CHIPS R&D Office reshapes pathways for semiconductor R&D and investment: Key takeaways

The United States Department of Commerce’s CHIPS Research and Development Office (CRDO) has amended its Broad Agency Announcement (BAA), formally restructuring how federal semiconductor research and development (R&D) funding and related investments will be awarded.

The revised BAA establishes and integrates the newly reestablished National Semiconductor Technology Center (NSTC) and its Investment Fund. It also establishes two application pathways within its single solicitation.

While the core eligibility framework remains intact, the changes introduce greater agency discretion over funding priorities and signal an increased emphasis on commercialization, scale up, and domestic supply chain impact. Applicants are encouraged to reassess proposal strategy and positioning in light of the revised process.

In this alert, we discuss the two distinct operational paths of the amended BAA and provide key takeaways for funding applicants.

Background

The CHIPS for America program allocates approximately $11 billion to semiconductor R&D through CRDO. Since its launch in September 2025, the BAA has functioned as the primary vehicle for funding advanced microelectronics research, with applications accepted on a rolling basis through September 30, 2029, unless it is amended to close at an earlier date.

Proposals for research, prototyping, and commercial solutions that advance microelectronics technology in the US are expected to accelerate the pace of commercialization to enable technology dominance in the industries of the future – in areas including semiconductors, artificial intelligence, quantum, biotechnology, biomanufacturing technology, commercialization of innovations, and standards development.

Additionally, the CHIPS and Science Act directs the Department of Commerce to establish and capitalize an investment fund – in connection with the NSTC and in partnership with the private sector – to support startups and collaborations between startups, academia, established companies, and new ventures, with the goal of commercializing innovations that contribute to the domestic semiconductor ecosystem.

The April 20, 2026 amendment to the BAA to incorporate this requirement represents an evolution in implementation rather than an overhaul of the solicitation. It materially alters how proposals may be considered, advanced, and funded, and represents a broader reset of the NSTC.

Reestablishment of the NSTC

The NSTC, directed to be established under the CHIPS and Science Act to advance semiconductor research, prototyping, and workforce development, was originally operated by Natcast, a nonprofit entity created in 2023 to manage specific CHIPS funded R&D activities.

In August 2025, however, the Department of Commerce voided up to $7.4 billion in CHIPS funding that had been allocated to Natcast, terminated its agreement, and removed the nonprofit as operator of the NSTC, effectively canceling the consortium’s original governance model.

Following Natcast’s cancellation, the Department of Commerce transferred operational control of the NSTC directly to the National Institute of Standards and Technology (NIST), reincorporating the NSTC into the Department’s internal CHIPS R&D structure. Rather than functioning as an independent public–private consortium as was contemplated, the NSTC appears to be newly administered – at least in part – through Commerce managed funding mechanisms, including the revised BAA.

Methods of convening said consortium are not detailed at the outset, though the new NSTC Charter highlights its statutory authority, its charge to support domestic capabilities and accelerate commercialization, and its establishment of a Semiconductor Ecosystem Investment Fund.

Subsequent changes to the BAA

Two application paths under one framework

To operationalize the reestablished NSTC’s Semiconductor Ecosystem Investment Fund, the amended BAA now intends to operate through two distinct paths.

The R&D Project Path will continue to support traditional research, prototyping, and technology development activities, as was previously published.

On the other hand, the introduction of the Investment Fund Path, through which CRDO may make investment style awards via the NSTC, is aimed at commercializing innovations that strengthen the domestic semiconductor ecosystem, securing the semiconductor supply chain, and reducing reliance on foreign manufacturers to safeguard US national security. CRDO may use the Investment Fund Path to make awards that are investments in companies, rather than funding specific scientific R&D projects.

All funding requests must still be at least $10 million, regardless of the funding path identified. Applicants whose proposals advance within either pathway may be required to issue – and should anticipate issuing – equity, warrants, licenses to intellectual property, royalties or revenue sharing, or other such instruments as may be required to ensure a return on investment to the federal government.

Enhanced role of the White Paper

The White Paper stage has taken on increased importance with this revision. All applicants will continue to enter the process through the pre-established, mandatory White Paper submission, which is the same for the R&D Project Path and the Investment Fund Path.

However, as a result, applicants may not know at the outset whether their proposal will be considered and evaluated as a traditional R&D award or as an investment oriented opportunity. CRDO may invite applicants to proceed under one of the two paths or decline to advance the submission, at its discretion. Applicants are not empowered to identify which pathway they would like to be considered for; rather, CRDO will determine whether an application should be considered for the R&D Project Path or the Investment Fund Path based upon its evaluation of the White Paper. Entities that have already applied to the BAA and have a pending White Paper may be considered by CRDO for the Investment Fund Path without having to reapply.

Evaluation of submission

The revised BAA introduces an important divergence in evaluation emphasis between the two pathways beyond the initial assessment of eligibility, completeness, and responsiveness.

Under the R&D Project Path, proposals are assessed primarily on traditional criteria such as technical merit, scientific novelty, national security impact, alignment with CRDO research priorities, and the feasibility of proposed research and prototyping activities. These evaluation criteria have not changed since the initial publication of the BAA.

By contrast, proposals directed to the Investment Fund Path are evaluated through a more commercialization‑oriented lens, with greater weight placed on an applicant’s ability to spur innovation in the semiconductor ecosystem, transition technology toward deployment, strengthen the domestic semiconductor ecosystem, provide a positive return on investment for the government, and advance supply‑chain resilience and national security objectives.

While all submissions are initially screened under the same White Paper process, CRDO now exercises discretion to apply pathway‑specific evaluation considerations that extend beyond research excellence alone.

Key takeaways

The newly published NSTC Charter – which legally reestablished the NSTC – appears to be intentionally high‑level and structural rather than programmatic. It sets out statutory authority, administrative ownership, broad mission areas, and authorizes an Investment Fund, but it does not articulate specific technical thrusts, milestones, governance bodies, or membership obligations beyond general participation language at this time.

Much of the specificity that previously appeared in NSTC strategy documents has effectively been pushed downstream into discretionary instruments, such as the revised BAA, where programmatic direction can be adjusted as needed. CRDO stated that it anticipates releasing additional guidance on the activities of the NSTC in the future.

As the semiconductor ecosystem seeks to engage with the NSTC or its Investment Fund through the BAA, applicants are encouraged to draft White Papers that are strategically framed with flexibility in mind, anticipating both traditional R&D and commercialization focused evaluation.

Applicants can continue to assume heightened scrutiny of business models, deployment timelines, and domestic impact – not just technical merit. Applicants already planning submissions are encouraged to reassess positioning under the revised BAA and consider whether their proposals are resilient across both potential funding paths.

Conclusion

DLA Piper advises clients across the semiconductor, advanced manufacturing, and emerging technology sectors on the full lifecycle of CHIPS for America engagement.

With experience at the intersection of federal policy, national security, and advanced technology, DLA Piper helps clients navigate complexity, manage risk, and access federal investment opportunities.

For more information about CHIPS for America funding opportunities or to discuss how these developments may affect your business, please contact the author.