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.

chinabiointel.com

BIOSECURE Act Implementation Timeline

NDAA Section 851 — Signed December 18, 2025

10

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

You are here
3 designated|8 under pressure|88 clear
STATUS
Enacted
NDAA Sec. 851
BCC LIST
Dec 2026
OMB publication
1260H ENTITIES
3
BGI, MGI, Complete Genomics
COMPLIANCE TOOLS
0
As of March 2026

Implementation Timeline

December 18, 2025

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 2026

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 →

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.

What This Means for Your Organization

If you use BGI/MGI/Complete Genomics

Begin mapping alternative providers now. These entities are on the 1260H list and are near-certain BCC designees. Federal contracts involving these entities will be prohibited after the transition period.

If you use WuXi AppTec/Biologics

Develop contingency plans but do not panic. WuXi is NOT currently designated. The timeline allows for planning. Monitor OMB Category B review and congressional activity closely.

If you license from Chinese biotechs

BIOSECURE restricts federal contracting, not private commercial licensing. Licensing innovative therapeutics from Chinese companies is NOT prohibited. Separate supply-chain risk from pipeline access.

If you receive federal grants

Secondary restrictions could extend BIOSECURE's reach to federal grant recipients. Map your exposure to BCC-designated entities across all federally funded programs.

Need a BIOSECURE exposure assessment?

We map your supply chain exposure to potential BCCs through Chinese corporate registries — the same Tianyancha and GSXT data that compliance attorneys use at $800/hr.

Request Assessment

Get weekly BIOSECURE updates

China Biotech Weekly tracks BIOSECURE implementation, BCC list developments, and compliance deadlines every week.

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