DoD Notice Names 30 Academic Institutions That Must Report By August 31

Thirty academic research institutions recently received formal notifications from the Department of Defense (DoD), requesting significant documentation regarding their academic, financial, and research ties to foreign entities of concern.

The DoD instructed institutions that, to maintain eligibility for future federal research funding, they must “complete a comprehensive audit of all identified foreign collaborations, assess the exposure of sensitive or export-controlled research, and implement strict mitigation plans, including the termination of problematic partnerships.” The institutions must report their findings and actions to the DoD by August 31, 2026.

Increased Focus on Foreign Influence in Higher Education

The August 17 notification requires the 30 institutions to provide substantial documentation regarding certain foreign relationships. This includes relationships with foreign entities identified under Section 1286 of the FY 2019 National Defense Authorization Act (NDAA) and organizations linked to Confucius Institutes, Chinese government-supported programs.

Federal concerns about foreign influence in academic research have been building for years. During the first Trump Administration, the Department of Justice’s China Initiative included investigations of academic researchers who allegedly failed to disclose Chinese affiliations in connection with federal grant applications. Although the Biden Administration later ended the formal initiative, federal concerns regarding foreign influence and research security continued.

That scrutiny has continued and expanded. Recent federal actions reflect a broader effort to address foreign involvement in federally funded research, including through enhanced research security requirements, restrictions on certain collaborations, and proposed changes to government-wide grant rules:

• In March 2026, DoD unveiled a new “Component Decision Matrix” to guide fundamental research proposal mitigation decisions, including verification that listed participants are not involved in “malign foreign talent recruitment programs.”
• Agencies such as the NIH and NSF are now requiring more stringent foreign disclosures, with the NSF publishing a “Dear Colleague Letter” in July 2026 notifying the research community that NSF funds for research collaborations are prohibited for entities on certain restricted-party lists.
• Proposed revisions to the Uniform Guidance (2 CFR Part 200) could fundamentally affect how research institutions collaborate with international entities. The proposed Section 200.220 would bar federal funding recipients from supporting bilateral and multilateral collaborations, agreements, programs or activities involving a “covered foreign country” or “covered foreign entity,” potentially extending federal scrutiny beyond relationships involving traditional “countries of concern.”
• The DoD has long been concerned about institutions engaging in activities with foreign countries of concern, which could threaten America’s national security and scientific integrity. On July 23, 2026, DoD identified 130 academic and research institutions located in China, Russia, and Iran and advised U.S. researchers to exercise “strict caution” when considering collaboration or data-sharing with institutions named on the list.

Next Steps For Research Institutions

The 30 institutions that received the DoD Notice must quickly work to gather responsive documents across many different departments. Grants and contracts offices, sponsored research programs, export control and cybersecurity personnel, and institutional research leadership should coordinate closely to identify responsive information and evaluate relevant policies, procedures, relationships, and activities.

Institutions also should examine individual faculty members’ relationships with foreign universities, research organizations, and governmental entities. This review should include not only formal agreements but also less formal arrangements through which faculty members may have received access to foreign research facilities, resources, funding, personnel, or other support. 

Legal counsel should be involved early in the process to assist with the scope and strategy of the response, evaluate potential legal and compliance issues, and preserve applicable privileges.

The implications extend beyond the 30 institutions that received the August 17 notice. Given the federal government’s continuing focus on research security and foreign influence, other colleges, universities, and research institutions should consider: 

• Conducting an internal assessment to determine the nature and extent of their foreign research ties; 
• Evaluating the legal, regulatory, funding, export control, and security risks associated with these relationships; and
• Determining whether it makes sense to maintain, restrict, or end the foreign collaboration altogether.

The DoD notice is another significant development in the federal government’s expanding scrutiny of foreign relationships involving U.S. research institutions. We do not expect audits, investigations, and enforcement efforts to stop with these 30 institutions. Colleges, universities, and other research organizations should expect foreign affiliations, research collaborations, and related disclosure obligations to remain an important area of federal oversight and enforcement.

Stay up to date on developments impacting higher education by joining Feldesman’s Higher Education Insights: Fall 2026 Update on Agency Priorities. Geared toward research institutions, colleges, and universities, this webinar will address new obligations and compliance requirements expected to affect institutions of higher education during the remainder of 2026.

Feldesman attorneys specializing in higher education and federal grants will continue to monitor federal audits, investigations, and enforcement activity affecting research institutions. If you have any questions about how these developments may affect your research institution, college or university, please contact Mindy Pava or Ted Waters.