Research and Innovation Services


NIH Financial Conflict of Interest (FCOI) Policy

All organisations in receipt of NIH funding are required to demonstrate compliance with the NIH Financial Conflict of Interest Policy (FCOI). Find out what you need to do.

The policy applies to funding awarded directly by the National Institutes of Health (NIH) itself or its Institutes or indirectly e.g. where UCL is (or receives funding from) a sub-awardee or sub-contractor.  

The policy applies to any staff involved in or responsible for the design, conduct, or reporting of research funded by the NIH which including (but not limited to):

  • Principal Investigators (PIs)
  • Co-Investigators (Co-Is)
  • Honorary Staff
  • Post-Doctoral Researchers
  • Students, Technicians
  • External collaborators or consultants.

For the purpose of this guidance and the NIH policy, all such individuals are referred to as ‘Investigators’.

Under the NIH Conflict of Interest Policy, Investigators must complete the online NIH FCOI tutorial prior to engaging in research related to any NIH grant and at least every 4 years.


Further guidance for Investigators and Academic departments can be found in the guidance document below.