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
8
months to BCC list
Act Signed
Dec 18, 2025
NDAA Sec 851
OMB Review
Q1–Q3 2026
Interagency BCC identification
BCC List Due
Dec 2026
OMB publishes official list
FAR Amendment
2027–2028
Procurement rules drafted
Grandfather Expires
~2033
Full restrictions in effect
Implementation Timeline
BIOSECURE Act Signed Into Law
Enacted as NDAA Section 851. Directs OMB to identify Biotechnology Companies of Concern (BCCs).
OMB Interagency Review
OMB conducts review to identify BCCs across three categories. No public comment period required by statute. Industry lobbying active.
BCC List Publication Deadline
OMB must publish the official Biotechnology Companies of Concern list. This is the trigger event for all downstream restrictions.
FAR Amendments Published
Federal Acquisition Regulation amendments implementing BIOSECURE contracting prohibitions. Rulemaking process typically takes 12–18 months.
Federal Procurement Restrictions Take Effect
New federal contracts with designated BCCs prohibited. Existing contracts enter wind-down period per OMB specifications.
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 →
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.
Need a BIOSECURE exposure assessment?
We map your supply chain exposure to potential BCCs through Chinese corporate registries — Using the same Tianyancha and GSXT data that institutional compliance teams rely on.
This tracker provides informational analysis only. It is not legal advice. Consult qualified legal counsel for specific compliance decisions. Last updated: May 2026.