Pentagon Expands Research Blacklist to China's Top Civilian Universities

What the Section 1286 List Expansion Entails

Previously focused almost exclusively on institutions with direct military or defense ties, the updated list now includes leading comprehensive civilian universities . The FY 2025 list formally identifies these 130 institutions as engaging in "problematic activities" that increase the likelihood of U.S. government-funded research being misappropriated for adversarial military applications .

New Restrictions Starting in FY 2026

Effective fiscal year 2026 (which began October 2025), the Department of War is prohibited from obligating or expending any funds for fundamental research that involves collaboration with any entity on the Section 1286 list . This broad funding ban applies to all mechanisms: grants, contracts, and any other assistance to institutions of higher education . The restriction also:

• Extends to personnel and equipment: It forbids conducting research in collaboration with, or using equipment from, any listed entity, and extends to all employees of such institutions .
• Carries compliance and disclosure requirements: Researchers must disclose all affiliations with listed entities and any activities related to foreign talent recruitment programs. Collaborating with an individual affiliated with a listed entity may affect eligibility for federal funding .
• Allows waivers: Waivers may be granted on a case-by-case basis if the work is deemed to be in the national security interests of the United States .

Broader U.S. Policy Objective: Decoupling Research Ecosystems

The inclusion of Fudan and Shanghai Jiao Tong represents a "significant shift" in U.S. science policy, extending the blacklist beyond institutions with traditional military connections to leading comprehensive civilian universities . This signals that Washington now views the entire Chinese civilian research ecosystem as a potential vector for state-backed intellectual property diversion and unwanted technology transfer.

The Section 1286 list is explicitly designed to "counter unwanted foreign influence on DoW-funded research" by identifying foreign entities confirmed to be engaging in activities that threaten U.S. national security . The stated rationale is preventing the diversion of Pentagon-funded fundamental research to military applications by China, Russia, or Iran.

Experts note the expansion could "further damage bilateral academic ties and impose substantial costs on US research and innovation," reflecting a broader policy trajectory of technology competition and strategic decoupling from China's science and technology sectors . Nearly 70 percent of the 130 institutions on the list are based in China, with the remainder from Russia and Iran .