Overview
The Department of Energy (DoE) published its final rule on Conflict of Interest and Conflict of Commitment Policy Requirements on July 16, 2026. This includes new requirements at proposal submission stage.
At proposal, all project participants (Covered Individuals) must complete disclosure and training that includes the following:
- Sponsor Specific Questionnaire (SSQ), which includes the annual FCOI/COCR training as part of SSQ disclosure form, go to START myDisclosures.
- Organizational Conflict of Interest and Conflict of Commitment in Research disclosure OCI/COC by completing a project specific questionnaire, go to https://go.illinois.edu/OCOICOCR.
- Research Security Training completed in the OVCRI Training Portal, go to https://go.illinois.edu/ResSecTraining.
Prior to award and as part of annual continuing review, the FCOI Checklist will be completed to verify that all project participants comply with the disclosure and training requirements as stated above.
This includes DoE-sponsored projects, along with its affiliates, such as National Laboratories.
All Department of Energy ORS Proposal Requirements:
1. Complete Research Security Training (RST)
The following (Covered Individuals) must complete Research Security Training (RST):
- Principal Investigators (PIs)
- Co-Principal Investigators (Co-PIs)
- Senior/Key Personnel
- Any other named personnel who participate in the purpose, design, conduct, or reporting of the research
- Named collaborators and consultants who participate in the purpose, design, conduct, or reporting of the research
For Subrecipient Personnel
Subrecipient organizations must document compliance with Research Security Training by doing one of the following:
- Providing certificates of completion;
- Including language in the Letter of Intent (LOI) indicating that RST will be completed;
- Indicating on the Illinois subrecipient form that the organization will manage its own RST requirements; or
- Completing the Documentation of Subrecipient Research Security Training Completion form:
https://go.illinois.edu/RSTSubrecipient
2. Complete the Organizational Conflict of Interest / Conflict of Commitment in Research (OCOI/COCR) Disclosure
DOE now requires disclosure of organizational conflicts of interest and conflicts of commitment in research at proposal stage.
Who Must Complete the Disclosure?
All Covered Individuals identified on the project must complete the OCOI/COCR Disclosure Form.
Covered Individuals include:
- PIs
- Co-PIs
- Senior/Key Personnel
- Any other individuals named in the proposal who participate in the purpose, design, conduct, or reporting of the research
How to Complete the OCOI/COCR Disclosure
Upon submission of the proposal transmittal to SPA, PIs, Co-PIs, and Senior/Key Personnel will receive an automated email with instructions for completing the disclosure.
Individuals who do not receive an automated email but are Covered Individuals should complete the disclosure form directly at: https://go.illinois.edu/OCOICOCR
Complete Early When Possible
If the project title and sponsor opportunity number are known before proposal transmittal submission, Covered Individuals are encouraged to complete the OCOI/COCR Disclosure as early as possible to help avoid proposal submission delays.
For Subrecipient Personnel
Similar to RST, subrecipient organizations can document compliance of OCOI/COCR by including language in the Letter of Intent that they have a compliant policy and Covered Individuals have completed disclosure requirements.
3. Complete Financial Conflict of Interest (FCOI) Training
DOE now requires Financial Conflict of Interest (FCOI) training to be completed every two years.
For DOE proposals, FCOI training must have been completed on or after August 19, 2026 and remain current throughout the proposal and award process.
If your training is not current, you must complete the required FCOI training before proposal submission.
Training status can be viewed in START myDisclosures.
For Subrecipient Personnel
If the subrecipient completes SPA’s Subrecipient Letter of Intent or Commitment Form and certifies compliance with FCOI rules and regulations (penultimate paragraph), no further action is necessary.
4. Complete the Sponsor Specific Questionnaire (SSQ)
All Covered Individuals must ensure that a Sponsor Specific Questionnaire (SSQ) is on file and has been completed within the previous 12 months.
If your SSQ is older than one year, you must submit a new questionnaire before the proposal can proceed.
SSQ records can be accessed through START myDisclosures.
For Subrecipient Personnel
If the subrecipient completes SPA’s Subrecipient Letter of Intent or Commitment Form and certifies compliance with FCOI rules and regulations (penultimate paragraph), no further action is necessary.
Summary Checklist for Covered Individuals
Before submission of a DOE or National Laboratory-sponsored proposal, please ensure that you have:
☐ Completed Research Security Training (RST)
☐ Completed the OCOI/COCR Disclosure Form
☐ Completed FCOI Training on or after August 17, 2026, and within the required two-year training period
☐ Completed a Sponsor Specific Questionnaire (SSQ) within the last 12 months
Failure to complete these requirements may delay proposal submission or award processing.