On August 31, 2023, the National Aeronautics and Space Administration (NASA) published a new Conflict of Interest Policy. This policy is very similar to the existing National Science Foundation (NSF) requirements. NASA’s COI requirements are effective December 1, 2023 and apply to any proposals, awards, or amended awards as of that date.


These requirements apply to Investigators participating in NASA-funded projects. Anyone meeting the following definition must be identified by the PI and listed in the Key-Personnel section of ORBiT for the relevant project.

The term “Investigator” means the principal investigator, project director, and any other person, regardless of title or position, identified on the proposed project who is responsible for the design, conduct, or reporting of research funded or proposed for funding by NASA.


While the NASA policy does not include a training requirement, researchers are reminded that they are required to complete the UC system’s Ethics and Compliance Briefing for Researchers through the Learning Center, which must be done every other year. This training covers conflicts of interest in research.

Initial Disclosure

To satisfy this disclosure requirement, Investigators will be asked to disclose all Significant Financial Interests that relate to any of their proposed or funded NASA research projects. NASA-related disclosures will be made on our existing NSF disclosure form through our online system (ORCOI). If you have an active NSF disclosure on file, you will not be required to submit a duplicate disclosure. However, you are required to update your disclosure upon obtaining or learning about any new Significant Financial Interests.

Disclosures must be filed annually for each Investigator proposing or receiving NASA funding. Investigators will be notified by email if they are required to submit an annual disclosure through our electronic disclosure submission system (ORCOI). The questions on the disclosure form are designed to help you identify your personal financial interests that meet NASA’s definition of a significant financial interest.

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.