The New Conflict of Interest Disclosure: What the Two-Year Lookback Means for Your Team

A new disclosure requirement covers any employee on a proposal or award who worked for the awarding federal agency within the two years before submission. Here's exactly what this requires operationally, and how to make it a standing habit instead of a scramble at application time.

What the disclosure actually requires, and what it doesn't. For any proposal or award team, you now need to know and disclose whether any team member, staff working on the proposal itself or staff who will support the resulting award, was employed by the specific federal agency issuing that funding opportunity within the two years before your application was submitted. This is informational disclosure, not a bar to participation. Having a former agency employee on your team doesn't disqualify your application; failing to disclose their prior employment when it applies is the actual compliance problem.

Here's why this is genuinely an intake problem, not a proposal-writing problem. The information you need, someone's employment history for the past two years, isn't something your grants team usually has on hand, and reconstructing it during application week, especially on a team that includes contractors or recently hired staff, is where organizations get caught. The fix isn't a better proposal checklist. It's capturing the answer once, at the point someone joins your organization or your proposal team, so it's already on file when a deadline arrives.

For every organization, the same two-step build applies. First, add one question to your standard new-hire intake or contractor onboarding: has this person worked for a federal grantmaking agency in the past two years, and if so, which one. Second, add a corresponding line to every proposal team roster your organization submits, confirming the disclosure status of everyone listed. Both are small additions to processes you already run. The value is in making them automatic rather than something someone remembers to ask only when a reviewer flags it.

For State Agencies and Nonprofit Primes: Treat This as Near-Term, Not Someday

For state agencies and nonprofit primes with staff who have federal agency backgrounds, more common in policy-adjacent and regulatory work, treat this as a near-term priority rather than a someday task. If your organization regularly hires people with federal experience, and many strong grants and compliance professionals do have that background, build the intake question into onboarding this month, not at your next proposal deadline. Organizations that wait until a specific application forces the question are the ones most likely to discover a gap under time pressure.

For Local Governments: Apply It Consistently

For local governments applying directly, add the question to your standard grant application checklist alongside your existing conflict of interest language, and apply it consistently across every application and every team member, not selectively for large awards.

For Nonprofit Subrecipients: Have the Answer Ready

For nonprofit subrecipients, expect this disclosure to appear in your prime's subaward application or renewal packet, and the preparation is the same: have the answer ready because you've already asked the question internally, not because you're checking records after the request arrives.

Prepare Now

• Add the two-year federal agency employment question to hiring and contractor intake for any role that could touch a federal award
• Add a disclosure line to every proposal team roster before submission
• Update your written conflict of interest policy to include this specific disclosure requirement
• If you administer subawards, add the disclosure requirement to your subaward application or renewal packet

Your first move toward getting ahead of the new compliance requirements. Get the 2026 Uniform Guidance Transition Checklist.