COI/COC Disclosure Requirements and Annual Certification

Disclosure Obligations

Individuals should disclose potential conflicts of interest and commitment when carrying out their external and University education, research, scholarship, or service responsibilities.  All external relationships, domestic and international, should be transparent and must be disclosed in a manner that is consistent with applicable requirements, including federal and state laws/regulations/agency guidance, as well as Emory University’s policies and procedures. 

Significant Financial Interests (SFI) requiring disclosure are interests held individually by the investigator, their spouse or same-sex domestic partner, and dependent children must be added together, and the aggregate value used to determine limits set forth by policies.

Click the image below to see what kinds of activities need to be disclosed as research and non-research faculty, staff, or visiting scholars.

For important guidance about the disclosure requirements and annual certification process, click on the panels below.

If the Research Conflict of Interest Committee (RCOIC) determines that a potential or actual conflict of interest exists for one or more of your outside activities, you are expected to:

  • Respond promptly to follow-up questions from the COI Committee
  • Review and act on a COI management plan. 
  • Complete an annual certification of the conflict situation/management plan

The COI Management Plan is a critical component of this process. It is a document that outlines and implements measures to actively reduce, mitigate, or eliminate an employee's actual, potential, or perceived conflict of interest.

Your disclosure will be reviewed, either expedited by the Conflict of Interest (COI/COC) Office, in conjunction with or by the Research Conflict of Interest Committee (RCOIC).

Based on the review, the following will be determined:

The lifecycle of a conflict of interest (COI) review process includes three (3) stages:

  • Initial Review
  • Determination & Response to Management
  • Annual Review

The Conflict of Interest and Commitment Office (COI/COC) conducts an Annual Review of active conflict of interest (COI) management plans for situations where the Research Conflict of Interest Committee (RCOIC) determines that management is required for an existing conflict. This includes any individual responsible for research design, conduct, or reporting.

**Examples are faculty, post-docs, research staff, part-time/temp research staff, etc.**

Active COI Management Plan(s) are reviewed annually to verify the following:

  • That the conflict of interest still exists
  • The individuals involved in the situation and their roles with the research or external entity
  • The individuals that have a role in the management of the conflict of interest
  • That disclosure of the conflict situation has occurred in publications, etc., as appropriate

As part of this process, the conflicted individual plays a key role in answering questions to update the COI/COC office with pertinent information about the conflict situation. The conflicted individual will receive an email with a link to the COI Annual Management Plan Review Form.

The COI/COC Office requires you to complete the form accurately and promptly to update your financial interest status and comply with the management plan provisions.

What is the Annual Disclosure/Certification Disclosure Process?

Disclosure: A report of whether or not you have an outside activity, relationship, or interest with an external organization related to your institutional responsibilities.

Emory University's Conflict of Interest (COI) in Research Policy requires individuals responsible for the design, conduct, or reporting of research-- Examples –faculty, post-docs, research staff, part-time/temp research staff, etc., to submit during the annual disclosure/certification cycle.

You will receive an email reminder to complete your Annual Disclosure/Certification from December to February to:

  • Review the training page in eDisclose. As the discloser, only you can certify that you have completed the training
  • Review and update any previously reported outside interests
  • Disclosing any new outside interests

To disclose, you can access your annual disclosure/certification in one of two ways:

  • By clicking the link in the email reminder to go directly into the disclosure record upon logging in; or,
  • Submit a disclosure profile in the online submission platform, accessible via
  • Enter your Net ID
  • Enter your Net ID password
  • Click on the Sign In button to log in. Please note this option will only be available for submission during the specified Annual Disclosure/Certification dates.

Please note that if you have not previously logged into eDisclose, you will receive an “Authentication Error” message from the system. You must submit an account request using this link to access the system.

For more detailed information, please visit our Annual Certification SharePoint Page.