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
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
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.
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.
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.