Enforcement (current leniency period)

NIH currently enforces Common Forms via eRA system validations:

• Common Forms are required for applications, JIT, RPPR, and Prior Approval submissions on/after Jan 25, 2026.
• NIH is currently in a leniency period through May 2026.
• During this period, NIH says noncompliant submissions may receive warnings, but the agency is not yet withdrawing applications for this issue.
• NIH has said it will announce the later submission-blocking error date in a future Guide Notice.

See NIH notices NOT-OD-26-018 and NOT-OD-26-033.

Operational implication: you need dedicated individual certification steps in your internal submission timeline. Delegates cannot certify for the named individual.