Conducting research brings with it many responsibilities, including reporting and disclosure requirements. Many of these requirements apply regardless of the source of the funding. The following provides a brief summary of some of the major requirements, and where to find more information.

Both Domestic and International

  • Disclose to the Office of Contracts and Grants all research projects you devote effort to—ongoing or proposed, both domestic and international. This includes any direct support provided to you, even if not officially through CU Boulder. 
  • Disclose all sources of support in federal funding applications, following specific funder guidelines.
  • Disclose any planned consulting activities outside of your university faculty role to department leadership, as required by the 1/6th Rule.  
  • Disclose any (joint) appointments at other institutions to your department chair, dean or institute director.
  • Disclose outside professional activities and financial relationships, whether compensated or uncompensatedthrough the Disclosure of External Professional Activities (DEPA) form. Disclose research-related Significant Financial Interests, including stipends, living expenses, payments and travel reimbursements received from other organizations. Disclosures should also include support received from international institutions of higher education or government/quasi-governmental organizations. For more information see:
    https://www.colorado.edu/researchinnovation/coi
  • Disclose financial interests related to your research when publicly sharing  research results, including journal articles, presentations, and other publications.   
  • Disclose any potential conflicts of interest when making purchasing decisions. https://www.cu.edu/psc/forms/conflict-interest-evaluation-coi
  • Promptly disclose inventions or other intellectual property to the Venture Partners at CU Boulder
  • If your work involves export-controlled technologies, inform the Office of Export Controls if you anticipate working with international collaborators, visiting foreign universities or companies (e.g,, making a presentation, taking a sabbatical leave), hosting foreign visitors, adding foreign nationals or exporting controlled items or data. 
  • If your work involves controlled unclassified information (CUI) and/or requirements to follow NIST 800-53/800-171, contact the Information Technology Security Office (ITSO).
  • Provide appropriate supervision for all visits and visiting scholars that you host to ensure that they are upholding University policies and are appropriately using University resources. Promptly alert departmental leadership (and the Office of Export Controls or Information Technology Security Office, as applicable) if you believe a collaborator or visitor may be misusing their access or relationship with CU Boulder.

International Only

The following guidance outlines disclosure and reporting requirements and the CU Boulder departments that can provide assistance.

Last updated October 2019

If you... You should... RIO Involvement and Contact Info
…have been invited to participate or are currently participating in a foreign talent recruitment program (e.g. foreign 1000 talents program, young scholar 1000 talents plan, etc.)

…follow University of Colorado policy related to Conflicts of Interest and Commitment in Research and Teaching and any department policies and procedures related to dual appointments at other institutions 

…contact Conflicts of Interest & Commitment (COIC) to discuss conflict of interest 

…contact the Office of Export Controls (OEC) to discuss export control concerns    

…disclose the relationship in biosketch and current and pending documents on proposals to federal sponsors

...decline to participate if you have a contract to work in a DOE national lab

  • RIO keeps up to date on any developments in federal guidelines and regulations around disclosure requirements and foreign talent programs   
  • Conflicts of Interest & Commitment can be contacted at 303-492-3024 or coi@colorado.edu
  • Office of Export Controls (OEC) can be contacted at 303-735-5177 or exportcontrolshelp@colorado.edu
…have been invited to work with Huawei or a subsidiary of Huawei …decline to work with Huawei or a subsidiary of Huawei. Currently, CU Boulder will not accept funding from Huawei or subsidiaries of Huawei.
  • RIO keeps up to date on any developments in federal guidelines and regulations around debarment of foreign sponsors
…have travel reimbursed or sponsored by a foreign entity, individual or government 

…contact OEC to discuss export control concerns for international travel

…comply with the CU Boulder travel processes and policies (including any travel policies your department may have), submit the trip through Concur, and, for international travel, complete an international export control travel form

… disclose the activity in your annual or updated Disclosure of External Professional Activities (DEPA)   

…have a foreign entity propose an institutional partnership with CU Boulder or a consulting relationship with you 

…disclose the activity in your annual or updated Disclosure of External Professional Activities (DEPA)    

…contact your OCG Proposal Analyst

… for consulting relationship with you, disclose the relationship in current and pending documents on proposals to federal sponsors

  • RIO works closely with the Global Engagement Office to support international activities critical to the CU Boulder mission
  • OCG can provide screenings of foreign entities
  • Office of Contracts and Grants, https://www.colorado.edu/ocg/directory
…have an active or proposed position with, or have been provided with funding by, a foreign institution 

…follow University of Colorado policy related to Conflicts of Interest and Commitment in Research and Teaching and any department policies and procedures related to dual appointments at other institutions

…disclose the activity in your annual or updated Disclosure of External Professional Activities (DEPA)

…contact the Office of Export Controls (OEC) to discuss export control concerns    

…disclose the relationship in biosketch and current and pending documents on proposals to federal sponsors

  • OCG and OEC work closely to screen, review, and seek approval for international relationships or work  
  • OCG can provide screenings as appropriate for purchases and/or shipments of materials and equipment   
…have funding from DOE or DOD …contact OCG prior to starting any international collaboration, related to the research or otherwise   
  • DOE and DOD have specific clauses that may limit international collaboration. OCG can identify and negotiate such clauses and works with the PI to develop an appropriate management strategy.   
  • Office of Contracts and Grants, https://www.colorado.edu/ocg/directory
…have ownership interest in a foreign company 

…disclose the activity in your annual or updated Disclosure of External Professional Activities (DEPA)

…disclose the relationship in biosketch and current and pending documents on proposals to federal sponsors, if applicable

  • Conflicts of Interest & Commitment (COIC) reviews and screens relationships disclosed via the DEPA  
  • COIC can be contacted at 303-492-3024 or coi@colorado.edu
…have any active research on campus (funded or un-funded)

…disclose the activity, as needed, in your annual or updated Disclosure of External Professional Activities (DEPA)

….disclose all projects with measurable effort in current and pending documents on proposals to federal sponsors  

  • The COI coordinator reviews all disclosures made on campus 
  • OCG screens all sponsors 
  • RIO works with OIT as necessary to develop procedures to protect research data   
…want to host a visiting scholar, student, tour group, or other individual from a foreign entity  …contact OEC who can review intended locations to be visited, verify if any restrictions apply, and vet individuals who will be visiting  
…anticipate a project that is classified and/or involves controlled unclassified (CUI) information

…contact the OCG Research Security team for classified research

…contact the CU Boulder Research Cyber Security Program for CUI research

…have concerns or questions about a proposed collaboration or research project  …contact your OCG Proposal Analyst