Research funding disclosure rules

Journal disclosure: the ICMJE recommendations

The International Committee of Medical Journal Editors asks authors to disclose all relationships and activities that might bias, or be seen to bias, their work. Financial relationships include employment, consultancies, stock, honoraria, patents and paid expert testimony ¹.

Articles should name sources of support and explain the funder's role in study design, data collection, analysis, interpretation, writing and any publication limits. If the funder had no such role, the article should say so ¹. Authors should avoid sponsor agreements that limit their access to data or their freedom to publish ¹. ICMJE member journals require its Disclosure Form ¹.

Editors carry duties too. Editors with a potential conflict should recuse themselves, and journals should publish disclosure statements of editors and staff ¹.

Institution rules: NIH financial conflict of interest

NIH grants and cooperative agreements fall under 42 CFR Part 50, Subpart F, Promoting Objectivity in Research. The final rule was published in the Federal Register on 25 August 2011 ². Phase I SBIR and STTR awards are excluded ².

Institutions must keep a written and enforced conflict of interest policy, post it publicly, train investigators, and review each investigator's significant financial interests. They report conflicts to the NIH awarding institute and manage them ². If noncompliance occurs, they must carry out a retrospective review within 120 days ².

Investigators must disclose foreign financial interests tied to their institutional duties, such as income from foreign universities or governments for lectures, advisory roles or sponsored travel. Interests of a spouse and dependent children count ². NIH says institutions may set their own disclosure thresholds in their policies ².

Industry payments: Open Payments

The US Centers for Medicare and Medicaid Services runs Open Payments, a national disclosure program with a public database of payments from reporting entities, such as drug and medical device companies, to covered recipients such as physicians ³. CMS publishes the data each year on or by 30 June ³. For Program Year 2025, from 1 January to 31 December 2025, it published 17.07 million records totalling $14.67 billion in payments and other transfers of value ³.

Foreign influence rules and universities

Foreign influence schemes can apply to research bodies. The Australian National University tells staff that the Foreign Influence Transparency Scheme requires registration within 14 days of entering a relationship with a foreign principal or starting a registrable activity ⁴. In the UK, the Foreign Influence Registration Scheme enhanced tier covers activities at the instruction of a specified foreign state or state-controlled organisation, with registration within 10 days of an agreement ⁵.