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BIOSECURE Act Compliance Tracker

Implementation timeline, BCC list status, and affected entity tracking for the BIOSECURE Act (NDAA Section 851, enacted December 18, 2025). Updated weekly.

BIOSECURE Act Implementation Timeline

NDAA Section 851, signed December 18, 2025

7

months to BCC list

You are here
  1. Act Signed, Dec 18, 2025, Complete
  2. OMB Review, Q1–Q3 2026, In progress
  3. BCC List Due, Dec 2026, Next milestone, critical milestone
  4. FAR Amendment, 2027–2028, Projected
  5. Grandfather Expires, ~2033, Projected
  • Complete
  • In progress
  • Critical milestone
  • Projected
3 designated8 under pressure88 clear

Current phase: OMB Review. 7 months until the BCC list publication deadline.

STATUS
Enacted
NDAA Sec. 851
BCC LIST
Dec 2026
OMB publication
1260H ENTITIES
3
BGI, MGI, Complete Genomics
TRANSITION PERIOD
~2033
Grandfather period expires

Implementation Timeline

Each milestone is marked by its status — completed, current phase, the next hard deadline, or an estimated projection — shown as both an icon and a label.

  1. December 18, 2025Completed

    BIOSECURE Act Signed Into Law

    Enacted as NDAA Section 851. Directs OMB to identify Biotechnology Companies of Concern (BCCs).

  2. Q1–Q3 2026Current phase

    OMB Interagency Review

    OMB conducts review to identify BCCs across three categories. No public comment period required by statute. Industry lobbying active.

  3. December 2026Next deadline

    BCC List Publication Deadline

    OMB must publish the official Biotechnology Companies of Concern list. This is the trigger event for all downstream restrictions.

  4. 2027–2028 (Est.)Estimated

    FAR Amendments Published

    Federal Acquisition Regulation amendments implementing BIOSECURE contracting prohibitions. Rulemaking process typically takes 12–18 months.

  5. Post-FAR (Est. 2028)Estimated

    Federal Procurement Restrictions Take Effect

    New federal contracts with designated BCCs prohibited. Existing contracts enter wind-down period per OMB specifications.

  6. ~2033 (Est.)Estimated

    Grandfathering Period Expires

    Five-year transition period for pre-existing contracts concludes. Full restrictions in effect for all federal contracting.

Entity Status Tracker

Current BCC designation status for key Chinese biotech entities. The enacted BIOSECURE Act does NOT name specific companies. It establishes a process-based identification system through three categories. View detailed company profiles →

  • Designated / 1260H
  • Under pressure
  • Monitoring
BGI Genomics华大基因
On 1260H List

Listed on DoD Section 1260H list. Probable BCC designation under Category A of the Act.

MGI Tech华大智造
On 1260H List

BGI subsidiary. Listed on DoD Section 1260H list. Probable BCC under Category A and Category C (subsidiary of BGI).

Complete Genomics
Subsidiary of BGI

BGI subsidiary. Probable BCC under Category C (subsidiary/successor of 1260H entity).

WuXi AppTec无锡药明康德
Under Congressional Pressure

Central to BIOSECURE legislative debate but NOT on 1260H list. Not formally designated as BCC. Status depends on OMB Category B review. Corporate restructuring underway.

WuXi Biologics无锡药明生物
Under Congressional Pressure

Affiliated with WuXi AppTec. NOT on 1260H list. Not formally designated. Potential BCC under Category B or C depending on OMB determination.

WuXi XDC
Monitoring

WuXi subsidiary focused on ADC manufacturing. Status depends on parent company determination.

BCC Designation Categories

Category A — 1260H List Entities

Entities already on the DoD Section 1260H list that are involved in biotechnology. Currently: BGI Group entities.

Category B — OMB Interagency Process

Entities designated through the OMB interagency review based on national security criteria. This is the pathway for WuXi entities if designated.

Category C — Subsidiaries, Parents & Successors

Subsidiaries, parent companies, and successor entities of Category A and B entities. This captures corporate restructuring designed to evade designation.

Practical Implications

Act now

BGI / MGI / Complete Genomics contracts

These entities are on the DoD 1260H list and are near-certain BCC designees. Federal contracting organizations should begin mapping alternative providers. The transition period allows time, but planning should start now.

Monitor

WuXi AppTec / WuXi Biologics

WuXi is NOT currently designated as a BCC. No formal prohibition applies. The OMB Category B review determines its status. Monitoring OMB activity and tracking corporate restructuring progress is the appropriate response.

Not restricted

Cross-border licensing transactions

The BIOSECURE Act restricts federal procurement, not private commercial licensing. Licensing therapeutics from Chinese biotechs remains permissible. Supply-chain risk and pipeline access are separate questions.

Map exposure

Federal grant recipients

Secondary restrictions may extend the Act's reach to federal grant recipients. Organizations receiving NIH, DoD, or other federal funding should map exposure to BCC-designated entities across all funded programs.

This tracker provides informational analysis only. It is not legal advice. Consult qualified legal counsel for specific compliance decisions. Last updated: June 2026.