Round 4 Frequently Asked Questions

NTIA news 28 July 2026 37 min read

SYusko@ntia.gov

Tue, 07/28/2026 - 15:06

Innovation Fund Round 4 (2026) AI Native Telecommunications

This page contains Frequently Asked Questions (FAQs) intended to clarify and provide guidance on information in the Innovation Fund’s fourth Notice of Funding Opportunity (NOFO), published on July 14, 2026. Further questions may be submitted to InnovationFund@ntia.gov for consideration to include in future updates to this list.

Please note: Due to NTIA’s upcoming transition to a new grants management system, NTIA cannot extend the application period beyond September 9, 2026 at 11:59 p.m. ET.

The below FAQs are for informational purposes only and are intended solely to assist potential applicants in better understanding the National Telecommunications and Information Administration (NTIA) Public Wireless Supply Chain Innovation Fund and the application requirements set forth in the NOFO. The FAQs do not and are not intended to supersede, modify, or otherwise alter applicable statutory or regulatory requirements, or the specific application requirements set forth in the NOFO. In all cases, statutory and regulatory mandates, and the requirements set forth in the NOFO, shall prevail over any inconsistencies contained in the below FAQs.

Public Wireless Supply Chain Innovation Fund

Frequently asked Questions

Section Header

General program questions

General

What is the Public Wireless Supply Chain Innovation Fund?

The Innovation Fund is a 10-year competitive grant program authorized under 47 U.S.C. § 906, administered by the National Telecommunications and Information Administration (NTIA). The fund aims to drive wireless innovation, foster competition, encourage the export of U.S. AI technology, and strengthen 5G and successor wireless technology supply chains. It will also help unlock opportunities for companies from the U.S. and its global allies to compete in a market historically dominated by a few suppliers, including high-risk suppliers that raise security concerns.

The Innovation Fund aims to facilitate the adoption of open and interoperable wireless networks by:

Promoting and deploying technology, including software, hardware, and microprocessing technology, that will enhance competitiveness in 5G and successor wireless technology supply chains that use open and interoperable interface RAN.
Accelerating commercial deployments of open interface standards-based compatible, interoperable equipment.
Promoting and deploying compatibility of new 5G equipment with future open standards-based, interoperable equipment.
Managing integration of multi-vendor network environments.
Identifying objective criteria to define equipment as compliant with open standards for multi-vendor network equipment interoperability.
Promoting and deploying security features enhancing the integrity and availability of equipment in multi-vendor networks.
Promoting and deploying network function virtualization to facilitate multi-vendor interoperability and a more diverse vendor market.

Can I apply for and receive funds under the AI RAN NOFO if I received funds under a previous Innovation Fund NOFO?

Yes. Please see Section 2.2.1.2 Past Award Recipients of the NOFO for more information.

How can I get my questions answered?

Since the Innovation Fund is a competitive grant program, NTIA encourages stakeholders, including potential applicants, to gain additional information about the program through the following channels:

Check the Innovation Fund webpage regularly for more information. NTIA will post program updates and frequently asked questions there.
If you have specific questions about the Innovation Fund program or the NOFO requirements, you can email your questions to the Innovation Fund team. NTIA will provide written responses and will also publicly post the questions and answers under the FAQs on the Innovation Fund website.

NTIA will not host or accept individual meetings specific to the AI RAN NOFO during the open application period due to the competitive nature of the grant program.

Do solutions developed under the AI RAN NOFO have to be tied to results or outputs from the first and second NOFOs?

No. Although it is not a requirement for solutions under the AI RAN NOFO to be dependent upon outputs from the first and second NOFOs, the Innovation Fund program is designed to build upon the research and development (R&D) and testing and evaluation (T&E) aspects of the first NOFO and the radio unit (RU) commercialization and innovation aspects of the second NOFO. It is recommended that applicants consider how their solution may leverage outputs from the first NOFO (e.g., usage of T&E facilities) and second NOFO (e.g., usage of developed open RUs) and communicate any linkage in their proposals.

How is the Innovation Fund incorporating external perspectives into their funding strategies and NOFO development?

We know stakeholder input is critical to the successful implementation of the Innovation Fund. This latest NOFO incorporates feedback from NTIA's most recent listening session held on March 23, 2026 as well as other modes of industry engagement and ongoing market analysis. Please see Section 1.3 Public Input Received of the NOFO for more information.

A video recording of the March 23, 2026 listening session can be found on NTIA's website.

Will NTIA provide any platform or event for applicants to connect and form solution teams for project collaboration?

The Innovation Fund Program will host an Industry Day event in the near future, during which in-person participants will be able to connect and network. At this time, no additional programming for NOFO 4 is scheduled. If additional programming is added, we will announce that and other programmatic updates on the Innovation Fund website.

Section Header

Application requirements and deadlines

General Application Requirements & Information

When is the deadline to apply?

Complete applications must be received through Grants.gov no later than 11:59 p.m. Eastern Time on September 9, 2026. Grants.gov will no longer accept applications starting at 12:00am on September 10, 2026. Complete applications or portions thereof submitted by postal mail, courier, email, or by facsimile will not be accepted/considered. All application forms and documents must be included with an applicant's complete application packet submission through Grants.gov.

When developing the submission timeline, each applicant should keep in mind that: (a) all applicants are required to have current registrations in SAM.gov; and (b) the registration process in SAM.gov may take weeks. Please note that a federal assistance award cannot be issued if the designated recipient's registration in SAM.gov is not current at the time of the award. Application period extensions will not be provided due to delayed SAM registration.

What accounts and registration are needed to submit applications electronically?

Each applicant will need a Unique Entity Identifier (UEI), registration with the System for Award Management (SAM), and an account with Grants.gov.

Please note that the UEI is replacing the Dun & Bradstreet Data Universal Numbering System (DUNS) number.

What is the purpose of Form SF-328 and which information is required for submission?

Grants.gov, the website where Innovation Fund applications are submitted, provides applicants 24/7 support via the toll-free number 1-800-518-4726 and email at support@grants.gov. For questions related to the specific grant opportunity, email InnovationFund@ntia.gov.

If you are experiencing difficulties with your submission, it is best to call the Grants.gov Support Center and get a ticket number. The Support Center ticket number will assist NTIA with tracking your issue and understanding background information on the issue.

If an applicant is registered to lobby under the Lobbying Disclosure Act, is the SF-LLL lobbying disclosure form required?

Yes.

Is there a way to revise an application submitted before the deadline or does an applicant have to completely resubmit the application to make changes?

The applicant must submit a changed or corrected application to Grants.gov. Please note that changes made after the deadline will not be considered. The steps to submit a changed or corrected application through Grants.gov are the following:

Access completed application forms and make any needed corrections. The Workspace AOR or Workspace owner must reopen the Workspace to edit forms.
Check the "Changed/Corrected Application" box in item #1 of the SF 424 form.
Provide the Grants.gov tracking number (e.g., GRANT12345678) in 5b. Federal Award Identifier field.
Save the changed or corrected application once all corrections are made.
Submit the changed or corrected application to Grants.gov (done by the AOR). Note: On the sign and submit pop-up window, applicants will be asked the question, "Is this a changed/corrected application?" and have an option to select "Yes" or "No". If an application is being re-submitted using the same workspace, the "Yes" option will be selected by default and the grant tracking number from the previous submission will be listed.
Track the changed or corrected application through Grants.gov.

More information can also be found on the Grants.gov Related Submissions help page.

I am trying to attach my Project Narrative, but I do not know how to do it. Can you please provide guidance?

Please see Section 5.1 of the NOFO for guidance on how to submit and upload application materials.

We would like to request a copy of the Individual PDF forms in Workspace but have not been able to download them. Could you please share the Individual PDF form with us?

All forms can be downloaded directly from the Grants.gov Grant Forms page.

What notice should I expect to receive if my application was successful? If it was unsuccessful?

NTIA anticipates announcing awards on a rolling basis beginning Fall 2026. Please refer to Section 7.2.1 of the NOFO for additional information regarding unsuccessful application notifications.

Should applicants use SF-424 version 2 or version 4?

Applicants should use SF-424 version 4.

What is the Federal Entity Identifier required by Question 5a in Form SF-424? Is that number assigned through the Workspace or does this not apply to this program?

The Federal Entity Identifier field 5a does not apply to this program.

Is this program subject to Executive Order 12372, as asked by Question 19 of Form SF-424?

The Innovation Fund is not subject to EO 12372.

Which forms do applicants need to complete pertaining to lobbying activity?

All applicants must complete form CD-511, "Certification Regarding Lobbying." Applicants do not need to complete other forms (i.e., SF-LLL) unless they engage in individual lobbying or have an external lobbyist work on their behalf to lobby the Innovation Fund program.

Does Question 14 on Form SF-424 apply to this program? If so, are there more specific instructions on which sort of areas should be included in response to Question 14?

This data element is intended to indicate the project's place(s) of performance. Please attach a Project/Performance Site Location(s) Form (PDF), available on Grants.gov.

For the purposes of application number limitations, who is considered the applicant or eligible entity?

The applicant is the lead entity, i.e., the organization submitting the application package on Grants.gov using a unique SAM registration. The applicant is not the principal investigator (PI). As noted in the Executive Summary of the NOFO, each applicant may submit a maximum of one (1) application. Please refer to Section 2.2 of the NOFO for additional eligibility requirements.

Does NTIA consider the principal investigator (PI) the applicant?

The applicant is not the PI. The applicant is the entity, i.e., the organization submitting the application package on Grants.gov using a unique SAM registration.

Our organization registered with SAM.gov and obtained a UEI, but our partners are not registered. Is it required that partners also register with SAM.gov?

NTIA only requires the eligible entity applying for project funding under the AI RAN NOFO to be registered with SAM.gov and have a UEI. For all applications, all partners need to provide either a SAM UEI or a completed SF-328 (see Section 5.1.1(l) of the NOFO). Note, however, that any recipient or subrecipient that receives Federal funding will need a UEI before receiving those funds.

What is the Build America, Buy America Act (BABA) and how do I know if it applies to my proposed project?

The Build America, Buy America Act (BABA) was enacted as part of the Infrastructure Investment and Jobs Act §§70901-70927, Pub. L. No. 117-58 (2021). BABA is aimed at promoting the use of American-made products and materials in federally funded infrastructure projects. BABA requires all iron, steel, manufactured products, and construction materials used in federally funded infrastructure projects to be produced in the United States. BABA applies to non-Federal entities that construct, alter, maintain, or repair infrastructure as part of their project. The term "non-federal entities" is defined to include States, local governments, territories, Indian tribes, Institutions of Higher Education, and nonprofit organizations. The term "infrastructure" only encompasses projects that will serve a public function. It is NTIA's expectation that BABA requirements will not apply to most applicants.

If you think BABA might apply to your project, please contact the Innovation Fund for more information.

Further details on BABA requirements and implementation can be found in the BABA statute (PDF), the Code of Federal Regulations, and guidance issued by the Office of Management and Budget (OMB).

The NOFO says applicants will have up to seven (7) calendar days to submit information responsive to the feedback provided by NTIA. What if a federal holiday falls within the seven-day window?

Applicants will have up to seven (7) calendar days from the date that the curing notification email was sent to resolve deficiencies, unless extended by NTIA. Additional days may be added to account for federal holidays falling within the seven (7) calendar day window.

The NOFO states, "Any new facility or equipment costs, including software and services, should be itemized, and justified." Should this information be included in the Project Narrative, or does this instruction refer to the Budget Narrative and Justification?

Itemization and justification of new facility or equipment costs, including software and services, should be included both in your Project Narrative and in your Budget Narrative and Justification spreadsheet.

The Project Narrative should include a detailed description of the facilities, equipment, software, and services required for your project, and should explain how these items are essential to achieving project objectives. This helps demonstrate the necessity of these resources and their direct relevance to the proposed activities. Section 4.9 of the NOFO provides instructions for including information regarding facilities and equipment in the Project Narrative.

The Budget Narrative and Justification spreadsheet should include itemized costs for these and other items, including specific figures and an explanation regarding why the requested amounts are necessary for the project. This explanation allows reviewers to assess the reasonableness and appropriateness of the proposed expenses. Section 5.1.1(g) of the NOFO provides detailed instructions for the Budget Narrative and Justification. Be sure to follow these guidelines carefully when determining the appropriate category for each cost.

Including information in both sections of your application will help ensure reviewers have a clear understanding of the resources required for your project and how they align with the objectives and scope of the NOFO.

What information in the application will be considered confidential and not reported publicly? How do we identify that information in the submission?

Please refer to Section 8.2.9 of the NOFO for guidance on confidential information. Information or data the applicant deems as confidential commercial information or that otherwise should not be publicly disclosed should be "identified, bracketed, and marked as privileged, confidential, commercial or financial information." NTIA will protect confidential and proprietary information from public disclosure consistent with applicable laws. However, if a project is selected for funding, the executive summary may be used by NTIA in award announcement materials and posted on the public NTIA.gov website; therefore, applicants should ensure that no proprietary or business confidential information is included in the executive summary.

Given that applications could include intellectual property (IP) from participating entities, does NTIA expect each participating entity to have read the complete application?

NTIA expects participants to read all sections of the application that pertain to their roles, responsibilities, and commitments. A participant is not required to read sections that include another participant's IP, unless those parts also pertain to the first participant's roles, responsibilities, and commitments.

Section 5.1.1 (m) asks for resumes of key personnel involved in the project and restricts the number of resumes provided to five. How does NTIA define “key personnel”? What should we do if there are more than five key personnel?

"Key personnel" refers to the five people who are most actively involved in or responsible for executing project activities. These are roles such as Authorized Organizational Representative (AOR), Principal Investigator / Program or Project Director (PI/PD) or any other recipient-defined Key Personnel that are essential to completing the project. NTIA will only accept resumes of five key personnel, even if the applicant has identified more than five key personnel.

Awards, budgets and allowable costs

How many awards does NTIA anticipate funding?

The program has not set a minimum or maximum number of awards. We are looking to fund high quality and innovative projects that demonstrate the ability to add value to the marketplace.

Does cost share count towards the award ceiling?

No, the award ceiling is only associated with the federal share (i.e., award size) and not the total project cost (i.e., the combined total of the federal share and non-federal share of costs).

For example, if a project's total cost is $60,000,000, with $25,000,000 in federal funds and $35,000,000 in cost share, the $50,000,000 cap only applies to federal funds. This is allowable because the $25,000,000 federal share (i.e., award size) does not exceed the statutory limit of $50,000,000.

Can you confirm that indirect costs are allowable charges under this NOFO? I see in the NOFO that an applicant can use its indirect costs as part of its cost share, and the NOFO discusses indirect costs for the budget.

Indirect Costs are allowable costs under the NOFO, and they can be included in the federal award. Indirect Costs based on a negotiated indirect cost rate agreement (NICRA) can also be included as part of an applicant's cost share; however, applicants using the de minimis rate cannot use indirect costs as part of their cost share. If you are including indirect costs in your proposed budget, you must either provide a copy of your approved NICRA with your cognizant Federal agency or provide a statement that you are electing to charge a de minimis rate of up to 15 percent of modified total direct costs, pursuant to 2 C.F.R. § 200.414(f). Please see Section 5.1.1 (g) of the NOFO and 2 C.F.R. § 200.414 for more information.

How should applicants calculate the cost of fringe benefits?

Please refer to 2 C.F.R. § 200.431.

Is there any NTIA guidance on what type of travel rates are allowable costs under the NOFO?

Please refer to 2 C.F.R. § 200.475.

Are software licenses an allowable cost? If so, what is the mechanism for valuation?

Yes, software licenses are an allowable cost as long as they are reasonable, allocable, and necessary in line with the NOFO 4 requirements. Applicants should document the basis of the cost through quotes or other similar means of demonstrating free and open competition and best value.

If an applicant elects to use an indirect cost rate greater than the de minimis rate outlined in 2 C.F.R. § 200.414(f) and does not have an indirect cost rate agreement with a cognizant Federal audit agency, then would the applicant be allowed to establish this rate after submitting an application?

Per term B.06 the Department of Commerce (DOC) General Terms and Conditions, an applicant can use a provisional rate (greater than the de minimis rate of up to 15% of modified total direct costs) on their application and then submit documentation to NIST within 90 calendar days of the award start date to negotiate an indirect cost rate agreement. The applicant would need to determine what their cognizant Federal Agency would be.

With respect to for-profit organizations, the term cognizant Federal agency generally is defined as the agency that provides the largest dollar amount of negotiated contracts, including options. See 48 C.F.R. § 42.003. If the only Federal funds received by a commercial organization are DOC award funds, then DOC becomes the cognizant Federal agency for indirect cost negotiations.

If DOC is not the cognizant agency and the applicant is using a facilities and administrative (F&A) rate greater than the de minimis rate outlined in 2 C.F.R. § 200.414, the applicant must provide a copy of a negotiated rate agreement, or a copy of the transmittal letter submitted to the cognizant agency requesting a negotiated rate agreement within 30 calendar days of receipt of a negotiated rate agreement or submission of a negotiated rate proposal.

If the recipient fails to submit required documentation to NIST within 90 calendar days of the award start date, the NIST Grants Office may amend the award to preclude the recovery of any indirect costs under the award. In addition, the NIST Grants Office will include an Indirect Cost Special Award Condition (SAC) in all the awards providing submission guidance if NIST is the cognizant agency.

Note that technical assistance will be provided to recipients post-award on how to handle specific allowable costs, budgets, and other questions specific to their grant.

We have a large 5G lab facility with network simulators, SDN and NFV infrastructure, testbeds, and so on. Can this be listed as an in-kind contribution? If so, can we list both materials and installation costs? This is already in place so we would not be adding future construction costs.

Existing facilities and equipment, such as a 5G lab, may be listed as an in-kind contribution. Costs related to acquisition and installation of equipment may only be used as an in-kind contribution if they are expended during the period of performance of the grant award under this NOFO. Similarly, costs related to using the equipment may also be listed as an in-kind contribution. However, if the equipment is used for both activities under this NOFO and for other purposes, only the portion proportional to its use for NOFO-related activities can be included in the match. Note that if the equipment was paid for by another Federal grant or other Federal funding source (e.g., Contract, Cooperative Agreement, donation of surplus equipment, etc.), it cannot be considered for a matching contribution. Please refer to 2 C.F.R. § 200.306 for additional compliance requirements and information regarding cost share.

Please clarify the distinction between contracts and subawards. Is it correct that funding provided through contracts is not subject to the requirement for full cost accounting but must be supported by official quotes?

A subaward subjects the subrecipient to the same terms and conditions as the direct recipient and it requires the direct recipient to oversee the subrecipients' activities to ensure they are reasonable and allowable. A subaward is typically used when the subaward entity will be substantially conducting or contributing to direct grant funded activities. A contract is used to purchase services and goods but does not subject the vendor to the applicable terms and conditions of the award. Awardees should document the basis of contract awards through official quotes or other similar means of demonstrating free and open competition and best value. Please see 2 C.F.R. § 200.331 for procurement/contract requirements.

Will applicants receive bonus points for additional cost share provided above the minimum requirement?

Applicants may contribute additional cost share above the minimum requirement but will not receive bonus points in Merit Review or Programmatic Review for doing so. However, for applications that include a higher cost share than the minimum required, the cost share may be considered as a component of the relative cost effectiveness of an application and may be used by the Selecting Official as a factor in making award decisions. Please be advised that cost share, whether cash or in-kind, must be for costs allowable under PWSCIF and expended within the period of performance, and expenditures must be reported semi-annually in the Federal Financial Report (FFR/SF-425).

Can a contractor/vendor on a project provide cost share as part of a submission?

Contractors, vendors, subrecipients and other partners can provide cost share as long as they are eligible entities per Section 2.2.1 of the NOFO. However, if the cost share is a result of a federal grant or other federal funding source (e.g., Contract, Cooperative Agreement, donation of surplus equipment, etc.), it cannot be considered for a matching contribution, unless the authority for that funding contains an explicit exception. Please refer to 2 C.F.R. § 200.306 for additional compliance requirements and information regarding cost share.

Can we regard labor expenses of existing employees as an in-kind investment to the extent hours are tracked?

Labor expenses may be counted as a cost share so long as they meet the requirements outlined in 2 CFR 200.306, including that they be verifiable in the recipient's records and be necessary and reasonable for achieving the objectives funded by the Innovation Fund award.

If any pre-existing software solutions are used as part of the overall execution plan, can fair market cost of the same software be treated as cost share?

Pre-existing software solutions used as part of the overall execution plan may be included as an in-kind contribution to the extent that the costs associated with the software were expended during the award's period of performance and are necessary and reasonable for achieving the objectives of the Federal award. This applies to both costs related to acquisition and installation of the software, as well as costs associated with using, maintaining, or updating the software. If the software is used for activities under this NOFO and for other purposes, only the portion of costs proportional to its use for NOFO-related activities can be included in the match. Note that if the software was paid for by another Federal grant or other Federal funding source (e.g., Contract, Cooperative Agreement, donation, etc.), it cannot be considered for a matching contribution. Please refer to 2 C.F.R. § 200.306 for additional compliance requirements and information regarding cost share.

Is there any discount or elimination of cost share requirements for universities and non-profit organizations?

All applicants, including universities and non-profit organizations, are required to meet the cost share requirements outlined in Section 2.2.4. of the NOFO.

What is the estimated timeline between grant award and the start of grant-funded work?

When an award is issued, the award documentation will include a period of performance start date. Recipients should not begin implementing their award before that date. All costs for activities undertaken prior to the start of the period of performance are incurred at the recipient's own risk, unless the recipient has received written approval from the NIST Grants Officer.

Section Header

Administrative & National Policy Requirements

Section 8.2.4 of the NOFO requires recipients to hold property in trust for the beneficiaries of the project. What does this mean in practical terms? Will grant recipients be required to give money back? Are there any tax implications of the trust relationship?

Any real property, equipment, or intangible property acquired with federal funds must be used for the purpose intended in the grant program throughout its useful life, even after the grant period of performance has expired.

For example, if a piece of equipment with a useful life of 10 years is purchased with federal funds to facilitate proposed activities in accordance with the NOFO, then that equipment must continue to be used for that purpose for the full 10 years, even if the grant expired after five (5) years. However, if the entity shuts down their proposed activities in accordance with the NOFO at the end of five (5) years, the entity will have to repurpose the equipment for other federally-sponsored activities or request disposition instructions from NTIA. Recipients may mitigate this by only allocating a proportion of the costs to the grant.

Please note, if a piece of equipment is purchased with the intention of using it for grant-related purposes and other non-grant related purposes, only the portion of the equipment used for grant purposes can be charged to the grant or used as a cost share. See 2 C.F.R. § 200.313(c)(1) and (e) for additional information about equipment use and disposition. For additional information on real property use and disposition, see 2 C.F.R. § 200.311(b) and (d), and for intangible property, please see 2 C.F.R. § 200.315.

What is the invoicing structure for the performers of this grant?

Grant funding will be available for reimbursement through an automated drawdown system as costs are incurred. Advances are limited to the minimum amounts necessary to meet immediate disbursement needs, but in no case should exceed the amount of cash required for a 30-day period. Funds drawn down in advance through ASAP must be kept in an interest-bearing account and be spent within three (3) business days. Supporting documentation (invoices, timesheets, etc.) for the drawdown amounts must be maintained by the recipient and is subject to audit and monitoring by the government.

My project will not involve construction. Am I required to include Environmental and Historic Preservation (EHP) and National Environmental Policy Act (NEPA) information in my application?

No. Applicants are required to include EHP and NEPA information in their applications only if the proposed project involves construction and/or ground disturbing activities. Per Section 5.1.1(g)(7) of the NOFO, construction costs are *not*allowed under this NOFO. Please refer to Section 8.2.13 of the NOFO for information regarding EHP and NEPA compliance when such activities are involved.

Section Header

Eligibility, Period of Performance, & Place of Performance

The eligibility section requires applicants to be capable of “developing and commercially selling and/or deploying” a solution. What specific documentation or evidence does NTIA expect applicants to provide to demonstrate this capability?

As described in Section 4.7 of the NOFO, applicants must include in their Project Narrative an explanation of how they are qualified to develop and commercially sell and/or deploy a solution that leverages a secure compute environment to enable native AI capabilities in the RAN. As part of this explanation, applicants are asked to provide examples of past success of relevant products. NTIA is particularly interested in evidence that the applicant has successfully scaled and commercially sold a solution broadly across geographic regions and customer bases. In addition to concrete examples of past experience, NTIA expects applicants to describe how their financial, human, and other resources will enable it to develop, scale and sell an AI-native solution as described in the NOFO.

Are only U.S. entities eligible to apply for and receive funding under the AI RAN NOFO?

The applicant must be organized under the laws of the United States or a State thereof, with its principal place of business in the United States. All participants (which include subrecipients, contractors, and any other funded or unfunded entity other than the applicant) may be organized under the laws of a foreign jurisdiction and have their principal place of business outside the United States. Please see Section 2.2 of the NOFO for more information regarding eligibility requirements.

Are all China-based companies presumed to be a “foreign entity of concern” and therefore ineligible to apply for funding or participate in grant activities under the AI RAN NOFO?

An entity is considered a "foreign entity of concern" if it meets the criteria in 15 U.S.C. § 4651(8) and 15 C.F.R. § 231.104, subject to any further rulemaking promulgated by the U.S. Department of Commerce. Any applicant, sub-applicant, participant, contractor, consultant, or other entity that is owned or controlled by a foreign entity of concern is ineligible to receive funds under the AI RAN NOFO.

Are there specific citizenship requirements for individuals working in the U.S.?

No, as long as the individual is eligible to work in the United States and is not an ineligible participant (see Section 2.2.2).

Are government agencies or government-affiliated organizations, such as government-funded research labs or Federally Funded R&D Centers (FFRDC), eligible to receive grants and participate in grant-funded activities?

Government-affiliated entities may be eligible to receive grants and participate in grant-funded activities under the AI RAN NOFO, if they meet the eligibility requirements in Section 2.2.1 and are not listed as an ineligible entity in Section 2.2.2. In accordance with 31 U.S.C. § 6304, federal grants are generally required to carry out a public purpose of support or stimulation and are not to be used to perform work for the direct benefit of the United States Government. As such, any costs for work where the principal beneficiary is one or more U.S. Government agencies are unallowable (e.g., work to develop a prototype that only meets the requirements of a single U.S. Government agency).

However, costs related to work where the U.S. Government is an indirect beneficiary are allowable. For example, a prototype developed for the commercial market that also may be used by U.S. Government customers. Any determination of the principal beneficiary is at the sole discretion of NTIA.

Can any development of the hardware prototype and beta-level software, such as testing, happen outside of the U.S.?

No, all project activities shall take place in the United States, its territories, and possessions. NTIA may elect to waive this requirement for certain field demonstration activities if presented with compelling evidence that such activities would materially advance the objectives of the NOFO. Please see Section 2.2.6. of the NOFO for further information regarding place of performance requirements.

I am developing my own software product independent of my proposed NOFO 4 project (i.e., the development of the software is not directly related to the project), and I would like to use generic features from that product in my NOFO project while I continue to develop the product independently. Does NTIA require the development of the software product in this case to take place in the U.S.?

Per NOFO section 2.2.6, place of performance requirements apply only to project activities. Any activities that occur independently of the project are not subject to the place of performance requirement. To the extent an activity occurs independently of the project, costs incurred in furtherance of that independent activity would be considered ineligible, because the costs are not incurred specifically for the federal award.

Is it possible for a trusted foreign company to qualify as an “applicant” if it is “organized under the laws of the United States or a State thereof, with its principal place of business in the United States”?

In addition to requiring that the applicant be organized under the laws of the United States or a State thereof, with its principal place of business in the United States, Section 2.2.1 of the NOFO states that any subsidiary, affiliate, or branch whose ultimate parent entity is organized under the laws of a foreign jurisdiction or has its principal place of business outside the United States is ineligible to be an applicant.

Section Header

Letter of Commitment

Are all entities other than the applicant required to submit a Letter of Commitment?

As stated in Section 5.1.1 (l) of the NOFO, individual Letters of Commitment must be submitted by all funded and unfunded partners and subrecipients. Contractors are not required to submit Letters of Commitment.

Does NTIA expect the application to include one Letter of Commitment signed by all partners and subrecipients, or does NTIA expect each partner and subrecipient to submit their own Letter of Commitment?

NTIA expects each partner and subrecipient to submit their own Letter of Commitment, including all elements as stated in Section 5.1.1 (l).

Section Header

Partnerships

Are consortium applications allowed, and if so, how should roles and responsibilities be documented?

Applicants may choose whichever partnership structure they believe is best suited to achieve the goals of the NOFO, including forming a consortium, provided they meet all eligibility requirements. Per Section 5.1.1(l) of the NOFO, all funded and unfunded partners must submit Letters of Commitment that describe the partner's role in the project. Please see Appendix A – Glossary of Terms for NTIA's definition of "partner" in the context of the NOFO.

Are applicants permitted to add new partners post award if the scope evolves, or must all participants be finalized at application time?

Changes may be permitted post-award on a case-by-case basis. Recipients must submit a request for any change, and the Grants Specialist and FPO will assess whether the proposed change affects the timelines or scope of the originally approved application or project. All change requests must be approved or denied by the Grants Officer.

Are partners required to submit a memorandum of understanding or other legal partnership mechanism as part of the application? If not, and the application is selected for award, are partners required to provide a memorandum of understanding or other legal partnership mechanism to NTIA before or during the period of performance?

Partners are not required to submit a memorandum of understanding ( MOU) or other legal partnership documentation as part of the application. However, as part of their application, partners are required to submit Letters of Commitment that include a description of how the entity and applicant plan to formalize their partnership after receiving an award. Recipients will be required to provide formal documentation of the partnership, such as an MOU or Letter of Partnership Intent, after award.

Are subrecipients able to participate in more than one project?

Yes, subrecipients may participate in more than one project. However, both recipients and subrecipients need to ensure that there is no actual or apparent conflict of interest in such participation (see Section 8.2.20.1 of the NOFO regarding conflict of interest disclosures). This also applies to contractors or consultants.

Is it mandatory to write down the proportion (%) of federal funding used by each partner in our Letter of Commitment?

Yes, per Section 5.1.1 (l) of the NOFO, the Letter of Commitment must document the partner(s) proportion of federal funding, regardless of whether the partner(s) receives any funds (e.g., a partner receiving no federal funding would use 0% of the federal funding).

Section Header

Technical Requirements & Scope

Are there specific types of projects that NTIA is looking to fund?

NTIA does not define specific project type details and welcomes creative and innovative applications that meet the requirements of the NOFO.

How does NTIA define “AI-Native RAN” for the purposes of this NOFO? Is a partially AI-enabled RAN considered responsive?

Please see Appendix A – Glossary of Terms for NTIA's definition of "AI-Native RAN" in the context of this NOFO.

Is use of CBRS spectrum acceptable for prototype demonstrations?

Yes, prototype demonstrations may involve the use of CBRS spectrum.

Section 3 says projects funded under the NOFO may begin the period of performance (POP) at any technical maturity level. Will NTIA accept projects beginning at the basic research level?

While projects may begin the POP at any technical maturity level, applicants should keep in mind that NTIA will consider the entry level in evaluating the project's feasibility to achieve a scalable prototype within the POP.

What counts as an acceptable prototype demonstration?

Applicants must conduct a working demonstration of the service(s) defined in their business case via the proposed AI-native RAN solution in a mobile communications field environment. The demonstration must include simultaneous active AI workloads and active mobile communications workloads, and it must include the generation and collection of data necessary to confirm the business case projections. Please see Section 4.3 of the NOFO for field demonstration requirements.

Will NTIA require funded solutions to demonstrate adherence to open interfaces — e.g., O‑RAN–defined interfaces, vendor‑neutral abstraction layers, and standardized AI/ML lifecycle management — or will vertically integrated approaches be considered when they demonstrably strengthen U.S. competitiveness?

Per Section 4.2 of the NOFO, the minimal RAN network configuration to support the proposed solution shall, at a minimum, be compliant with 3GPP 5G NR Release 18 specifications and the latest releases of the O-RAN Alliance specifications per the March 2026 Specification Train (Release 5), as applicable to the proposed solution and prototype. If an applicant chooses to use a later 3GPP 5G NR release or O-RAN Alliance specification, it should be documented in the Project Narrative.

Are related standard development activities in scope for support? If so, in what form?

No, standard development activities are not within the scope of this NOFO.

Will applications that feature the planned use or development of open-source software receive extra points?

No. NTIA encourages, but does not require, the use or development of open-source software in the solutions developed under this NOFO including, but not limited to, Open Centralized Unit Distributed Unit (OCUDU) or other Open-Source RAN software.

Section 4.3 requires a field demonstration under specific conditions. Can the required field demonstration be conducted using a virtualized or emulated RAN environment if the applicant justifies that it accurately reflects real world deployment conditions?

No, field demonstrations may not be conducted using a virtualized or emulated RAN environment in lieu of a field environment. Per Section 4.3, the prototype must be demonstrated in a field environment that is the same as or very similar to the projected commercial deployments.

The field demonstration must take place in an environment similar to commercial deployments. Are private testbeds acceptable if their conditions approximate a commercial environment?

Yes, private testbeds are acceptable if the field demonstration meets the requirements in Section 4.3 and throughout the NOFO.

Does the AI Native Network Fabric have to adhere to a certain physical or logical structure?

It is at the discretion of the applicant to design the network as they deem appropriate to support the requirements of the NOFO, so long as the requirements of Section 4.2 of the NOFO (Description of AI-Native Network Fabric) are satisfied (e.g., the requirement that the fabric can process AI and telecom workloads simultaneously at any point in the network and support access to any required data).

Are backhaul solutions in scope for purposes of the NOFO?

Yes, backhaul solutions are in scope. Section 4.2 of the NOFO requires that the fabric can support both AI and telecom workloads simultaneously at any point in the network, and it defines Core functionality as a specific telecom workload to be supported. As Core functionality requires transport, backhaul would be considered part of that workload.

Are proposals required to use certain data sources?

The applicant is required to comply with 3GPP and ORAN standards which include any telecom workloads and relevant data. It is at the discretion of the applicant to identify any additional required data sources from within or outside the RAN.

Will open-source solutions be scored higher in the evaluation process than proprietary solutions?

No. PWSCIF encourages open-source solutions but does not require them or score them differently than proprietary submissions (see Section 1.3 of the NOFO).

How will the new AI Network Fabric be assessed for performance?

It is at the discretion of the applicant to define the performance measures and how they will be assessed. Metrics to be defined by the applicant should support all AI or RAN enabled processing necessary to actualize the associated business case.

The NOFO requires the demonstration to occur in a mobile telecom environment. How will NTIA assess the wireless stack functionality? Is a simple UDP datagram sufficient?

The level of detail of the field demonstration plans will be a component of the Merit Review process (see Section 7.1.2 (b) (2) of the NOFO). The applicant must clearly and credibly demonstrate the commercial viability, including export potential, of one or more service(s) uniquely enabled by the AI-native network fabric in accordance with NOFO Section 4.3, which includes a requirement for detailed plans for the prototype demonstration.

What types of AI workloads and use cases does NTIA view as most responsive to the NOFO objectives?

NTIA does not define specific project type details and welcomes creative and innovative applications that meet the requirements of the NOFO. It is at the discretion of the applicant to design the network as they deem appropriate to support the requirements of the NOFO. For example, the NOFO requires that the fabric can process AI and telecom workloads simultaneously at any point in the network and support access to any required data (see Section 4.2 of the NOFO for AI-Native Network Fabric requirements).

Are indoor, outdoor, commercial network, private network, and lab deployments evaluated differently?

NTIA will evaluate applications based on the criteria in Section 7.1.2 of the NOFO Additionally, applications may be prioritized as per Section 7.1.4 of the NOFO.

Within the Security Plan, is the expectation to deliver an assessment and migration plan for post-quantum cryptography, or a plan to implement quantum resistant algorithms within the design, or both?

Per Section 4.5 of the NOFO, projects are required to assess current cryptographic implementations and consider a migration plan to post-quantum cryptography. Applicants are not required to implement quantum resistant algorithms within the design or deliver a migration plan, but they must assess current implementations and consider a plan where applicable.

For the field trial, can grant funds be used for installation of the test network? Installation activities can be defined as installation of servers, attaching 5G antennas to existing structures, running power and fiber connectivity and other similar work.

Per Appendix A – Glossary of Terms in the NOFO, “construction” includes the construction, rehabilitation, alteration, conversion, extension, repair, or improvement of buildings, highways, or other real property. Temporarily affixing equipment to a tower or other property, or temporarily deploying equipment for the field demonstration, is not considered construction under the NOFO. Per Section 8.2.13 of the NOFO (Environmental and Historic Preservation), it is the applicant’s and subgrantee’s responsibility to obtain all federal, state, local, and Tribal permits, authorizations, and approvals necessary to conduct the proposed work.

For the field trial, can the trial cover two separate locations by two different customers that illustrate an AI-Network fabric for two different use cases?

Yes. Projects may only propose one AI-native network fabric, but the field demonstration may cover multiple locations, customers, and use cases.

Section Header

Business Case

Applicants must describe the “service value chain” in their business case. Should this include planned commercialization partners, or only conceptual actors in the ecosystem?

NTIA expects applicants to go beyond conceptual ideas in their business case. While we understand that applicants might not have contracts with commercial partners in place at the time of submission, NTIA expects applicants to identify specific entities when describing target customers and key players in the value chain. A strong business case will include concrete details about the marketplace to demonstrate the commercial viability of the proposed service(s).

Section Header

Funding, Use of Funds, & Costs

Are all parties, including the applicant and participants, required to share the cost share equally? Is the applicant required to contribute most of the cost share?

The cost share may come from the applicant and participants, including subrecipients, as long as they are eligible entities per Section 2.2 of the NOFO. The applicant and participants are not required to contribute an equal amount of the cost share, and the applicant is not required to contribute the majority of the cost share. However, applicants are ultimately responsible for ensuring the application meets the cost share requirement. Please note, if a project is awarded and one of the participants who provides cost share leaves the project, the applicant will be responsible for providing that cost share through their own resources or any other sources as long as they meet the above-mentioned requirements.

The NOFO states that construction costs are not allowed. Would temporarily affixing equipment to a tower for the field demonstration be considered construction?

Is a provisional indirect cost rate negotiated with another cognizant federal agency acceptable for use in the proposal budget, or does NTIA require a rate specifically negotiated with a cognizant agency recognized by Commerce?

Only one Federal agency should be the cognizant agency for indirect rates (2 CFR 200.1). The cognizant agency is typically the Federal department or agency that provides the largest dollar amount of direct federal funding or negotiated contracts to the organization. NTIA/NIST do not have the authority to choose cognizant agencies. Negotiated indirect cost rates must be accepted by all Federal agencies (2 CFR 200.414(c)(1)). If the rate agreement is in the process of negotiation and the rates are therefore provisional, NTIA/NIST must accept them, although the rate is subject to adjustment once the final or fixed rate has been negotiated with the cognizant agency.

If a provisional indirect cost rate negotiated with another cognizant federal agency is not directly acceptable, would the subrecipient be required to negotiate a new rate agreement with a cognizant federal audit agency prior to award, per Section B.06 of the Department of Commerce Financial Assistance General Terms and Conditions? If so, is there a process for doing so concurrently with, or shortly after, award rather than prior to proposal submission?

If a rate agreement is in the process of negotiation with another cognizant agency, and the provided rate is therefore provisional/temporary, NTIA/NIST will accept the provisional/temporary rate, subject to adjustment once the final or fixed rate has been negotiated with the cognizant agency. Subrecipients are subjected to the same requirements and restrictions as recipients.

Is there a mechanism to use an existing provisional cost rate negotiated with another cognizant federal agency for budgeting purposes at the proposal stage, with formalization of a Commerce-recognized rate to follow post-award?

NTIA/NIST would not dictate which agency is the correct cognizant agency, and would accept a provisional rate assuming it is currently being negotiated. If the recipient is using provisional rates, the established rates should be provided to NIST/NTIA (we recognize the rate establishment can take several months), and the rates should be reconciled after each fiscal year. Any provisional indirect cost rate is subject to adjustment once the final or fixed rate has been negotiated with the cognizant agency.

Should our financial projections be built from a customer (of our product) standpoint, or a product-building standpoint? Should the cost projections include revenue, internal product development cost, and cost of sales? Or should they cover revenue plus cost of sales, or another alternative?

As outlined in Section 4.4 of the NOFO, the business case must include a description of the target customer(s), while the cost projections and other pro forma financial projections included in the business case must support the commercial viability of the specific service set. As such, the cost projections should take product development and one or more target customers into account to demonstrate the revenue and/or cost savings sufficient to support the service set’s broad deployment.

Notice of Funding Opportunity

Waiver

Section header and content

Policy

Section Header and Content

Section Content

Microwave Spectrum FCC & policy Ownership & deals Towers Funding Market