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Home / Resources / Government Oversight
Government Oversight

What foreign affiliation disclosures are required for SBIR and STTR applicants?

Published January 31, 2026

SBIR and STTR applicants must disclose investment and foreign ties, and the current foreign-country-of-concern list is limited to four named countries.

What foreign affiliation disclosures are required for SBIR and STTR applicants editorial illustration
Gov Contract Finder Editorial Team
•2 min read•Updated August 26, 2026•Information as of August 26, 2026

AI-assisted and automatically checked against the linked primary sources.

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What does the SBIR/STTR foreign disclosure requirement cover?

According to the SBA SBIR foreign disclosures page, the SBIR and STTR Extension Act of 2022 amended section 9 of the Act to require small businesses applying for SBIR or STTR awards to disclose information about the applicant’s investment and foreign ties. The SBA says it responded by amending Section 9(a) of the Policy Directive and adding an appendix that gives Participating Agencies responsibilities for collecting those disclosures. The page also says the amendment created a common template, based on the statutory language in the Act, to uniformly capture the required disclosures. The same source defines a “foreign country of concern” as the People’s Republic of China, the Democratic People’s Republic of Korea, the Russian Federation, the Islamic Republic of Iran, or any other country later determined to be a country of concern by the Secretary of State. The current list on the page includes only those four countries, and the SBA says there are no additional countries designated for SBIR and STTR purposes at this time.
[1]

What is a foreign country of concern?

SBASBIRSTTR
The SBA defines it as the People’s Republic of China, the Democratic People’s Republic of Korea, the Russian Federation, the Islamic Republic of Iran, or any other country later determined to be a country of concern by the Secretary of State.
Sources: [1] Required Disclosures of Foreign Affiliations or Relationships | SBIR

Important Note

The SBA’s current SBIR/STTR page says there are no additional countries of concern designated beyond the four listed countries. Do not assume the list has expanded unless the official page changes.

Process

  1. 1
    Check whether your application includes foreign ties or investment information

    The SBA says applicants for SBIR or STTR awards must disclose information about investment and foreign ties.

  2. 2
    Compare the facts against the official definition

    Use the SBA’s definition of a foreign country of concern and the current list on the page.

  3. 3
    Use the agency’s disclosure template and instructions

    The SBA says the Policy Directive now includes a common template and an appendix for Participating Agencies to collect the required disclosures.

  • SBIR/STTR applicants must disclose investment and foreign ties, according to the SBA.
  • The SBA says it amended the Policy Directive and added an appendix to support collection of those disclosures.
  • The current foreign-country-of-concern list on the page includes only the four named countries.
  • The SBA says there are no additional countries designated for SBIR and STTR purposes at this time.
Next Step

Sources & Citations

1. Required Disclosures of Foreign Affiliations or Relationships | SBIR [Link ↗](government site)Accessed 8/26/2026

Tags

#cybersecurity#government-oversight#SBIR#small business#STTR

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Review the official SBIR foreign disclosures page before submitting an application and confirm whether any required foreign-ties disclosures apply.