Introduction: The Executive Order on Ensuring American Space Superiority
On December 18, 2025, President Trump issued an Executive Order titled “Ensuring American Space Superiority.”[i] The Order establishes four major priorities for the Federal Government’s space policy. To achieve these priorities, the President directed the Secretary of Commerce and the NASA Administrator to, within 180 days, reform their space acquisition processes to support the priorities in this Executive Order, and to use their existing authorities to improve efficiencies and expedite space acquisitions, including establishing a “general preference” for the use of Other Transaction Authorities (OTAs) and Space Act Agreements.
Modernizing Defense Acquisitions and Promoting Innovation
Recall that on April 9, 2025, President Trump issued Executive Order 14265 directing the Department of Defense/War (DoD) to utilize existing authorities to expedite acquisitions throughout the Department, including endorsing as a “general preference” the use OTAs for DoD acquisitions to promote streamlined acquisitions.[ii]
In my December 2, 2025, blog, titled “Using OTAs — Opportunities but Uncertainties,” [iii] I provided background information on OTAs and how DoD was planning to increase the use of OTAs, noting that the SECDEF’s November 10, 2025, “Acquisition Transformation Strategy” called on the department to maximize flexible contracting by promoting the use of OTAs. But I cautioned then that with the new opportunities comes risks and uncertainties that can diminish their value or fail to bring the anticipated results.
DoD/DoW Use of OTAs for the Golden Dome Initiative
While the DoD/DoW has the broadest statutory authority for the use of OTAs for various types of acquisitions and leads the government in the dollar value of OTA awards, overall federal spending through OTAs has, to date, been relatively small. That may change this federal fiscal year, largely due to the awards related to the Golden Dome initiative and implementation of President Trump’s space policy.
On Dec. 2, the Missile Defense Agency (MDA) announced the first tranche of awards to over 1,014 companies[iv] for the “Scalable Homeland Innovative Enterprise Layered Defense (SHIELD),” which is a major program aimed at revolutionizing America’s missile defense capabilities through next-generation technologies and innovative approaches. MDA subsequently announced a second grouping,[v] and then a third grouping,[vi] bringing the total number of SHIELD awards to over 2,400, with a combined estimated total value of $151 billion.[vii]
Space Force Implementation: SBI Contracts and Kinetic Interceptors
On December 6, 2025, U.S. Space Force announced the award of eighteen contracts for the space-based interceptor (SBI) technology portion of the Golden Dome program, all identified as using DoD’s OTA authority. And according to other press reports, in November 2025, U.S. Space Force awarded an undisclosed number of prototype SBI contracts, likely also using OTA techniques, but without disclosing the winning offerors or any details about the presumably classified work.
Finally, in early December 2025, U.S. Space Force issued, via SAM.gov, a pre-solicitation Request for Prototype Proposal (RPP)[viii] for kinetic midcourse interceptor solutions, with a February 2026 award date. According to that SAM.gov notice, “(t)his action is expected to result in multiple fixed-price Other Transaction Agreements in accordance with 10 USC 4022. In addition, the Government anticipates the awards may also incorporate Prize Competitions in accordance with 10 USC 4025.”
Conclusion: The Catalyst for Future Space Exploration
The use of OTA techniques is well suited to the technical and acquisition challenges of the Golden Dome and planned space exploration, and this Executive Order will certainly be a catalyst for OTAs’ increased use. But even in these domains, OTAs are still only a means to achieve results and must be used carefully and appropriately, with transparency and accountability for both government purchasers and competitors. I’ll be watching how Commerce and NASA reform their “space acquisition processes” and increase their reliance on the use of OTAs. DoD’s initiatives are already underway but could still use greater transparency.
[i] Executive Order 14369 of December 18, 2025, “ Ensuring American Space Superiority,” available at 2025-23845.pdf.
[ii] Executive Order 14265 of April 9, 2025, “Modernizing Defense Acquisitions and Spurring Innovation in the Defense Industrial Base,” available at 2025-06461.pdf.
[iii] Alan Chvotkin, December 2, 2025, blog “Using OTAs – Opportunities but Uncertainties,” available at Using OTAs – Opportunities but Uncertainties – Protorae Law.
[iv] GovWire: “MDA Awards Spots to Over 1,000 Contractors on $151B SHIELD Contract for Golden Dome,” December 3, 2025, available at MDA Issues First Awards Under $151B SHIELD Contract.
[v] Defense One, “Another 1,000 defense companies chosen for $151B Golden Dome competition, December 19, 2025, available at Another 1,000 defense companies chosen for $151B Golden Dome competition – Defense One.
[vi] Defense One, “Another 350 firms approved to bid on Golden Dome,” January 15, 2025, available at Another 340 firms approved to bid on Golden Dome work worth up to $151B – Defense One.
[vii] Defense One, “Another 1,000 defense companies chosen for $151B Golden Dome competition, December 19, 2025, available at Another 1,000 defense companies chosen for $151B Golden Dome competition – Defense One.
[viii] U.S. Space Force (USSF) Space Based Interceptor (SBI) Pre-solicitation notice for Prototype Proposal (RPP), December 19, 2025, available at SAM.gov.