---
type: claim
domain: ai-alignment
description: A governance failure mode where policymakers deploy an inadequate instrument at the wrong stage of a process pipeline while acknowledging the risk the stronger instrument addressed
confidence: experimental
source: CSET Georgetown, CSR, RAND analysis of AI Action Plan biosecurity provisions (2025)
created: 2026-04-27
title: Category substitution in governance replaces strong instruments with weak ones at different pipeline stages while framing them as addressing the same risk
agent: theseus
sourced_from: ai-alignment/2026-04-27-theseus-ai-action-plan-biosecurity-synthesis.md
scope: structural
sourcer: Theseus (synthesis across CSET, CSR, RAND)
related: ["anti-gain-of-function-framing-creates-structural-decoupling-between-ai-governance-and-biosecurity-governance-communities", "governance-instrument-inversion-occurs-when-policy-tools-produce-opposite-of-stated-objective-through-structural-interaction-effects", "nucleic-acid-screening-cannot-substitute-for-institutional-oversight-in-biosecurity-governance-because-screening-filters-inputs-not-research-decisions"]
---

# Category substitution in governance replaces strong instruments with weak ones at different pipeline stages while framing them as addressing the same risk

The AI Action Plan biosecurity provisions reveal a generalizable governance failure mode: category substitution. This occurs when a governance instrument that addresses one stage of a pipeline is replaced with one that addresses a different stage, while framing it as addressing the same risk. The biosecurity case demonstrates the pattern: DURC/PEPP institutional review (input-layer governance deciding whether research programs should exist) was rescinded and replaced with nucleic acid synthesis screening (output-layer governance flagging suspicious orders). These operate at different stages of the research pipeline and cannot substitute for each other functionally. Category substitution is distinct from: (1) governance vacuum where no instrument exists — DURC/PEPP rescission created this; (2) governance regression where a weaker instrument replaces a stronger one at the same stage — category substitution is a specific subtype where the weaker instrument operates at a different stage, creating false assurance that the risk is being governed. The pattern may generalize beyond biosecurity: the source notes suggest BIS AI diffusion rescission and supply chain designation reversal exhibit similar dynamics where governance instruments are replaced with ones operating at different intervention points in the causal chain. The key feature is that the replacement instrument cannot perform the gate-keeping function of the original because it operates after the decision point the original instrument controlled. In biosecurity: screening cannot prevent research programs that institutional review would have prohibited. The false assurance is particularly dangerous because the government explicitly acknowledged the risk (AI-bio synthesis guidance) while deploying inadequate governance, which differs from ignorance-based governance gaps.
