The Pentagon's New Program to Help Companies Obtain a Facility Security Clearance

The U.S. Department of War (DOW or the Department) continues to expand the number of companies who can perform classified contracts. On August 18, 2026, the DOW's Defense Innovation Unit (DIU) publicly unveiled the Bridge Program, a new business unit within DIU's Strategic Initiatives Group (SIG). The Bridge Program targets some of the critical bottlenecks that have long frustrated commercial technology companies: facility security clearances and related access to classified spaces, technology accreditations and testing requirements. On September 24, 2026, the Bridge Program opened two pathways under its Classified Access to Address Technologies (CLASS ACT) program, which aims to help nontraditional entities with technical capabilities of interest to the DOW to obtain top secret clearances.

This comes on the heels of the Department's launch of the Secure Space Network, a new initiative to design, produce and deploy approximately 50 mobile Sensitive Compartmented Information Facilities.

This Holland & Knight alert provides an overview of the Bridge Program's structure and information on the CLASS ACT solicitation as a new on-ramp for commercial companies seeking to work with DIU. It also outlines how experienced legal counsel can help businesses navigate the regulatory complexities of the defense market.

What Is the DIU Bridge Program?

The Bridge Program was created to drive long-term, systemic reform across DOW. The program sits within DIU's SIG and uses DIU portfolio companies as a test bed to pilot technology-enabled solutions to the most significant challenges companies face after they are awarded a DOW contract. Its core purpose is to eliminate the barriers – security clearances, classified facility access, cyber accreditations, and test and evaluation requirements – that have historically prevented commercial firms from competing effectively in the defense marketplace.

Currently, Bridge Program services are offered only to DIU portfolio companies; however, DIU is actively working with partners across the Department to scale these solutions enterprise-wide.

How the Bridge Program Works

The Bridge Program operates as part of SIG and partners with a broad agency working group that includes:

• the Offices of the Under Secretaries of Defense for Intelligence and Security, Acquisition and Sustainment, and Research and Engineering
• the Defense Intelligence Agency
• the Defense Counterintelligence and Security Agency
• the U.S. armed services

DIU leverages Other Transaction Authority under 10 U.S.C. Section 4022 to award prototype agreements in as few as 60 to 90 days – a fraction of the time required under traditional procurement processes. After a successful prototype, the company and any DOW entity may enter a follow-on production contract, providing a clear pathway from prototype to procurement at scale.

The CLASS ACT Solicitation: A New On-Ramp to the Defense Market

The CLASS ACT is a pilot program (SAM Notice No. HQ084526SC002) issued under the Bridge Program. Born out of the fiscal year 2025 National Defense Authorization Act, which included a provision aimed at giving more nontraditional defense contractors access to facility clearances (FCLs), the program is intended to expand the bench of top-secret-cleared nontraditional entities with technical capabilities available to the DOW. The current CLASS ACT topic area targets countering unmanned systems in maritime environments.

According to the Solicitation, CLASS ACT "aims to support entities that a) do not have a facility clearance (FCL), b) meet the definition of a nontraditional defense contractor, and c) demonstrate they can provide capability and value to the DoW."

CLASS ACT will run for 36 months. During that period, DIU's Bridge Program will periodically release priority topic areas and accept submissions in the form of white papers of no more than five pages. The solicitation is issued under the authority of 10 U.S.C. Section 4022's pilot program provision and may result in a prototype Other Transaction Agreement (OTA), bailment agreement or combination of the two. (View guidance on negotiating intellectual property and data rights in OTAs.) If selected, CLASS ACT performers will be sponsored for a Top Secret (TS) FCL so they can interact with DOW personnel to understand classified challenges, treats, requirements and other information needed to deliver commercial capabilities to the government. The goal is for CLASS ACT participants to understand DOW requirements so they can leverage or adapt their capabilities to critical DOW needs.

Notably, DIU pledges to "coordinate industrial security support for each CLASS ACT performer to assist with navigating and completing the FCL process," and selected entities "should expect to receive a minimum of $2,500 for their efforts on a prototype OT award."

A critical distinction separating the CLASS ACT program from the requirements normally applicable to entities seeking an FCL is that CLASS ACT performers do not need to hold a DOW prime contract or subcontract. Traditionally, an agency or cleared prime contractor had to sponsor an entity for an eligibility determination as part of the contracting or performance process. 32 C.F.R. Section 117.9(10). Recognizing that this process "delay[s] the timelines to achieve a clearance and inhibit[s] the speed of the commercial solution" and that "it can take two years (or more) between when DoW decides to invest in a capability and when funding becomes available for acquisition," the CLASS ACT program is helping nontraditional defense contractors "with promising capabilities, ideas, or technology related to specific topic areas of interest to the DoW" obtain an FCL before a specific contracting requirement exists.

What DIU Is Seeking

For technology and capability providers, DIU will evaluate proposals based on the following criteria:

• Alignment. Whether the proposed technology or capability is aligned with the applicable topic area.
• Maturity. The capability must have reached at least Technology Readiness Level (TRL) 7, meaning it has been tested in an operational environment, and the company must have raised at least $10 million in equity financing.
• Company Viability. The company must have booked annual revenues of at least $2 million and must not be backed by adversarial capital.
• National Security Traction. The company must either have been awarded recent Federal Acquisition Regulation (FAR) or non-FAR-based instruments – such as prototype agreements, Small Business Innovation Research (SBIR) solicitations or task orders – with DOW components or other participants in the national security ecosystem or participated in government-sponsored exercises or test events where the government sponsor collected performance data.

For investors, DIU will evaluate proposals based on the following criteria:

• Dry Powder. The investor must have at least $100 million of available capital to invest from non-adversarial capital sources.
• Investment Alignment. The investor must demonstrate a track record of making investments in the co-listed topic area and have an average investment size of at leat $5 million in companies that enable U.S. national security.

One interesting point: DIU explicitly announced in the Solicitation that it "may utilize artificial intelligence (AI) tools, machine-learning software, and automated data processing systems" in reviewing applications.

What CLASS ACT Does for Businesses

CLASS ACT includes two topic areas.

Topic Area 1: Technology Companies (Sensors and Effectors)

 For companies developing sensors and effectors to counter unmanned systems in maritime environments, DIU is expanding the availability of TS-cleared nontraditional defense contractors providing sensors (passive and active) and effectors to defeat adversarial unmanned systems (UxV) in and around maritime environments. Of specific interest are long-range (60 kilometers-plus) passive detection, assured active detection and tracking of swarms (hundreds of UxVs at distances greater than 5 km) with emphasis on Group 3 systems, and effectors that lower the cost per kill.

Eligibility Requirements for Technology Companies: Companies must not have a current or previously held facility clearance, qualify as a nontraditional defense contractor, offer a sensor or effector, have a solution at TRL 7 or higher, have raised at least $10 million in equity financing, have booked annual revenue of $2 million or more, not be backed by adversarial capital and have key management personnel who are U.S. citizens. Pursuant to 10 U.S.C. Section 3014, a "nontraditional defense contractor" is an entity that is not currently performing and "has not performed, for at least the one-year period preceding the solicitation, any DOW contract or subcontract that is subject to full coverage under the cost accounting standards (beginning October 1, 2026, $100 million or more)."

Topic Area 2: Investors

For private capital firms with investment experience in technologies related to countering unmanned systems in maritime environments. When private capital providers understand the DOW's most pressing challenges, capital can be deployed to enable technologists to develop, mature and commercialize capabilities important to the DOW.

Eligibility Requirements for Investors: Investors must not have a current or previously held facility clearance, qualify as a nontraditional government contractor, demonstrate investment experience in relevant technologies, have at least $100 million in available capital to invest that is not from adversarial sources, have an average investment size of $5 million in companies enabling U.S. national security and have key management personnel who are U.S. citizens.

Any Prototype OT agreement awarded may result in the direct award of a follow-on production contract without further competitive procedures under 10 U.S.C. Section 4022(f).

How to Get Involved

• The CLASS ACT opportunity is available on SAM.gov.
• Companies must be registered in SAM.gov and have a Commercial and Government Entity (CAGE) code.
• FCL preparation: Before applying to CLASS ACT, offerors must review the DSCA FCL Orientation Handbook and 32 C.F.R. Part 117, the National Industrial Security Program Operating Manual (NISPOM), to ensure they understand the process and requirements for obtaining and maintaining an FCL.
• DIU will respond within 30 days if interested. If selected, companies negotiate prototype contract terms.
• Responses are due soon: October 13, 2026.

For guidance on competing for a CLASS Act award or advice on FCL and NISPOM requirements, please contract the authors. Holland & Knight's Government Contracts Group has extensive experience guiding commercial technology companies through the regulatory landscape for defense contracting, including cybersecurity requirements, negotiating favorable terms in OT agreements and positioning companies for success in working with DIU and the broader DOW. Whether your company is new to government contracting or seeking to scale an existing defense relationship, Holland & Knight can provide strategic legal counsel to take full advantage of the opportunities presented by the DIU Bridge Program.

Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.