NSF, NIH, DOE, DOW ( Department of War, previously Department of Defense) and DARPA have taken noticeably different positions on AI use in proposal writing, and the gap between them is wide enough to significantly matter when it comes to funding.
NSF: Disclose and Proceed
NSF’s position is the most permissive. Under PAPPG 24-1, AI use in proposal preparation is
allowed. You must disclose the extent and manner of that use within the relevant proposal section. Failure to disclose is treated as misrepresentation, which carries legal weight under the certifications you sign at submission. No restrictions on volume, no declarations about originality.
That said, NSF is working on a new PAPPG, designated 26-1, which was planned for release in fiscal year 2026. Its publication has been deferred while OMB updates the Uniform Guidance under Executive Order 14332. When 26-1 does arrive, the AI disclosure requirements could tighten. Watch nsf.gov/policies/pappg for updates. NSF’s original notice on generative AI use is at nsf.gov/news/notice-to-the-research-community-on-ai.
NIH: Substantially Harder Line
NIH moved significantly further in July 2025. Effective September 25, 2025, NOT-OD-25-132 states that applications substantially developed by AI are not considered original ideas of the applicant and will not be funded. The policy was triggered by a real problem: some PIs used AI tools to submit more than 40 applications in a single submission round, overloading the review system.
NIH now uses AI-detection software, and post-award detection can result in misconduct referrals, cost disallowances, grant suspension, or termination. NIH also capped submissions at six applications per PI per calendar year, effective January 1, 2026.
DOE: Compliance and Access Control
DOE focuses on access control and compliance rather than originality. AI-assisted content must meet federal requirements including Section 508 and the Plain Writing Act. Accessing tools like ChatGPT from a DOE computer requires a valid business justification. The framing is IT governance, not proposal integrity. DOE’s AI guidance is at energy.gov/cio/artificial-intelligence.
DOW and DARPA: No Specific Policy
DOD and DARPA have not issued specific guidance on AI use in proposal writing. Their policy energy is directed at research security — foreign talent recruitment programs, Confucius Institute restrictions, and undue foreign influence risk assessments. Current DARPA proposer guidance is at darpa.mil/about/offices/contracts-management/proposer-grants.
The practical takeaway: the same AI workflow that is acceptable at NSF could get your NIH grant terminated. Before your next submission, check the current policy for that specific agency. These policies are moving fast, and the gap between funders is only likely to grow.
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