE’s policy extends beyond financial interests. You must report non-financial Outside Professional Commitments, including foreign academic appointments, foreign talent program participation, and contracts with data-sharing restrictions. 
 

Strict 15-Day Update Window:
You are required to update your institutional disclosure within 15 calendar days of acquiring, discovering, or incurring any new actual, apparent, or potential COI or COC.



 

Who is a “Covered Individual”?

Under DOE regulations, the term "Covered Individual" is used to define who is subject to these regulations. You are required to submit a DOE disclosure in ORCOI if you meet any of the following criteria:

Project Leadership:
Named Principal Investigators (PI), Project Directors (PD), Co-PIs, Co-PDs, or Project Managers.

Functional Equivalents:
Any individual, regardless of title, who functionally performs as a PI, Co-PI, or Project Manager.

Key Personnel:
Anyone for whom a Biosketch, CV, or Current & Pending Support document is included in the proposal.

Understanding COI vs. COC Requirements

DOE regulations require oversight of both financial interests and non-financial commitments. Disclosure is required annually and must be updated within 15 days of identifying a new reportable interest. Below explains how the two types of conflicts differ:

Conflict of Interest (COI)

Definition:

Financial interests or relationships (domestic or foreign) that could directly and significantly affect the design, conduct, reporting, or funding of DOE research.

What Must Be Disclosed:

  • Remuneration > $5,000 in the past 12 months from an entity, public or private.
  • Any equity interest in non-publicly traded companies, or > $5,000 in a publicly traded company.
  • IP rights/royalties from non-UC entities.
  • Sponsored/reimbursed travel (see section below for details).
     

Conflict of Commitment (COC)

Definition:

Situations where outside professional commitments (paid or unpaid) conflict with time, effort, or obligations and could affect your DOE effort, institutional obligations, or involve research security concerns, such as external obligations to inappropriately share information or withhold required information from UCSB or the DOE.

What Must Be Disclosed:

  • Foreign government talent recruitment program participation.
  • Academic, professional, or honorary foreign appointments.
  • Outside employment or consulting creating time/effort overlaps.
  • External agreements with problematic data-withholding or improper sharing clauses.Personal contracts or agreements that restrict your right to publish your University research, or that require unauthorized sharing or withholding unpublished research data, proprietary information, or intellectual property.


Sponsored & Reimbursed Travel Rules

DOE requires reporting of sponsored or reimbursed travel, regardless of value.

Required Disclosure

  • Foreign: Travel paid for or reimbursed by any foreign entity (government, university, company, or non-profit), related to your institutional responsibilities, regardless of amount or purpose.
  • Domestic: Travel paid for or reimbursed by a domestic entity, regardless of amount, that overlaps with the scope of work, deliverables, or effort pledged to your DOE project.

Exempt from Disclosure

  • U.S. Federal, State, or local government agencies.
  • U.S. Institutions of Higher Education (universities).
  • U.S. Academic teaching hospitals or affiliated research institutes.

     

Two-Stage Review Process

Review is split into two operational stages to ensure proposal deadlines are met while maintaining full post-award compliance. Screening is required at proposal stage to meet DOE’s reporting requirements. The following actual, apparent, or potential COIs or COCs must be identified and explicitly disclosed within the proposal submission, along with any measures taken to eliminate, reduce, or manage the conflict:

  • Conflicts that cannot be eliminated or appropriately managed or reduced in accordance with our campus policy.
  • Conflicts involving any foreign governments, their instrumentalities, or any other entities owned, funded, or otherwise controlled by a foreign government

Stage 1:

Proposal Submission Phase

Disclosures are screened at proposal routing to identify Foreign Government-Related Conflicts or Unmanageable Conflicts. Proposals and associated disclosures should be submitted internally at least 7 business days prior to the sponsor deadline to allow time for pre-submission screening.

Key Outcome: Required foreign conflicts are disclosed directly in the proposal application package to DOE.

Stage 2:

Award Setup and Ongoing Phase

Upon notice of award or when a new Covered Individual is added to the project, COCs are administratively cleared and COIs are reviewed by the COI Committee to determine whether formal management is needed to mitigate a potential, actual, or apparent conflict.

Key Outcome: Sponsored Projects holds spending account setup until all reviews are completed and any Management Plans are signed.
 

Administrator Resources

Proposal Preparation Guide

  1. Covered Individual Identification: Cross-reference the PI and Key Personnel listed in ORBiT against the individuals submitting Biosketches and Current & Pending forms in the proposal before routing.
  2. Subrecipients: Verify that subrecipients certify to having a compliant policy prior to proposal submission and have identified any reportable conflicts. Notify the COI office and SPO officer if a subrecipient notifies you about a conflict that must be reported to DOE.
  3. Training Verification: The required annual Research Security Training fulfills DOE’s training requirement. Covered Individuals are also required to complete the mandatory UC Ethics and Compliance Briefing for Researchers every 2 years. The ORBiT record will indicate if an individual’s training needs to be completed. Covered Individuals are automatically notified when training is needed.

Background and Regulatory Changes

The Department of Energy (DOE) issued updated regulations regarding conflicts of interest and conflicts of commitment on July 17, 2026 and took effect on August 17, 2026.

The new rule expands what must be reviewed and when, and directly impacts how and when Covered Individuals submit disclosures, especially prior to grant proposal submissions.

Key Changes

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.

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 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 (7 days) before the sponsor deadline.

Policy and References