Live Tracker
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
- Act Signed, Dec 18, 2025, Complete
- OMB Review, Q1–Q3 2026, In progress
- BCC List Due, Dec 2026, Next milestone, critical milestone
- FAR Amendment, 2027–2028, Projected
- Grandfather Expires, ~2033, Projected
- Complete
- In progress
- Critical milestone
- Projected
Current phase: OMB Review. 7 months until the BCC list publication deadline.
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.
- December 18, 2025Completed
BIOSECURE Act Signed Into Law
Enacted as NDAA Section 851. Directs OMB to identify Biotechnology Companies of Concern (BCCs).
- 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.
- 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.
- 2027–2028 (Est.)Estimated
FAR Amendments Published
Federal Acquisition Regulation amendments implementing BIOSECURE contracting prohibitions. Rulemaking process typically takes 12–18 months.
- 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.
- ~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
Listed on DoD Section 1260H list. Probable BCC designation under Category A of the Act.
BGI subsidiary. Listed on DoD Section 1260H list. Probable BCC under Category A and Category C (subsidiary of BGI).
BGI subsidiary. Probable BCC under Category C (subsidiary/successor of 1260H entity).
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.
Affiliated with WuXi AppTec. NOT on 1260H list. Not formally designated. Potential BCC under Category B or C depending on OMB determination.
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
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.
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.
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.
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.