PF 2026-61 Department of Energy Interim Conflict of Interest Policy Requirements for Financial Assistance

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PF 2026-61 Department of Energy Interim Conflict of Interest Policy Requirements for Financial Assistance

DATE:  August 18, 2026 (Original December 21, 2021)

TO: HCAs/Senior Contracting Partners/Grant Officers

FROM: Director, Contract and Financial Assistance Policy Division, Office of Policy, Office of Acquisition Management

 

SUMMARY: This Policy Flash provides updated information to the Department of Energy’s (DOE or Department) implementation of 2 CFR 200.112, Conflict of Interest Policy Requirements issued on December 21, 2021, FAL 2022-02 .

On July 16, 2026, the Department of Energy released its final Conflict of Interest and Conflict of Commitment (COI/COC) regulations. The new regulations are codified in is 2 CFR Part 910 subpart C and will replace DOE’s interim COI policy. The regulations have an effective date of August 17, 2026. However:

  • Existing awards will continue to follow the COI requirements specified in the award terms and conditions (e.g., interim COI policy) until such time as DOE modifies the award terms and conditions to include the final COI/COC regulations policy.
  • Applications submitted to NOFOs that refer to the interim COI policy still follow the interim COI policy. If an application is selected for award negotiation, DOE will give guidance on when and how the final COI/COC policy will be applied to those awards.
  • DOE knows that many institutions are concerned about meeting the August 17, 2026, effective date. DOE is considering extending the compliance deadline and will share more information soon.

See the Frequently Ask Questions for more information regarding the Interim Conflict of Interest Policy Requirements provided in PF 2022-41.

Questions concerning this policy flash should be directed to the Contract and Financial Assistance Policy Division at DOE_oapmpolicy@hq.doe.gov .

For NNSA questions concerning this policy flash, please contact the Acquisition Policy and Oversight Division, Policy & Oversight Branch (NA-PAS-111), at (505) 845-5639.