Manuel B. Garcia

Manuel B. Garcia serves as the Senior Director for Educational Technology and Digital Learning at FEU Institute of Technology, Manila, Philippines. Read More

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Should AI Use Be Disclosed in a Research Grant Application?

AI disclosure requirements vary among research funders, and not every use of generative AI requires the same treatment. Learn when disclosure may be mandatory, what information to report, and why transparency does not automatically make prohibited AI use acceptable.

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01 · The Question

Do You Need to Tell a Research Funder That You Used Generative AI?

You use generative AI to improve the clarity of a research grant proposal, organize its objectives, or examine possible weaknesses in the methodology. Before submitting the application, you wonder whether the funding organization needs to know.

Does using AI to polish a paragraph require disclosure? What if the system helped develop the research approach or draft substantial sections of the proposal?

The distinction matters because funding organizations may have different policies concerning AI-assisted writing, intellectual contribution, originality, and transparency. Some provide specific disclosure instructions, while others establish restrictions on particular uses without prescribing a universal declaration format.

Researchers therefore need to distinguish between what a funder explicitly requires, what it encourages, and what responsible reporting may warrant when AI materially influenced the application.

02 · The Short Answer

Disclosure Depends on the Funder's Rules and the Nature of AI Assistance

In Brief

AI use should be disclosed in a research grant application when the funding organization requires it. When disclosure is encouraged rather than mandatory, researchers should follow the funder's guidance and consider transparently reporting AI assistance that materially contributed to the proposal's development.

There is no single disclosure requirement applicable to every research funder or every AI-assisted activity. The appropriate approach depends on current funding policies, the type and extent of assistance, and any additional institutional requirements. Disclosure also does not authorize AI activities that the funder prohibits.

03 · What You Need to Know

When and How AI Assistance Should Be Reported in Grant Applications

Why Might Research Funders Want AI Use Disclosed?

A grant application is not merely a writing exercise. It represents the applicant's proposed intellectual contribution, research commitments, and justification for receiving funding.

Generative AI may contribute in different ways. It might correct grammar without changing the underlying research, or it might suggest hypotheses, develop methodological alternatives, generate substantive arguments, or draft extensive sections.

These activities raise different questions about the applicant's contribution and responsibility.

Disclosure can help distinguish the researcher's own intellectual work from assistance provided by an AI system. It may also support compliance with funding policies and provide transparency about how consequential proposal content was developed.

However, disclosure should not be treated as a substitute for originality, accuracy, or scientific accountability.

Does Every Use of AI Require Disclosure?

Not necessarily. Requirements depend on the funding organization and the activity involved.

Some funders may distinguish routine editorial assistance from substantive AI involvement in developing the research proposal. Others may provide broader disclosure instructions or require applicants to follow institution-specific policies.

The distinction should be based on the actual governing policy, not an assumed universal rule that grammar correction is always exempt or that every AI interaction must be declared.

Type of AI Assistance Possible Disclosure Consideration What Authors Should Verify
Spelling and grammar correction May be treated as routine editorial assistance Whether the funder requires disclosure of language-editing tools
Improving clarity and organization May warrant disclosure depending on the extent of assistance Whether AI substantially changed the proposal's presentation or argument
Drafting proposal sections Raises questions about originality and the extent of AI contribution Whether substantial AI development is restricted or must be reported
Suggesting research objectives or hypotheses May involve substantive intellectual assistance Whether the funder permits this activity and expects disclosure
Developing methodological alternatives May influence the scientific content of the application Whether the applicant independently justified and selected the method
Reviewing proposal weaknesses May be considered preparatory feedback Whether the review involved restricted information or prohibited AI processing
Generating references or factual claims Creates accuracy and research-integrity risks Whether all sources and claims have been independently verified

These categories illustrate relevant considerations rather than establish mandatory disclosure thresholds. A particular funder may adopt requirements that differ from this classification.

What Does the National Science Foundation Say About AI Disclosure?

In its December 2023 notice concerning generative AI in merit review, the US National Science Foundation (NSF) distinguished between the responsibilities of reviewers and proposers.

For proposers, NSF encouraged applicants to indicate in the project description the extent to which generative AI was used and how it contributed to the proposal's development.

NSF also emphasized that proposers remain responsible for the accuracy and authenticity of their submissions, including content developed with AI assistance.

The wording is significant. An encouragement to disclose should not automatically be described as a universal mandatory declaration.

Applicants should consult the current NSF Proposal and Award Policies and Procedures Guide, the relevant solicitation, and any subsequent official guidance to determine what applies to their submission.

What Does the National Institutes of Health Say About AI-Developed Applications?

The US National Institutes of Health (NIH) has addressed AI use through policies that distinguish applicant preparation from confidential peer review.

In Notice NOT-OD-25-132, issued in July 2025, NIH established restrictions concerning research applications or sections of applications substantially developed by AI. The policy applies to applications submitted for receipt dates beginning September 25, 2025.

NIH's concern includes whether the submitted work represents the original ideas of the applicants.

This policy should not be reduced to a simple instruction to disclose AI use. If a particular form of substantial AI development is restricted, adding a disclosure statement does not necessarily make that activity permissible.

Applicants should examine the actual notice and subsequent official guidance rather than assuming that a disclosure statement resolves every concern about AI-generated content.

Disclosure and Permission Are Different Requirements

A researcher may accurately disclose an AI activity while still violating a policy that prohibits the activity itself.

Conversely, a permitted activity may not always trigger a mandatory disclosure requirement.

Permission Whether the funding organization and other relevant authorities allow the proposed AI activity.
Disclosure Whether and how the applicant must report the AI assistance that occurred.
Accountability The applicant's continuing responsibility for the accuracy, originality, integrity, and feasibility of the submitted proposal.

These obligations should be evaluated separately. Researchers should first establish that their intended AI use is permissible, then determine the applicable disclosure requirements.

The broader question of restrictions imposed by research funding organizations is especially relevant when different rules govern applicants and peer reviewers.

What Should an AI Disclosure Statement Include?

When a funder requires or permits a disclosure statement, researchers should follow its specified format and location.

If the funder provides no prescribed wording, a useful disclosure may identify the AI tool, describe the relevant assistance, and explain how the applicants reviewed and retained responsibility for the final content.

The level of detail should reflect the significance of the assistance. A general statement that AI was used may be insufficient when the system materially influenced the proposal's methodology or scientific argument.

At the same time, an unnecessarily extensive account of every routine interaction may obscure the activities that genuinely matter.

Should Researchers Identify the AI Tool and Model?

Where required, researchers should report the specific tool and any additional details prescribed by the funding organization.

For consequential AI assistance, recording the provider, product, model identifier where available, and relevant dates may improve transparency and make the process easier to reconstruct.

However, this level of documentation should not be presented as a universal grant application requirement.

Researchers may retain a more detailed internal record than the funder requires them to include in the submitted application.

Where Should AI Use Be Disclosed?

The appropriate location depends on the funding program.

A funder may specify a section within the project description, provide a dedicated declaration field, or issue separate instructions about AI-assisted content.

Researchers should not automatically insert an AI statement into an arbitrary section of the application, particularly when strict formatting and page limits apply.

When the policy encourages disclosure without prescribing a location, applicants may need to determine an appropriate approach consistent with the official instructions.

If uncertainty remains, clarification from the funding organization or institutional research office may be useful.

Does AI Disclosure Remove Responsibility for Errors?

No. Disclosure identifies assistance; it does not transfer responsibility.

If an AI system invents a citation, misrepresents preliminary results, or produces an unsupported methodological claim, the applicants remain responsible for correcting the error before submission.

Similarly, disclosure does not justify presenting AI-generated ideas as independently validated scientific contributions.

Researchers should verify every consequential claim and ensure that the proposal reflects decisions they can explain and defend.

The distinction becomes particularly important when considering what must remain the applicant's own intellectual contribution.

What If the Funder Has No Explicit AI Disclosure Policy?

The absence of an explicit AI disclosure requirement should not be interpreted as permission to disregard other obligations.

Applicants must still comply with requirements concerning originality, research integrity, confidentiality, data protection, and truthful representation.

Where AI materially influenced the scientific development of the application, voluntary transparency may be appropriate, provided it is consistent with the funder's instructions.

However, researchers should avoid claiming that voluntary disclosure is universally mandatory or that it automatically resolves questions about permissible AI assistance.

Watch Out

Do not assume that declaring AI assistance makes prohibited conduct acceptable. If a funder restricts substantial AI development, confidential data processing, or another activity, disclosure does not override that restriction.

04 · A Practical Example

Deciding Whether and How to Disclose AI Assistance

Hypothetical Example

An Educational Technology Grant Application

A researcher prepares a proposal examining the effects of AI-supported formative feedback on undergraduate learning outcomes.

The researcher independently develops the research questions, selects the methodology, and establishes the proposed analysis plan. Generative AI is then used to improve paragraph clarity, organize a preliminary timeline, and identify possible weaknesses in the proposal's explanation of recruitment procedures.

Before submission, the researcher checks the funding organization's current AI policy.

Step 1: Identify the actual AI contributions

The researcher records that AI assisted with language revision, timeline organization, and preliminary critical feedback. It did not independently determine the final research objectives or methodology.

Step 2: Examine the funding policy

The researcher determines whether the funder permits these activities and whether disclosure is required, encouraged, or not specifically addressed.

Step 3: Verify the final proposal

The researcher checks that the revised text accurately represents the proposed study and that no AI-generated references, commitments, or methodological claims remain unverified.

Step 4: Prepare an appropriate declaration

If disclosure is required or voluntarily provided, the researcher uses the funder's prescribed format. Where no wording is specified, the statement describes the actual assistance without exaggerating or concealing its extent.

An illustrative disclosure, where permitted by the funder, might read:

Generative AI was used to assist with language editing, organization of the project timeline, and preliminary identification of areas requiring clarification. The applicants independently developed the research objectives and methodology, reviewed the AI-assisted revisions, and take responsibility for the accuracy and content of the submitted application.

This example is not a universally accepted disclosure template. It would be inappropriate if AI had actually developed substantial scientific content or if the funding organization prescribed different reporting requirements.

The essential principle is that the statement should accurately describe what occurred.

05 · What Researchers Often Get Wrong

Misconceptions About AI Disclosure in Grant Applications

Misconception

Every Funding Agency Requires the Same AI Disclosure Statement

Funding organizations differ in their policies and reporting expectations. Applicants should not reuse a disclosure template without checking whether it satisfies the relevant instructions.

Misconception

Using AI for Grammar Correction Always Requires Disclosure

There is no universal rule covering every funder. Whether routine language assistance must be disclosed depends on the applicable policy and any institutional requirements.

Misconception

Disclosing AI Use Makes Any AI-Generated Application Acceptable

Disclosure does not override restrictions on substantial AI development or other prohibited activities. Permission and reporting are separate obligations.

Misconception

AI Disclosure Transfers Responsibility to the Technology Provider

The applicant remains responsible for the scientific content, accuracy, and integrity of the application. A disclosure statement does not make the AI provider accountable for the applicant's research claims.

Misconception

If the Funder Does Not Mention AI, There Are No Relevant Restrictions

General obligations concerning originality, confidentiality, intellectual property, and research integrity may still apply. Applicants should not interpret silence as unrestricted permission.

Misconception

A Generic Statement That AI Was Used Is Always Sufficient

A vague declaration may not explain material AI contributions. Where disclosure is required, the statement should provide the information specified by the funder and accurately reflect the assistance received.

06 · What This Means for You

How to Make an Appropriate AI Disclosure Decision

Begin with the current funding policy rather than with a generic disclosure template. Determine whether the proposed AI activity is permitted, whether the funder requires reporting, and whether the assistance materially affected the application.

A practical disclosure framework

If the funder explicitly requires AI disclosure
Follow the prescribed wording, content, location, and submission instructions.
If the funder encourages disclosure
Consider describing the actual AI contribution in a manner consistent with the official guidance.
If the funder prohibits the intended AI activity
Do not undertake the activity. Disclosure cannot substitute for permission.
If the funder has no explicit disclosure requirement
Check other applicable obligations and consider whether material AI assistance warrants transparent reporting.
If the AI contribution is difficult to classify
Document the activity and seek clarification from the funder or institutional research office when necessary.

Maintaining an internal record of consequential AI assistance can make disclosure more accurate. The record might identify the task, tool, relevant dates, nature of the generated content, and the researcher's verification or revision decisions.

Such documentation is particularly useful when several members of a research team use different tools during proposal preparation.

It also helps distinguish editorial assistance from substantive scientific development without relying on vague recollections at the time of submission.

07 · A Quick Checklist

Checklist for AI Disclosure in Research Grant Applications

Before submitting an AI-assisted grant application, check:
Retrieve the current official funding policy concerning generative AI.
Determine whether the intended AI assistance is permitted under the applicable rules.
Distinguish mandatory disclosure requirements from recommendations or encouragement.
Identify the actual tasks performed by AI during proposal preparation.
Determine whether AI materially influenced the research objectives, methodology, analysis, or scientific argument.
Follow the funder's specified disclosure format and location where applicable.
Verify the accuracy of AI-assisted content, references, and research commitments.
Confirm that the final application represents the applicants' authentic intellectual contribution.
Retain appropriate documentation of consequential AI assistance and resolve uncertainties before submission.
08 · Frequently Asked Questions

Frequently Asked Questions About AI Disclosure in Grant Applications

Do I have to disclose ChatGPT use in a grant application?

That depends on the funder's current policy, the nature of the assistance, and any institutional requirements. Some funders encourage disclosure, while others establish specific restrictions or reporting conditions.

Does using AI only for grammar correction require disclosure?

Not universally. Some policies may distinguish routine language editing from substantive content development. Applicants should follow the applicable funder's instructions rather than assume an automatic exemption.

Does NSF require applicants to disclose generative AI use?

NSF's December 2023 notice encouraged proposers to indicate the extent and contribution of generative AI use in the project description. Applicants should verify the current solicitation and agency guidance for any additional requirements.

Does NIH allow grant applicants to use generative AI?

NIH distinguishes applicant preparation from peer review and restricts applications or sections substantially developed by AI under Notice NOT-OD-25-132. Applicants should consult current official guidance to determine whether their intended assistance is permissible.

Can I disclose AI use and still violate a funding policy?

Yes. Disclosure does not authorize prohibited activities. A funder may restrict certain forms of AI development or processing regardless of whether the applicant reports them.

Where should I put an AI disclosure statement in a grant proposal?

Use the location prescribed by the funding organization. If no location is specified, consult the applicable guidance and consider seeking clarification before inserting a statement into a section with strict formatting or page limits.

Should I disclose which AI model I used?

Provide the model or tool details required by the funder. Recording the specific system internally may also support transparency, particularly when AI materially contributed to the application.

Does an AI disclosure statement protect me from responsibility for errors?

No. Applicants remain responsible for verifying the accuracy, originality, and integrity of the submitted material, including content developed with AI assistance.

09 · The Bottom Line

Disclose AI Assistance According to the Funder's Actual Requirements

The Bottom Line

AI use must be disclosed in a research grant application when the funder requires it, while encouraged or voluntary disclosure should accurately reflect the nature and extent of the assistance without implying that prohibited AI activities become permissible.

Check the current funding rules, distinguish routine editing from substantive intellectual assistance, and preserve the applicant's responsibility for every scientific claim. Transparency is valuable, but it works alongside permission, originality, and research integrity rather than replacing them.

10 · Sources and Further Reading

Official Sources on AI Disclosure and Research Funding Policies

11 · Cite this Guide

How to Cite This Guide

This guide is intended to be read, shared, and used in research, teaching, and academic work. If you draw on its ideas, explanations, or other content, please acknowledge the source by citing the guide. Doing so gives appropriate credit and helps your readers locate the original resource.

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