Energy Department Tweaks Conflict Rules for Funding Recipients
Published Date: 7/16/2026
Rule
Summary
Starting August 17, 2026, the Department of Energy is updating its rules for anyone applying for or getting financial help from them. These new rules make sure folks spot and fix any conflicts of interest or commitment so everything stays fair and clear. If you’re a non-Federal group receiving DOE funds, get ready to follow these fresh disclosure and reporting steps—no surprises, just smooth sailing!
Analyzed Economic Effects
9 provisions identified: 1 benefits, 7 costs, 1 mixed.
Must Have Written COI/COC Policies
If you are a non-Federal organization applying for or receiving DOE financial assistance, you must establish and enforce a written conflict of interest (COI) and conflict of commitment (COC) policy covering actual, apparent, and potential conflicts (domestic and foreign) starting August 17, 2026.
New Disclosure and Reporting Deadlines
Applicants and recipients must disclose COIs and COCs as part of applications and must report any new COI or COC to DOE as soon as practicable but not later than 15 days after it arises; organizational conflicts of interest (OCIs) must be reported within 15 days of learning of them. This takes effect August 17, 2026.
Training and Annual Disclosure Rules
Covered individuals must complete COI/COC training before working on DOE-funded projects and refresher training at least every two years. Covered individuals must update disclosures annually and report new conflicts as soon as practicable but not later than 15 days after they arise. These rules take effect August 17, 2026.
Subrecipient Certification or Coverage Requirement
If you are a subrecipient under a DOE financial assistance award, you must either certify you have COI and COC policies that comply with DOE rules or agree that your covered individuals will be subject to the recipient's COI/COC policy; this must be established in a written agreement between recipient and subrecipient.
Organizational Conflict Standards and OCI Reporting
Non-Federal entities with a parent, affiliate, or subsidiary (other than a state, local government, or Indian tribe) must maintain written standards of conduct covering organizational conflicts of interest consistent with 2 CFR 200.318(c)(2) and must report any potential or actual OCI to DOE within 15 days of learning of it.
Broad Disclosure Scope: 'Other Support' and No De Minimis
DOE adopts definitions consistent with PHS: significant financial interest and 'other support' include resources made available to a covered individual (including in-kind support and gifts without terms). DOE did not adopt a de minimis monetary threshold for disclosures, so these categories may need reporting under DOE rules.
Tribes Under Office of Indian Energy Exempt
Subpart C does not apply to applicants or recipients of DOE financial assistance under the Office of Indian Energy; the rule excludes those awards because of tribal sovereignty and program mission considerations.
DOE Can Require Extra Disclosures In Special Cases
DOE may require routine or on-request submission of covered individuals' disclosures in special circumstances—such as monitoring compliance, bankruptcy, winding down, or acquisition (including foreign acquisition)—even though routine submission is not expected to be typical.
Program Offices May Tailor Individual Rules
DOE program offices may tailor COI, COC, and OCI provisions for individuals applying for or receiving DOE financial assistance in their individual capacity, but DOE will not tailor the requirements when the non-Federal entity is a university or research facility.
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Key Dates
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