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Scan for outdated or missing drivers - takes under a minuteDriver Scan →Clear out junk files and repair common Windows errorsFree Scan →Fix the driver behind crashes, sound loss and screen glitchesFind Drivers →AI research collaboration in the UK is not automatically licensed or prohibited because it involves AI, an overseas co-author, an international student or a cloud service. The project must be assessed on its specifics: what technology or knowledge will be transferred or accessed, who will receive it and where, its intended end use, and whether the agreement grants rights or control over research assets. Export controls, UKRI’s Trusted Research and Innovation principles, the National Security and Investment Act, ATAS and sanctions are separate checks; more than one can apply to the same project.
Start with the project, not the label “AI”
UK strategic export controls can cover military and dual-use goods, software and technology, as well as technical assistance. Whether a licence is required depends on the relevant control-list entry or an applicable end-use or end-user control. The Export Control Act 2002 and Export Control Order 2008 form part of the framework. The government’s strategic export guidance was updated on 23 April 2026 and places responsibility for checking licence requirements on the exporter.
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For an AI collaboration, assess the particular system, model capability, software, hardware, algorithms, technical data and assistance—not AI as a general category. Technical assistance may include instructions, training, specialist working knowledge, consulting or troubleshooting. Data and algorithms can also be relevant. Even ordinary communications, such as an email sent overseas, may transmit controlled technology if they contain it.
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Make an inventory before sharing or granting access. Include draft papers and presentations as well as less visible research outputs and interactions:
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- Source code, software, algorithms, model weights or other model artefacts.
- Technical data, datasets, design documents, specifications and unpublished findings.
- Hardware, specialist equipment, or instructions for using, modifying or reproducing it.
- Training, demonstrations, technical discussions, troubleshooting and other specialist assistance.
- Remote access to repositories, research environments, facilities or technical staff.
For each item, establish its technical characteristics and whether a control-list entry may apply. Then identify the proposed recipient, their location and affiliations, the intended end use, and any relevant destination or diversion concerns. Applied research in telecommunications and information technology is among the areas the Export Control Joint Unit (ECJU) identifies as potentially high risk; that is a reason to screen carefully, not evidence that all AI work is controlled.
How the academic research exemptions work
ECJU’s academic guidance describes exemptions for technology or software already in the public domain, qualifying basic scientific research, and the minimum technical information needed for certain non-nuclear dual-use patent applications. These exemptions are specific and do not establish a general exemption for academic work.
Public domain and planned publication are different
Research is not already in the public domain simply because the team intends to publish it or send it for peer review. Sending controlled research overseas for peer review or publication may require a licence before it is published. Assess the material being shared at that stage, including draft papers, code, data and supporting technical information.
Basic scientific research has a narrow meaning
For this purpose, basic scientific research is experimental or theoretical work undertaken solely to gain fundamental knowledge, with no specific practical aim or technical problem in view. The exemption applies only to controlled dual-use technology, not military-listed technology, and does not remove end-use, end-user or destination concerns. Advanced postgraduate work, including MPhil or PhD research involving controlled technology, is unlikely to be wholly exempt if it includes applied research or unpublished technology.
Do not infer that a whole project is exempt from the subject area, academic setting or publication plan. Consider each output and transfer, and ask the institution’s export-control specialist to assess uncertain classifications or exemption claims.
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International partners, remote access and cloud services
ECJU recommends due diligence before agreeing to international research collaborations. Check whether a transfer will occur, whether there is a risk of diversion, and whether partner organisations or individuals have relevant links or activities of concern. Appropriate checks can include open-source information, sanctions or restrictions lists, and publicly available information about military or defence involvement. ECJU can be contacted about specific export-licensing questions.
Online and distributed research is not outside the analysis. ECJU’s academic guidance includes e-Research and e-Science as activities where export controls can still apply. A UK-based server does not, by itself, resolve the question if overseas collaborators can access controlled technology or receive specialist assistance remotely.
Questions to settle before granting access
- What files, models, datasets, source code, technical instructions or expertise can the collaborator reach?
- Who will have access, from which locations, and through which accounts or systems?
- Do permissions allow downloading, copying, onward sharing, training on the material or changing access rights?
- Can the access be limited to the material and people needed for the work, and removed when it is no longer required?
- Do the partner’s affiliations, activities, intended end use or the destination raise diversion, sanctions or other concerns?
Access controls and contractual safeguards can help manage a project, but they do not replace classification or licensing checks where a controlled transfer may occur.
How the main UK checks differ
These regimes answer different questions. A security concern is not automatically a legal prohibition, and clearance under one regime does not settle the others.
| Check | What it addresses | When it may matter | What it does not replace |
|---|---|---|---|
| Strategic export controls | Controlled military or dual-use goods, software, technology and technical assistance; certain end-use or end-user concerns. | When technology or assistance is transferred, including through some electronic or remote access, or a relevant catch-all control applies. | TR&I due diligence, NSI review, ATAS or sanctions checks. |
| UKRI Trusted Research and Innovation (TR&I) | Risk-based practices to safeguard research, people, infrastructure and intellectual property while enabling responsible collaboration. | For organisations funded by UKRI, which are expected to comply with relevant law and use appropriate partner, agreement, cybersecurity and access-management practices. | Legal export-control analysis or any required licence. |
| National Security and Investment (NSI) Act | Qualifying acquisitions of UK-connected entities and assets where statutory tests are met and national-security risk may arise. | When an arrangement involves an acquisition or a grant of control or greater control over a qualifying entity or asset. AI is one of 17 sensitive areas for certain mandatory entity notifications. | Export licensing; an export licence does not provide NSI clearance. |
| Academic Technology Approval Scheme (ATAS) | Approval for certain foreign students and researchers studying or conducting research in specified sensitive fields in the UK. | When a person and their research subject meet current ATAS eligibility rules. | Export-control screening or licensing. |
| Sanctions and embargoes | Restrictions on specified destinations, persons, entities, activities or exports under sanctions legislation. | When a proposed export or collaboration involves a restricted party, destination or activity; requirements can change. | Other export-control, TR&I or NSI checks. |
UKRI Trusted Research and Innovation
UKRI’s TR&I principles, version 2.0, were published on 13 June 2025. UKRI expects organisations it funds to comply with relevant law and take a proportionate, risk-based approach. Its principles call for appropriate partner due diligence; an understanding of partners’ governance, ownership and relevant state affiliations; suitable collaboration agreements; cybersecurity awareness; management of knowledge and facility sharing; and access to data only for people with a clear need, and only for as long as needed. Institutions may use different assessment methods and have different risk appetites.
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UKRI defines TR&I as “the protection of the UK’s intellectual property, sensitive research, people, and infrastructure from potential theft, misuse and exploitation.” It is a framework for responsible practice, not a blanket bar on international collaboration or a substitute for legal analysis. A risk signal should prompt proportionate consideration rather than being treated automatically as proof that collaboration is prohibited.
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When an AI collaboration may need NSI Act review
The NSI Act is distinct from export control. It can apply to qualifying acquisitions of UK-connected entities and assets when statutory control tests are met and a national-security risk may arise. AI is one of 17 sensitive areas in which certain qualifying acquisitions of entities can trigger mandatory notification if the legal conditions and thresholds are met. Asset acquisitions are not subject to mandatory notification, but a qualifying asset acquisition can still be called in for assessment.
Research assets can include software, trade secrets, databases, source code, algorithms, patents and other intellectual property, as well as specialised laboratory equipment. A collaboration, sponsorship, licence or spin-out arrangement may warrant NSI review if it gives another party control or greater control over a qualifying asset, including a future asset. Public funding or an academic purpose does not automatically exempt an acquisition. Check the actual rights and control terms; an ordinary research relationship is not, by itself, proof that the NSI Act applies.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.ATAS, sanctions and related security guidance
ATAS is person- and subject-specific
The Foreign, Commonwealth & Development Office administers ATAS for certain foreign students and researchers who study or conduct research in specified sensitive technology-related fields in the UK. Whether a particular researcher needs approval depends on the person and subject under the current eligibility rules. The public guidance was updated on 24 March 2026. ATAS is not a general export licence.
Check sanctions against current parties and destinations
Sanctions and embargoes can restrict exports or make the proposed end user and destination decisive. The government’s strategic export guidance explains that a sanctions licence may be required for exports prohibited by sanctions legislation. Check the current rules against the specific parties, destination and activity when the collaboration is proposed; do not rely on a static country summary.
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Foreign interference and political influence are related but separate
The Department for Education’s guidance, Protecting UK higher education from foreign interference, published on 9 February 2026, helps higher-education providers recognise, prevent and report foreign interference while protecting people, research and academic freedom. It complements, rather than replaces, export-control and NSI legal checks.
UKRI also identifies the Foreign Influence Registration Scheme (FIRS) as relevant where an arrangement involves political influence activity in the UK at the direction of a foreign power. Routine research collaboration alone should not be treated as triggering FIRS; assess whether the arrangement and activity fall within the scheme’s current rules.
A practical screening sequence for a research office
- Describe the work and assets. Record the research activity, technical characteristics, project outputs, facilities and expertise involved. Separate information already public from unpublished material.
- Map transfers and access. Identify every recipient and location, including remote users, and how code, data, model artefacts, technical assistance or equipment may be shared.
- Check control-list and end-use questions. Ask the institution’s export-control specialist to assess potentially relevant list entries, military or dual-use character, end users, end uses, destinations and diversion concerns. Determine whether a licence or a specific exemption is relevant before sharing.
- Review the partner and security context. Carry out proportionate due diligence on organisations and individuals, including relevant ownership, governance, affiliations, restrictions and publicly known activities.
- Read the agreement for rights and control. Examine provisions for access, use, onward sharing, ownership, licensing, governance and control over current or future research assets. Refer potential qualifying acquisitions for NSI review.
- Check people-specific and other legal requirements. Confirm whether ATAS applies to any researcher, and check current sanctions and embargo rules for the parties, destination and proposed activity.
- Set safeguards and document the decision. Use suitable collaboration terms, cybersecurity measures, access limits and review points. Record the basis for decisions and seek institutional or government advice if classification or applicability remains uncertain.
The UKRI principles do not prescribe one universal due-diligence method, and the correct legal outcome cannot be determined from a project description alone. Government guidance identifies the relevant checks; technical specifications, legal terms and circumstances determine how they apply.
Where to get specialist guidance
Route technical classification and licensing questions through the organisation’s export-control or research-compliance process; ECJU is the relevant government contact for specific export-licensing questions. UKRI-funded organisations should also use their TR&I governance and due-diligence processes. The Cabinet Office’s Research Collaboration Advice Team (RCAT) provides advice to the research sector on national-security concerns in international collaboration; its 2026 update includes AI among the topics on which it advises. RCAT reported more than 3,800 engagements with institutions across the UK, including management of more than 500 cases. Those are overall activity figures, not counts of AI-specific risks or evidence against any individual partner.
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