On March 3, 2026, the Senate took a major step toward reauthorizing the Small Business Innovation Research/Small Business Technology Transfer (“SBIR/STTR”) programs, by passing the Small Business Innovation and Economic Security Act (S. 3971).  Known collectively as “America’s Seed Fund,” the SBIR and STTR programs provide small businesses with early-stage funding to commercialize their new technological innovations. 

The SBIR and STTR program authorities (15 U.S.C. § 638) expired on September 30, 2025, preventing agencies from issuing new awards under the programs.  The bipartisan bill, if it is passed by the House of Representatives and signed by the President, would extend the programs through September 30, 2031.  In addition to reauthorizing the program, the bill would also introduce some notable changes to the SBIR/STTR programs, which we highlight in this blog post.

Notable Changes to SBIR/STTR

Strategic Breakthrough Awards.  The reauthorization bill would create Strategic Breakthrough Awards, a new Phase II funding mechanism intended to accelerate the transition of critical technologies from SBIR research into deployment, acquisition, or production.  The program allows certain agencies to dedicate a limited portion of their SBIR funds to larger, milestone-driven awards focused on technology transition, rather than incremental R&D.

               Only agencies with more than $100 million in annual SBIR obligations would be eligible to use this authority.  For those agencies — which include the Departments of Defense, Energy, and Homeland Security, as well as the Environmental Protection Agency, and the National Aeronautics and Space Administration — Strategic Breakthrough Awards would be funded through a capped strategic breakthrough allocation, limited to 0.50% of the agency’s extramural R&D budget each fiscal year.

               Under this new authority, agencies could award up to $30 million to a small business concern in a single award or a series of milestone‑based awards, provided that the total period of performance does not exceed 48 months.  Agencies would also be required to complete contract awards within 90 days of receiving a proposal, reflecting Congress’s intent to streamline decision‑making.  To be eligible for a Strategic Breakthrough Award, a small business must:

  • have received at least one prior Phase II SBIR or STTR award;
  • demonstrate 100% matching funds from new private capital, qualifying non‑SBIR government sources, or a combination of both (the statute specifies that matching funds must be new funding obtained as a result of the Strategic Breakthrough Award); and
  • demonstrate through market research that its technology is an effective solution.  We interpret this requirement as calling for credible, market‑based evidence that the technology addresses a clearly defined customer problem more effectively than existing alternatives, rather than merely demonstrating technical promise or feasibility.

               Additional requirements would apply to Department of War (“DoW”) awards.  DoW applicants must demonstrate that their technology is sufficiently mature, has a commitment for inclusion in a Program Objective Memorandum from a senior acquisition official, and addresses high priority operational needs.  The matching funds requirement would also differ:  at least 20% of required matching funds must come from new DoW funding outside of the SBIR/STTR Phase I or II programs.

               In selecting awardees for a Strategic Breakthrough Award, agencies must prioritize national security impact, transition potential, customer demand, and undercapitalized technology areas, and are directed to use streamlined proposal and contracting processes to accelerate awards.

Enhanced Supply Chain Security Requirements.  The reauthorization bill would significantly strengthen national security due diligence requirements for SBIR and STTR awards.  In addition to the existing ban on awards to any small business concern owned by, or with related entities located in foreign countries of concern, the bill would bar awards to any small business concern with connections to entities appearing on specified federal watch lists, including the Section 889 Prohibition List, the Military End User List, the 1260H list of Chinese military companies, and the Non-SDN Chinese Military Industrial Complex Companies List.  The bill also includes a broad catch-all authority permitting an agency to deny an award where the applicant “has a security risk that the Federal agency determines warrants a denial.”

               In assessing national security risk, agencies would be required to consider a range of factors, including the applicant’s cybersecurity practices; patent portfolio; foreign ownership interests; and the affiliations or business relationships of covered individuals, owners, and key personnel with individuals or entities in a foreign country of concern.

               STTR applicants, in particular, could face heightened scrutiny in light of these new requirements.  The assessments for STTR applicants would necessarily extend to the applicant’s partner nonprofit research institution and cover individuals involved in the STTR partnership, making the assessment process more complex, creating a wider group of scrutinized affiliations and relationships, and exposing STTR applicants to greater risk of adverse finding.

Streamlined Administrative Processes.  The reauthorization bill also includes a series of administrative changes intended to improve program efficiency, oversight, and data transparency within the SBIR/STTR programs. 

               Chiefly, the bill would require agencies to establish their own caps on the number of proposals a single applicant may submit in response to Phase I solicitations and certain Phase II solicitations.  Agencies would retain broad discretion to set these limits on a per year, per solicitation, or per topic basis, reflecting a policy concern that high-volume proposal submissions by repeat applicants can strain agency review capacity and crowd out other competitors.  To preserve flexibility for mission-critical needs, the bill would allow the Director of an agency’s SBIR or STTR program office — subject to approvals from the agency Under Secretary and the SBA Administrator along with Congressional notification — to grant limited waivers of these proposal caps for specific topics that are both time-sensitive and urgent to the agency’s mission.  That waiver authority would be capped at no more than 5% of SBIR/STTR topics in any given fiscal year, balancing agencies’ need for agility against Congress’s concern that waivers not undermine the proposal-limiting framework. 

               The bill also directs agencies to provide additional training for contracting officers responsible for administering SBIR/STTR awards, addressing longstanding concerns about inconsistent implementation and limited familiarity with SBIR‑specific authorities within the acquisition workforce.  

               Finally, the legislation would enhance program transparency and data collection by requiring agencies to publicly report whether a new award is a direct‑to-Phase II or subsequent Phase II award, a Strategic Breakthrough Award, or a Phase III prime or subcontract award — a change intended to improve Congressional oversight, program evaluation, and stakeholder visibility into transition outcomes.

Legislative Status and Path Forward 

It is important to note that the legislative process is not yet complete.  Sustained advocacy by the DoW played a significant role in advancing the bill out of the Senate, but it must still be considered by the House, which is currently in recess through March 16.  The House and Senate must pass identical legislation before a bill can be presented to the President for signature and enactment into law.  As a result, any changes made by the House would require the bill’s return to the Senate for further passage — steps that would almost certainly result in additional delay. Another complicating factor:  last Sunday, President Trump announced in a Truth Social post that he would not sign any new legislation until the SAVE America Act is passed.

Takeaways

Applicants don’t need to wait for final reauthorization to begin preparing.  Based on the direction of the legislation, there are several practical steps companies can take now to position themselves for the next SBIR/STTR cycle:

The reauthorization bill is another indication of the Government’s continued interest in promoting commercial technologies.  Applicants interested in a Strategic Breakthrough Award should prepare now to demonstrate the commercial readiness and market potential of their technology.  In particular, applicants should be able to point to identified customers, clearly articulated needs, comparative advantages over existing solutions, and realistic pathways to deployment or acquisition — factors that will support both the “effective solution” requirement and agency selection criteria emphasizing transition impact.

Second, applicants should begin planning for the 100% matching‑funds requirement, particularly given the emphasis on new capital obtained as a result of a Strategic Breakthrough Award.  Early engagement with private investors, non‑SBIR government programs, and even DoW program offices will be critical to meeting this threshold without delaying award execution.

Third, companies should candidly assess technology readiness and execution feasibility to ensure that any remaining work can realistically be completed within the 48‑month performance period for a Strategic Breakthrough Award.  This is especially important for DoW‑focused applicants facing readiness and acquisition‑pathway requirements.

The reauthorization bill also shows Congress’s interest in creating new vetting structures around SBIR/STTR awards to address national security and supply chain concerns.  When coupled with shorter award timelines, these requirements mean applicants should proactively review ownership, affiliations, IP, and cybersecurity practices, and ensure internal and partner arrangements are largely in place as soon as possible.  For STTR applicants in particular, this diligence should extend to research institution partners.

Companies that align early around transition readiness, capital strategy, and security diligence will be best positioned to compete under the reauthorized SBIR/STTR framework.

Photo of Scott A. Freling Scott A. Freling

Scott Freling co-chairs the firm’s Government Contracts practice and is recognized by Chambers USA as a leading practitioner. He divides his practice between representing civilian and defense contractors in traditional government contracts matters and guiding buyers and sellers—including a number of leading private…

Scott Freling co-chairs the firm’s Government Contracts practice and is recognized by Chambers USA as a leading practitioner. He divides his practice between representing civilian and defense contractors in traditional government contracts matters and guiding buyers and sellers—including a number of leading private equity firms—through the regulatory aspects of complex M&A deals involving government contractors.

Chambers USA ranks Scott as a Band 1 lawyer for Government Contracts M&A. Scott is sought after for his regulatory expertise and his ability to apply that knowledge to the transactional environment. He has extensive experience leading classified and unclassified due diligence reviews of government contractors, negotiating transaction documents, and assisting with integration and other post-closing activities. He has served as the lead government contracts lawyer in dozens of M&A deals, with a combined value of more than $80 billion. Scott’s notable transactions include Warburg Pincus and Berkshire Partners’ take-private acquisition of TRIUMPH for $3 billion, Advent International’s take-private acquisition of Maxar Technologies for $6.4 billion, Aptiv’s acquisition of Wind River for $3.5 billion, and Veritas Capital’s sale of Alion Science and Technology to Huntington Ingalls Industries for $1.65 billion.

Scott also represents contractors at all stages of the procurement process and in their dealings with federal, state, and local government customers. He handles a wide range of government contracts matters, including compliance counseling, contract terminations, claims, disputes, audits, and investigations. Scott frequently advises contractors on organizational conflicts of interest and government intellectual property rights. He also counsels clients on risk mitigation strategies, including obtaining SAFETY Act liability protection for anti-terrorism technologies.

Law360 has recognized Scott as a MVP in Government Contracts. He was a founding co-chair of the Mergers and Acquisitions Committee of the ABA’s Public Contract Law Section.

Photo of Stephanie Barna Stephanie Barna

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior…

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior leader on Capitol Hill and in the U.S. Department of Defense (DoD). Most recently, she was General Counsel of the Senate Armed Services Committee, where she was responsible for the annual $740 billion National Defense Authorization Act (NDAA). Additionally, she managed the Senate confirmation of three- and four-star military officers and civilians nominated by the President for appointment to senior political positions in DoD and the Department of Energy’s national security nuclear enterprise, and was the Committee’s lead for investigations.

Previously, as a senior executive in the Office of the Army General Counsel, Stephanie served as a legal advisor to three Army Secretaries. In 2014, Secretary of Defense Chuck Hagel appointed her to be the Principal Deputy Assistant Secretary of Defense for Manpower and Reserve Affairs. In that role, she was a principal advisor to the Secretary of Defense on all matters relating to civilian and military personnel, reserve integration, military community and family policy, and Total Force manpower and resources. Stephanie was later appointed by Secretary of Defense Jim Mattis to perform the duties of the Under Secretary of Defense for Personnel and Readiness, responsible for programs and funding of more than $35 billion.

Stephanie was also previously the Deputy General Counsel for Operations and Personnel in the Office of the Army General Counsel. She led a team of senior lawyers in resolving the full spectrum of issues arising from Army wartime operations and the life cycle of Army military and civilian personnel. Stephanie was also a personal advisor to the Army Secretary on his institutional reorganization and business transformation initiatives and acted for the Secretary in investigating irregularities in fielding of the Multiple Launch Rocket System and classified contracts. She also played a key role in a number of high-profile personnel investigations, including the WikiLeaks breach. Prior to her appointment as Deputy, she was Associate Deputy General Counsel (Operations and Personnel) and Acting Deputy General Counsel.

Stephanie is a retired Colonel in the U.S. Army and served in the U.S. Army Judge Advocate General’s Corps as an Assistant to the General Counsel, Office of the Army General Counsel; Deputy Staff Judge Advocate, U.S. Army Special Forces Command (Airborne); Special Assistant to the Assistant Secretary of the Army (Manpower & Reserve Affairs); and General Law Attorney, Administrative Law Division.

Stephanie was selected by the National Academy of Public Administration for inclusion in its 2022 Class of Academy Fellows, in recognition of her years of public administration service and expertise.

Photo of Catherine Wettach Catherine Wettach

Catherine Wettach is an associate in the Government Contracts Practice Group.  She assists clients with a wide range of government contracts matters, including compliance counseling, investigations, disputes, and the application of public records laws to government contracts and related records.