Update: Transition from Warnings to Errors for NIH Common Forms Submissions Starting May 8, 2026
NIH Requiring Common Forms and SciENcv Certification Starting January 25, 2026, and
Research Security Training Certification Starting May 25, 2026
The NIH has issued Notice NOT-OD-26-018 and NOT-OD-26-017, announcing significant changes to disclosure and certification requirements for grant applications and progress reports.
Update: NIH Announces Enforcement Date of May 8, 2026 for Common Forms
Per NIH Notice NOT-OD-26-033, NIH has extended the leniency period for transitioning to the Common Forms for Biographical Sketch, Current and Pending (Other) Support, and the NIH Biographical Sketch Supplement.
Although Common Forms are required by policy as of January 25, 2026, NIH will allow continued used of the NIH Biosketch and Other Support format pages through May 7, 2026. During this leniency period, NIH submission systems will continue to issue warnings - but will not block submissions - for applications containing non-compliant Common Forms.
Beginning May 8, 2026, NIH will fully enforce Common Forms compliance:
- System warnings will convert to errors
- Applications not using compliant Common Forms will be blocked from submission
In addition, NIH has identified the following issues that will result in application rejection when enforcement begins:
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SciENcv Biosketches attached in Cayuse must not be flattened PDFs.
Biographical Sketches generated in SciENcv must retain their required structure; flattened PDF biosketches will be rejected by eRA Commons. -
All senior/key personnel must have an ORCID iD linked to their eRA Commons profile
prior to submission.
eRA Commons will reject an application if any senior/key person has not linked their ORCID iD to the Commons account. This linkage is separate from the use of SciENcv, only needs to be completed once, and must be in place before the application is submitted.
NIH encourages applicants to begin using the Common Forms as soon as possible to avoid submission delays. This enforcement timing is intended to provide applicants additional time to address errors prior to the May 25, 2026 standard receipt date for Cycle 2.
Common Form Implementation Begins January 25, 2026
Starting in January, and per NOT-OD-26-18, NIH and AHRQ will require:
- Common Forms for Biographical Sketch and Current and Pending (Other) Support.
- A new NIH Biographical Sketch Supplement.
These forms must be generated in SciENcv, and all senior/key personnel must:
- Link an ORCID iD to their eRA Commons account.
- Personally certify their forms in SciENcv.
- The SciENcv Biographical Sketch and Current and Pending (Other) Support documents require each individual to certify that the information provided is accurate, current, and complete.
- Certify they are not participating in a Malign Foreign Talent Recruitment Program
(MFTRP).
Malign Foreign Talent Recruitment Programs (MFTRP) CertificationIndividuals who are party to a Malign Foreign Talent Recruitment Program are not eligible to serve as a senior/key person on federal proposals. See University Policy R-7-200A: Prohibition of Participation in Malign Foreign Talent Recruitment Programs
- See also NIH disclosure requirements
Key Dates:
| Before January 24, 2026: | Continue using current NIH formats | |
| On/after January 25, 2026: | Use Common Forms and NIH Supplement |
Failure to use NIH's SciENcv format with updated signed certifications for all senior/key persons will result in the application being rejected or withdrawn for non-compliance.
Expanded Documentation Requirements
For Other Support submissions, senior/key personnel are required to provide copies of supporting documentation for certain foreign relationships and resources, including:
- Employment or appointment agreements with non-U.S. entities (e.g., contracts, letters of appointment).
- Contracts or sponsored agreements awarded to the foreign entity where the researcher is named as PI or holds another role.
- Agreements for in-kind support, such as:
- Access to lab space, facilities, or equipment.
- Provision of personnel or funding.
- Other resources supporting research activities, regardless of location.
NIH may request these documents during Just-In-Time (JIT) or post-award compliance checks.
Research Security Training Requirements Effective May 25, 2026
Starting in May, and per NIH Notice NOT-OD-26-17, all senior/key personnel listed on NIH proposals must complete a compliant research security training, such as rED 367 or the CITI module for research security, PRIOR to submission. Certification of completion is required at the time of proposal submission through the SciENcv Biographical Sketch.
This certification is provided separately for each individual designated as senior/key personnel on the proposal.
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- The SciENcv Biographical Sketch and Current and Pending (Other) Support documents require each individual to certify that the information provided is accurate, current, and complete, and that they have completed the requisite research security training during the last 12 months.
University of Utah Research Security Training
Before submitting proposals to NIH on or after January 25, researchers are required to take the course once in a 12-month period.
Even if you are not submitting an NIH proposal, we encourage researchers to complete this training. Other federal agencies such as NSF, DOE, and DOD have implemented similar requirements.
Register for the research security office
red 367 Research security training
Questions regarding research security training or foreign influence should be sent to the Research Security Office. General questions re: NIH submissions should be sent to your Sponsored Projects Officer. See also NIH NSPM-33 Common Form Disclosure Requirements.