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 Applicants Be Told if AI Was Used to Review Their Grant Proposal?

Applicants may reasonably expect to know when AI contributes to evaluating their research proposals, especially when it influences scientific judgments or funding decisions. Explore what meaningful disclosure should include, how policies differ, and why transparency must be accompanied by accountability.

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01 · The Question

Do Researchers Have a Right to Know Whether AI Evaluated Their Grant Application?

You submit a research grant proposal and receive an unfavorable evaluation. The reviewers question your methodology, describe your contribution as insufficiently original, and assign a score below the funding threshold.

Later, you discover that an AI system may have helped generate some of those assessments.

Would knowing this information have changed how you interpreted the review? Should the funding organization have disclosed the AI involvement before the evaluation, after the decision, or at all?

These questions become particularly important when AI moves beyond administrative assistance and contributes to scientific judgments, numerical scores, applicant rankings, or recommendations about which projects deserve funding.

The issue is not simply whether AI was used. It is whether applicants receive enough information to understand how their proposals were evaluated and who remains accountable for the resulting decisions.

02 · The Short Answer

Meaningful AI Involvement Should Generally Be Disclosed

In Brief

Research funding organizations should generally disclose when AI materially contributes to evaluating grant proposals, particularly when it influences scientific assessments, scores, rankings, or funding recommendations. Applicants should be able to understand the role of AI and identify who is responsible for the final decision.

However, there is no single universal disclosure rule applicable to every funder, jurisdiction, or type of AI assistance. Some organizations prohibit particular uses of generative AI in grant review altogether. Disclosure also does not make an otherwise prohibited or unreliable evaluation acceptable, nor does it necessarily require revealing confidential reviewer identities or proprietary technical information.

03 · What You Need to Know

What Transparency Should Mean in AI-Assisted Grant Review

Why AI Disclosure Matters to Grant Applicants

Research grant evaluation is a consequential process. Funding decisions can determine whether a project proceeds, whether researchers can recruit staff, and whether early-career investigators can establish independent research programs.

Applicants generally understand that grant proposals may undergo administrative screening, external peer review, panel discussion, and funding decisions based on published criteria. The precise procedures vary among funding organizations.

When AI becomes part of that process, applicants may reasonably want to know whether their work was evaluated by human experts, an automated system, or some combination of the two.

Disclosure helps distinguish the source of an assessment from the authority responsible for it. It can also make it easier to identify which parts of a decision may require additional scrutiny.

However, transparency should not be confused with a guarantee of fairness. An organization can openly disclose an AI system while still using it in ways that are scientifically inappropriate or inconsistent with its own policies.

Not Every Use of AI Has the Same Disclosure Significance

The case for disclosure becomes stronger as AI moves closer to substantive evaluation and consequential decision-making.

For example, an automated system that checks whether required application fields are complete performs a different function from a language model that evaluates scientific originality.

AI Application Potential Influence Disclosure Consideration
Administrative completeness checks Identifies missing forms or required fields General process transparency may be sufficient, subject to applicable rules
Formatting and language assistance Improves wording without changing substantive judgments Follow the funder's specific rules and distinguish editing from evaluation
Proposal summarization May influence which information reviewers notice Disclosure and careful validation become more important; some funders prohibit this use
Scientific merit assessment Evaluates originality, methodology, or significance Strong justification for explicit disclosure, if the use is permitted at all
Automated scoring or ranking May influence funding thresholds and selection order Requires particularly strong transparency, validation, and accountability safeguards
Automated rejection May exclude applications without substantive human assessment Raises substantial concerns about authorization, procedural fairness, and applicable legal obligations

These distinctions describe the potential significance of different AI functions. They are not universal classifications established by every funding agency.

Even seemingly administrative systems may warrant additional disclosure if their errors can prevent an otherwise eligible proposal from receiving scientific review.

Some Research Funders Prohibit AI Use in Scientific Review

Before asking how AI involvement should be disclosed, researchers should establish whether the funding organization permits that involvement.

The U.S. National Institutes of Health (NIH) issued Notice NOT-OD-23-149 in June 2023, prohibiting scientific peer reviewers from using generative AI technologies to analyze and formulate critiques of grant applications and research and development contract proposals.

The notice also explains that uploading or sharing confidential application content or original concepts with online generative AI tools violates NIH peer-review confidentiality requirements. The official NIH notice provides the governing requirements for the activities it covers.

The European Research Council (ERC) clarified its guidance in March 2026. Its principles include non-delegation of evaluation and protection of confidentiality. ERC reviewers may not use AI to summarize proposals in place of reading them, assess scientific merit, or generate draft evaluations. Limited uses, such as improving review language without sharing proposal content, are permitted under specified conditions.

These examples demonstrate that research funders may draw different boundaries around acceptable AI assistance. They do not establish a universal policy for all national funding agencies, private foundations, or institutional research programs.

Where a particular AI use is prohibited, informing applicants that it occurred does not resolve the underlying violation.

What Information Should Applicants Receive About AI Involvement?

A meaningful disclosure should explain the role of AI in terms that applicants can understand. Simply stating that an organization uses advanced technologies may provide little useful information about the actual evaluation process.

Where AI materially contributes to assessment and its use is permitted, a disclosure could address the following questions:

  • What stage of the review process involved AI?
  • What task did the AI system perform?
  • Did it generate summaries, criticisms, scores, rankings, or recommendations?
  • How were its outputs checked before influencing the evaluation?
  • Who retained responsibility for the final assessment?
  • What procedure is available for raising concerns about a possible error?

The level of technical detail may depend on the system's role, applicable law, security considerations, and the need to protect confidential evaluation materials.

Applicants do not necessarily need access to model weights, private reviewer deliberations, or confidential information about competing proposals to receive a meaningful explanation of AI involvement.

Should AI Use Be Disclosed Before or After the Funding Decision?

Disclosure timing affects its usefulness.

Advance notice allows applicants to understand the evaluation procedure before submitting their work. It may also inform their decisions about participation, particularly when proposals contain unpublished intellectual property or commercially sensitive information.

Post-decision disclosure can help applicants interpret reviewer feedback and identify possible grounds for requesting clarification or correction.

For consequential AI involvement, a combination of general advance notice and decision-specific information may be more informative than either approach alone.

Process-level disclosure Explains which AI systems or functions may be used during the funding organization's evaluation process.
Application-specific disclosure Explains whether and how AI actually contributed to the assessment of a particular application.

A general statement that AI may be used does not necessarily tell an applicant whether their own proposal was assessed with AI assistance.

Conversely, application-specific disclosure may require reliable internal records showing when the system was used and what role its outputs played.

Does Disclosure Require Revealing the Identity of Human Reviewers?

Not necessarily. Transparency about AI involvement and confidentiality of peer-review deliberations address different concerns.

Many funding systems protect reviewer identities or restrict access to internal deliberations to support candid evaluation and manage conflicts of interest.

An organization may be able to explain that AI assisted with an authorized administrative task without identifying individual reviewers or revealing confidential discussions.

Similarly, an applicant may receive information about the existence and function of an automated scoring system without gaining access to another applicant's proposal.

Disclosure arrangements should preserve legitimate confidentiality protections while providing sufficient information to understand the evaluation process.

Can AI Disclosure Help Applicants Challenge an Unfair Evaluation?

Disclosure may make it easier to identify possible errors, but it does not automatically create a legal right to appeal a funding decision.

Appeal and reconsideration procedures differ among funding organizations. Some permit challenges involving procedural errors or conflicts of interest but do not reconsider scientific judgments merely because an applicant disagrees with them.

Where an AI system materially contributed to an assessment, applicants may reasonably ask whether its outputs were verified and whether the procedure complied with the funder's published rules.

For example, if an AI-generated criticism incorrectly claims that a proposal lacks a methodology section, the issue may concern an identifiable factual or procedural error rather than an ordinary disagreement about scientific merit.

Any request for correction should follow the funding organization's established communication and review procedures.

Why Disclosure Alone Cannot Prevent AI Bias

An AI system may systematically favor particular institutions, research approaches, or styles of academic writing. Disclosing its use does not eliminate those tendencies.

Likewise, a reviewer may become influenced by an AI-generated score even when the organization formally assigns final responsibility to human evaluators.

These concerns connect to bias in AI-assisted grant scoring and the possibility that automated systems may reproduce historical inequalities in research funding.

Meaningful governance therefore requires more than a disclosure statement. It also requires appropriate validation, monitoring, and procedures for identifying and correcting consequential errors.

The NIST AI Risk Management Framework provides a general approach to AI governance, including transparency, explainability, accountability, and the management of harmful bias. Its principles can inform research funding practices, although they do not establish one mandatory disclosure format for all grant programs.

Who Remains Responsible When AI Contributes to a Funding Decision?

An AI system cannot assume institutional responsibility for allocating research funds.

The funding organization remains responsible for establishing appropriate evaluation procedures, applying its published criteria, and complying with applicable requirements.

Human reviewers and decision-makers also retain responsibilities determined by their roles and the organization's policies.

This remains true even when an AI system produces the initial summary, identifies possible weaknesses, or generates a numerical recommendation.

The relevant governance question is which decisions may appropriately receive AI assistance and which require independent human judgment.

04 · A Practical Example

When a Grant Applicant Discovers That AI Contributed to Their Evaluation

Hypothetical Example

An AI-Generated Methodological Criticism

A fictional research foundation permits a specifically approved AI system to assist reviewers with identifying potential methodological concerns. Its procedures require human verification before any AI-generated observation can influence a proposal's scientific score.

A researcher submits a proposal investigating the effects of adaptive learning technologies on students' problem-solving performance.

The researcher later receives an evaluation stating that the proposal lacks a clear strategy for addressing baseline differences between comparison groups.

However, the application contains a detailed baseline adjustment procedure. The applicant wonders whether the criticism resulted from an oversight during review.

Step 1: Identify the evaluation procedure

The foundation's published policy explains that an approved AI system may flag methodological concerns but cannot independently determine scientific scores.

Step 2: Request clarification through the official process

The applicant identifies the relevant section of the submitted proposal and asks whether the criticism reflects an overlooked passage or a substantive disagreement about the proposed analysis.

Step 3: Examine the internal assessment record

The foundation reviews its records and determines that the AI system initially generated the criticism. The assigned reviewer retained it without adequately checking the corresponding methodology section.

Step 4: Apply the established correction procedure

The foundation follows its documented process for addressing evaluation errors. Depending on its rules, this might involve correcting the review record, obtaining an independent assessment, or determining whether the error materially affected the funding decision.

The scenario is hypothetical and does not describe an actual foundation or documented funding dispute.

It illustrates why meaningful disclosure should be accompanied by traceable evaluation records and procedures for examining potential errors. Without those safeguards, applicants may know that AI was involved but have little practical means of determining whether its involvement affected their assessment.

05 · What Researchers Often Get Wrong

Misconceptions About AI Disclosure in Grant Review

Misconception

Every Research Funder Is Legally Required to Disclose All AI Use

Disclosure obligations vary across jurisdictions, organizations, and types of automated processing. A strong ethical case for transparency does not establish a universal legal requirement. Researchers should consult the relevant funder's policies and applicable law.

Misconception

Disclosing AI Use Makes an Otherwise Prohibited Review Acceptable

Disclosure cannot override a funding organization's prohibition on AI-assisted evaluation or unauthorized sharing of confidential proposals. Compliance with the governing policy must be established independently.

Misconception

AI Disclosure Means Applicants Must Receive Every Internal Review Record

Meaningful transparency does not necessarily require unrestricted access to confidential reviewer deliberations, proprietary information, or competing applications. The appropriate scope of disclosure depends on the evaluation process and applicable requirements.

Misconception

A Human Signature Proves That AI Did Not Influence the Evaluation

A reviewer may formally approve an assessment while relying heavily on AI-generated criticisms or recommendations. Meaningful oversight requires independent scrutiny rather than nominal approval.

Misconception

AI Use Only Needs to Be Disclosed When the Application Is Rejected

Transparency concerns the evaluation procedure, not merely the outcome. Applicants whose proposals succeed may also have legitimate interests in understanding how their work was assessed and how confidential information was handled.

Misconception

Disclosure Automatically Gives Applicants a Right to Appeal

Appeal rights and reconsideration procedures are determined by the funding organization's rules and applicable law. Disclosure may help identify a possible error, but it does not independently establish grounds for overturning a decision.

06 · What This Means for You

What Applicants and Funding Organizations Should Do About AI Disclosure

For applicants, the most useful starting point is the funding organization's official evaluation policy.

Before submission, examine whether the organization explains its use of automated systems, confidentiality protections, and review procedures. If the policy is unclear and AI involvement would materially affect your decision to submit, seek clarification through an authorized channel.

After receiving a decision, distinguish between disagreement with a reviewer's scientific judgment and evidence of a possible factual or procedural error.

For funding organizations, disclosure should be proportionate to the influence of AI on the assessment and sufficiently specific to support accountability.

A practical decision framework

If AI is used only for authorized administrative processing
Explain the relevant automated procedures where appropriate or required, particularly when errors could affect eligibility or progression to scientific review.
If AI assists with scientific assessment and the use is permitted
Provide clear information about the AI's role, validation procedures, and human responsibility for the evaluation.
If AI-generated scores or rankings materially affect decisions
Apply heightened transparency and governance safeguards, including documented evaluation procedures and appropriate mechanisms for investigating errors.
If the funding organization prohibits AI-assisted review
Do not use AI for the prohibited activity. Disclosure cannot substitute for compliance with the restriction.

Disclosure Should Be Supported by an Internal Audit Trail

A funding organization cannot reliably explain AI involvement if it has not documented how the system was used.

Where AI assistance is permitted, relevant records may include the system's function, version, authorized inputs, generated outputs, validation results, and any human decisions that relied on those outputs.

These records should be retained according to applicable governance, confidentiality, and records-management requirements.

They may also support investigations into confidentiality risks associated with AI-assisted grant review.

Watch Out

Do not assume that a funding organization's silence about AI means that AI was used or that it was absent. Similarly, an unfavorable review is not evidence of AI involvement. Concerns should be grounded in official policies, documented procedures, or identifiable evaluation errors rather than speculation about the origin of reviewer comments.

The objective of disclosure is not to make AI use inherently acceptable. It is to ensure that applicants understand the relevant evaluation process and that funding organizations remain answerable for the decisions they make.

07 · A Quick Checklist

Checklist for Transparent AI Use in Grant Evaluation

Before implementing or evaluating AI disclosure practices, check:
Verify the funding organization's current policy on AI use in scientific review and administrative processing.
Determine whether applicable law or institutional rules impose specific disclosure obligations.
Identify which evaluation stages involve AI and whether its outputs can influence consequential decisions.
Distinguish administrative assistance from scientific merit assessment, scoring, and ranking.
Provide applicants with understandable information about material AI involvement where appropriate or required.
Document how AI-generated assessments are validated and who retains responsibility for final decisions.
Protect confidential applications, reviewer identities, and sensitive evaluation records.
Establish procedures for examining possible AI-related factual or procedural errors.
Maintain an appropriate audit trail of authorized AI involvement and review the disclosure policy when procedures change.
08 · Frequently Asked Questions

Frequently Asked Questions About Disclosing AI Use in Grant Review

Are research funders required to tell applicants when AI reviews their proposals?

There is no universal requirement applying to every funder. Obligations depend on applicable law and organizational policies. Nevertheless, meaningful disclosure is advisable when permitted AI use materially influences scientific assessments or funding decisions.

Does the NIH allow generative AI to evaluate grant applications?

NIH Notice NOT-OD-23-149 prohibits NIH scientific peer reviewers from using generative AI to analyze and formulate critiques of grant applications and research and development contract proposals. Reviewers must also comply with NIH confidentiality requirements.

Can European Research Council reviewers use AI?

Under ERC guidance issued in March 2026, reviewers may not delegate proposal understanding or scientific evaluation to AI, or upload proposal content to external AI systems. Limited assistance, such as improving the language of reviews without sharing confidential content, is permitted under the stated conditions.

Should applicants be informed before their proposals are processed by AI?

Advance notice can help applicants understand the evaluation procedure and relevant data-handling arrangements. Whether it is mandatory depends on the governing requirements. For consequential AI involvement, advance process-level information may usefully complement later application-specific disclosure.

Can applicants request the AI-generated comments used in their evaluation?

They may ask through the funding organization's official procedures, but access is not automatically guaranteed. Disclosure rules, confidentiality protections, records policies, and applicable law determine what information may be provided.

Can a grant decision be challenged because AI was involved?

Potentially, if the AI use violated an applicable rule or contributed to an error covered by the funder's reconsideration procedures. AI involvement alone does not necessarily establish grounds for appeal.

Is disclosing the AI model's name sufficient?

Usually not when AI materially influences evaluation. Applicants may also need to understand what the system did, how its outputs were checked, and who remained responsible for the decision. The appropriate level of detail depends on the context.

Does AI disclosure guarantee fair grant review?

No. Transparency supports scrutiny but does not independently establish accuracy, fairness, or methodological validity. These properties require appropriate testing, governance, and meaningful human accountability.

09 · The Bottom Line

Applicants Should Understand When AI Influences Their Evaluation

The Bottom Line

Research funding organizations should generally disclose material AI involvement in grant evaluation so applicants can understand how their proposals were assessed and who remains accountable for consequential decisions.

The precise disclosure requirements depend on the funder, jurisdiction, and permitted uses of AI. Transparency must also be supported by confidentiality protections, reliable evaluation procedures, and meaningful human responsibility. Explaining that AI was used is valuable, but it does not by itself make the evaluation fair, valid, or compliant with policy.

10 · Sources and Further Reading

Official Guidance on AI Transparency and Grant Review

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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