How to Prepare for NIH New Research Security Training Requirement Before the Next Solicitation Drops

Your TL;DR: NIH just announced that, beginning May 25, 2026, every senior and key personnel listed on NIH funding applications must certify they’ve completed Research Security Training (RST) within the year prior to submission. Institutions also must certify that their investigators are compliant.

This requirement flows from the CHIPS and Science Act of 2022 and will become a hard gate at application time starting in mid-2026. Preparing now — by selecting appropriate training, tracking personnel compliance, and integrating certification into institutional workflows — will prevent delays or disqualifications when the next NIH Notice of Funding Opportunity opens.

If you’re gearing up for NIH funding, there’s a compliance wave building on the horizon — not in the form of new scientific criteria, but training prerequisites that will soon be as fundamental as budgets and biosketches. With Notice NOT-OD-26-017, NIH has flagged a requirement that every senior and key personnel listed on an NIH application must certify completion of Research Security Training (RST) completed within 12 months of submission. This isn’t an optional add-on; it’s fast becoming a hard eligibility condition.

If it’s helpful, setting up your internal compliance plan now will mean you’re not scrambling the week before a due date.

What NIH Just Changed

NIH’s notice implements provisions of the CHIPS and Science Act of 2022, which directs federal research agencies to strengthen research security across the extramural portfolio. For NIH applicants, that means:

  • Who must train: Every senior/key person on an NIH application must complete compliant Research Security Training.
  • When the training must be completed: Within 12 months prior to the NIH application due date.
  • How NIH will document compliance: Each individual will certify completion in their SciENcv Biographical Sketch at submission.
  • Institutional responsibility: The Authorized Organization Representative (AOR) must also certify that all covered personnel have completed training via the signed face page of the application.
  • Effective date: Mandatory for applications with due dates on or after May 25, 2026.

Training may come from any program that covers topics such as cybersecurity, international collaboration and foreign interference, proper use of funds, and conflict of interest/commitment. NIH recognizes modules developed by NSF and partners, as well as condensed versions that meet federal standards.

Why This Matters for NIH Applicants

This is more than a checkbox. NIH’s RST requirement signals a broader shift in how federal agencies are treating research integrity and national security as core parts of grant compliance. For innovators, it carries several implications:

  1. Training Equals Eligibility: If a senior/key investigator on your proposal hasn’t completed a compliant RST within the last year, the application may not pass NIH’s compliance checks. This is no longer a post-award issue — it’s captured at submission.
  2. Institutional Certification Is a Hard Gate: Because the institution must certify compliance as part of submitting the application face page, non-compliance could delay or derail proposal submission altogether.
  3. Workflow Adjustments Are Critical: Research administrators will need to incorporate RST into pre-award checklists, track completion dates, and ensure SciENcv certifications are accurate and up-to-date. Manual workflows or a lack of tracking systems will create bottlenecks.

How NIH Applicants Can Prepare Before the Next NIH Solicitation

Here’s a preparation roadmap that turns policy into readiness:

  • Map Who Needs Training: Make a list of all senior/key personnel likely to be named on NIH proposals. This should include PIs, Co-PIs, senior scientists, and others NIH would consider key personnel. Get ahead by confirming their current RST status and recency.
  • Choose Your Training Program: Select training modules that meet NIH criteria. Many institutions adopt the NSF/NIH/DOE/DOD RST modules or the SECURE Center’s condensed training because they were designed to satisfy the CHIPS Act mandate.
  • Establish an Internal Tracking System: Whether via institutional LMS or research administration software, track: Training completed date, Expiration date (12 months), Certification status in SciENcv. This proactive tracking prevents lapses and ensures your team remains eligible for upcoming deadlines.
  • Train Administrators too: Don’t forget that your AORs and pre-award staff need to understand how NIH will collect and verify these certifications. Train them on SciENcv updates, certification language, and compliance flags to watch for.

NOT-OD-26-017 isn’t a sidebar; it’s a pivot in NIH compliance that elevates Research Security Training to a fundamental launch condition for NIH proposals due on or after May 25, 2026. Embedding RST into your grant readiness workflow now isn’t just smart — it’s essential for maintaining competitiveness and avoiding last-minute compliance gaps. If you’re deciding between options for building compliant training and tracking systems, early planning now reduces risk and saves time later.

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