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The FY2026 SBIR Compliance Checklist: Why Proposals Get Triaged Out Before Review

Most losing SBIR/STTR proposals never reach a technical reviewer. They get screened out first for administrative non-compliance — a missing attestation, a formatting violation, an eligibility box left unchecked. The science was fine; the paperwork wasn't.

The April 2026 SBIR/STTR reauthorization (S.3971) raised that bar with new due-diligence and national-security disclosure requirements. Here's a practical pre-submission checklist so you don't get triaged out.

1. Eligibility (auto-reject if wrong)

  • Organized for-profit U.S. small business, work performed in the U.S.
  • >50% owned & controlled by U.S. citizens / permanent residents (or eligible entities under the rules)
  • ≤ 500 employees, including affiliates
  • PI's primary employment (>50%) is with the applicant firm at time of award (SBIR)

2. FY2026 national-security due diligence (the new bar)

This is where 2026 applicants get caught. Confirm you've disclosed/attested:

  • FOCI — Foreign Ownership, Control, or Influence
  • MFTRP — no covered individual participates in a Malign Foreign Talent Recruitment Program
  • Foreign affiliations / relationships with a country of concern
  • Foreign investment ties from entities in a country of concern
  • Technology licensing / joint ventures with parties in a country of concern
  • Current & Pending (Other) Support — including all foreign support
  • Cybersecurity practices described / attested

3. Required components

Specific aims, work plan, commercialization plan, budget, biosketch(es), and letters of support — all present and clearly labeled.

4. Formatting & page limits

  • Body text at least 11 pt in an allowed typeface
  • Margins at or above the solicitation's minimum on all sides
  • Correct assembly and file format; Phase I page limits respected per agency

If you want to check a draft against all of this in about 30 seconds, I built a free SBIR Compliance Checker: paste your proposal, get a submission-readiness score plus an itemized gap list — including the new FY2026 attestations. It runs 100% in your browser (your text never leaves the page) and needs no account: https://autogranthunter.com/checker?ref=devto

Would love feedback from anyone submitting this cycle — what tripped you up in the new rules?

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