The Department of War's list of foreign institutions and talent programs now decides what Defense money can fund. This page tracks the current version, what a listing triggers, how Congress may expand it, and how institutions are expected to screen against it.
The Department of War's yearly list of foreign institutions and talent programs that threaten U.S. research. 130 institutions in the current version.
Defense money can't fund fundamental research done in collaboration with a listed institution.
Screen researchers' ties and partners against the current list, and screen again each summer when a new version comes out.
The Section 1286 list is the Department of War's annual public list of foreign academic and research institutions, and foreign talent recruitment programs, that pose a threat to U.S. national security research. It comes from Section 1286 of the FY2019 NDAA, as amended. The current version, the FY25 list, names 130 institutions in China, Russia and Iran.
The FY25 lists, released July 23, 2026: 130 institutions (Table 1) and six named talent programs plus any program that meets the CHIPS and Science Act definition (Table 2).
Table 1: institutions in China, Russia and other countries with specified characteristics. Table 2: foreign talent recruitment programs that threaten national security interests.
FY2019 NDAA §1286(c)(9)–(10), as amended
The law requires the lists every year, published on a public website in a searchable format, and allows more frequent updates.
The list has been published every year since 2023, and each version has added institutions. The law behind it has changed more: it began in 2018 as an initiative with no list, added the institution list in 2019 and the talent program list in 2021, and since 2023 has been tied to Defense funding decisions.
| Version | Released | What changed |
|---|---|---|
| FY22 lists | June 29–30, 2023 | First public release, with the Department's “Countering Unwanted Foreign Influence in Department-Funded Research” policy and the first decision matrix. Table 2 named six talent programs plus a catch-all. |
| FY23 lists | July 2024 | Institutions added; the talent program table reaffirmed. |
| FY24 lists | About June 2025 | Institutions added; the talent program table reaffirmed. |
| FY25 lists (current) | July 23, 2026 | 130 institutions in China, Russia and Iran, with about 27 reported as new, including, for the first time, leading civilian Chinese universities. Talent program table reaffirmed. |
Release dates for FY23 and FY24 and the per-version counts before FY25 come from secondary sources and are approximate. The FY25 count is the Department's own.
Directs the Department to protect academic researchers from undue foreign influence: information sharing, training, and policies consistent with open fundamental research.
Academic institutions of China, Russia and other countries with a history of improper technology transfer or espionage, ties to military or intelligence services, or recruitment to transfer knowledge.
Adds the list of foreign talent programs and requires both lists to be published every year in a searchable format.
Policies to limit funding to institutions or researchers who knowingly contract with listed entities: a risk-based decision matrix, notice and 30 days to cure, appeals, disclosure, and annual certification.
Annual reviews of a sample of research grants, and no Defense funds for fundamental research in collaboration with a listed institution.
Section 1286 itself is unchanged; the collaboration ban now covers FY2026 funds.
A listing has teeth. Defense funds can't support fundamental research done in collaboration with a listed institution, the 2026 DoW decision matrix treats active ties as prohibited and recent ones as needing mitigation, a listed sponsor can make a talent program malign under the CHIPS and Science Act, and researchers must disclose every affiliation.
Or a talent program in its Table 2.
No fundamental research in collaboration with it.
Prohibited or mitigation, by how recent the tie is.
Its programs can be malign under the CHIPS Act.
And collaborating with its people is a compliance risk.
Defense funds may not go to a university to conduct fundamental research in collaboration with an institution on the most recent list, including its employees. “Collaboration” is broad: shared facilities or data, know-how, financial or in-kind contributions, sponsored fellowships or visas, joint ventures, and serving as a consultant, advisor or board member. Extended to FY2026 funds by FY2026 NDAA §215. Waivers are case by case.
P.L. 118-159 §238; P.L. 119-60 §215
The 1286 list is one of 13 federal lists in the matrix. Active collaboration with, or funding to or from, a listed entity is prohibited. Affiliations, co-author affiliations or co-patents with one in the past five years require mitigation. The matrix, explained →
2026 DoW Component Decision Matrix
A talent program sponsored by an institution on the list, or named in Table 2, meets the sponsor test for a malign foreign talent recruitment program, and the Act's protection for open international collaboration falls away when a listed institution funds or runs the activity. Talent programs, explained →
42 U.S.C. 19237(4)
The FY25 list's introduction says researchers must disclose all affiliations with listed entities and any talent program activity, and that collaborating with someone affiliated with a listed entity is a compliance risk. The Department's January 2026 memo requires full current and pending support reporting.
The Senate's FY2027 NDAA would move Section 1286 into Title 10, widen it from academic institutions to any entity, and automatically add every entity on eight other categories of federal lists. It would also bar covered institutions from certain contracts from 2028. As of October 15, 2026 none of this is law, and the House bill does not include it.
| Category | Lists that would flow in automatically (S. 4784 §220) |
|---|---|
| Commerce | Export control lists: the Entity List, Unverified List, Military End-User list and Denied Persons List. |
| Treasury | Sanctions: the Specially Designated Nationals list. |
| Defense | Chinese military companies under Section 1260H. |
| State | Parties debarred under the arms export rules. |
| Procurement bans | Telecommunications (FY2019 NDAA §889) and semiconductors (FY2023 NDAA §5949). |
| OMB | Biotechnology companies of concern under the BIOSECURE Act (FY2026 NDAA §851). |
| FCC | The Covered List of communications equipment and services. |
| Homeland Security | Forced labor (UFLPA) entity lists. |
The list leaves its NDAA note and becomes permanent Title 10 law, covering “entities” rather than only academic institutions.
Covered institutions could not hold certain contracts with covered nations or foreign entities of concern, with waivers. Chief Research Security Officers would be required.
Section 224 of the Senate bill would carry the §238 collaboration ban into fiscal year 2027.
The committee reported S. 4784 on June 15, 2026. The House passed its FY2027 NDAA (H.R. 8800) on July 22, 2026 without these provisions, and a Senate procedural vote failed on July 14. What survives conference is open.
Enforcement stepped up in 2026. A January memo ordered spot checks of Defense research awards, the March decision matrix widened the lists program officers check, and in August the Department of War ordered 30 academic institutions to audit their collaborations with listed and other foreign entities of concern within two weeks.
The Under Secretary of War for Research and Engineering ordered annual spot checks of every mitigated award and at least 25% of other awards, a Department-wide risk review repository, full current and pending support reporting, and nominations of new entities for the list.
“Fundamental Research Security Initiatives and Implementation”
Prohibited-entity lists grow from 4 to 13, and the look-back shortens to five years. Read the explainer →
The Department of War ordered 30 academic institutions to audit their academic, financial and research collaborations with foreign entities of concern, including institutions on the 1286 list and groups tied to rebranded Confucius Institutes; to assess exposure of sensitive and export-controlled research; and to adopt mitigation up to ending partnerships, by August 31. Future funding eligibility was tied to the response. The Department did not publish the institutions' names, and reported in September that all 30 responded.
Department of War release, August 17, 2026 · Inside Higher Ed, September 10, 2026
Screen every covered individual on a Defense proposal, and their affiliations, co-authors, co-patents and funders over the past five years, against the current list. Screen collaborators and partners directly, match institution names carefully, screen again when a new version is published, and document every decision.
Every covered individual, and through them their affiliations, co-authors' affiliations, co-patents and funders. The 2026 matrix looks back five years.
Visiting scholars, subawardees, consultants, sponsors of fellowships and visas, and the institutions behind shared facilities or data, because “collaboration” under §238 reaches all of them.
Listed institutions appear under English and transliterated names, abbreviations, and affiliated institutes grouped under a parent. A match needs the same institution, not a similar name, and every match should name the version of the list it came from.
A new version arrives each summer. A collaboration that was clean last year can be prohibited this year.
Table 2 names programs and adds any that meets the CHIPS and Science Act definition, so look for the arrangement, not only the name.
Disclosed, mitigated, ended, or no concern: write down what you found, what you decided, who approved it, and when. That is what an audit asks for.
We review this page whenever the Department of War publishes a new version of the list, Congress changes the statute, or the Department announces new enforcement, and at least once a month. Each change is dated here so you can tell whether what you read is current.
Short answers to the questions research security, sponsored programs and compliance offices ask most often about section 1286 list. Each answer is a summary for orientation; the statute, regulation or agency notice cited on this page has the final word.
The Department of War's annual public list of foreign institutions, and foreign talent recruitment programs, that threaten U.S. national security research, required by Section 1286 of the FY2019 NDAA as amended. Its formal title is the “Lists Published in Response to Section 1286.”
The FY25 lists, released July 23, 2026. Table 1 names 130 institutions in China, Russia and Iran; Table 2 names six talent programs plus any program that meets the CHIPS and Science Act definition.
Not on Defense-funded fundamental research. FY2025 NDAA §238, extended by FY2026 NDAA §215, bars Defense funds for fundamental research conducted in collaboration with a listed institution or its employees, with case-by-case waivers. Other funders apply their own rules.
Not by itself. The 2026 DoW decision matrix treats co-author affiliations with listed entities in the past five years as requiring mitigation, while active collaboration or funding is prohibited. Disclosure is required either way.
The law requires it every year and allows more frequent updates. Recent versions have appeared each summer.
The Department of War did not publish their names. Its August 17, 2026 order asked them to audit collaborations with foreign entities of concern by August 31, and it reported in September that all 30 responded.
Possibly. The Senate's FY2027 NDAA (S. 4784 §220) would widen it to any entity and automatically include entities on other federal lists. As of October 15, 2026 that provision is not law, and the House bill does not include it.
This page summarizes federal law and policy for orientation and is not legal advice. Your sponsored programs office and counsel have the final word on what your institution certifies and how it complies.
What the OMB list means for institutions: the designation pathways, the timeline, and the supplier audit.
Read the guide →What the Defense Department's list is, what a listing triggers, and how to screen collaborators against it.
Read the guide →Each agency's talent program certification side by side: effective date, notice, who certifies and how.
Read the guide →What to review before an audit, how to assess export-control exposure, and what a defensible mitigation plan holds.
Read the guide →What the CHIPS and Science Act forbids, what it protects, and where talent programs show up on the record.
Read the guide →The four factors Defense program officers weigh for fundamental research proposals, explained.
Read the guide →All guides → New to the terms? The research security glossary →
We'll show your office how SYSWERX screens researchers against government lists, names the list version behind each match, and keeps every decision in a documented case.