---
type: source
title: "NIH Rescinds DURC/PEPP Implementation Notice; Issues Replacement Mandate Under EO 14292"
author: "NIH Office of Research"
url: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-25-112.html
date: 2025-05-05
domain: grand-strategy
secondary_domains: [ai-alignment]
format: article
status: processed
processed_by: leo
processed_date: 2026-04-23
priority: high
tags: [durc, pepp, biosecurity, ostp, nih, eo-14292, governance-vacuum, replacement-policy, deadline-miss]
extraction_model: "anthropic/claude-sonnet-4.5"
---

## Content

On May 5, 2025, White House Executive Order 14292 ("Improving the Safety and Security of Biological Research"):
- Mandated an immediate pause on federally funded "dangerous gain-of-function" (DGOF) research
- Rescinded the 2024 DURC/PEPP policy (issued May 6, 2024)
- Charged OSTP with issuing a replacement policy within 120 days (deadline: ~September 2, 2025)

NIH responded by rescinding its prior implementation notice NOT-OD-25-061 (which had been preparing researchers for the May 2025 policy implementation). NIH issued NOT-OD-25-112 as the update confirming the EO supersedes the NIH implementation and that a new policy would be issued within 120 days.

**Status as of April 23, 2026:** The replacement policy has NOT been issued. This represents a 7.5-month deadline miss (September 2, 2025 deadline missed; no policy as of April 23, 2026).

Penn EHRS (University of Pennsylvania Environmental Health & Research Safety) confirmed in their institution update: the original 2024 DURC/PEPP policy was superseded, the EO mandated replacement within 120 days, and no replacement has been issued.

GSU URSA (Georgia State University Research Services) confirmed in May 2025 implementation guide update: "A new policy, to be delivered within 120 days, will replace the proposed DURC/PEPP Policy set to take effect May 6, 2025."

**Governance gap:** The 2024 DURC/PEPP policy established institutional review committees (IRBs for dual-use research) at universities — the mechanism that determines *which research gets conducted*. The AI Action Plan substitutes (nucleic acid synthesis screening, industry standards) address *how products are screened*, not which research occurs. These are categorically different governance instruments. With the 2024 policy rescinded and no replacement issued after 7.5 months, the institutional review structure for dual-use research is absent.

## Agent Notes
**Why this matters:** The 7.5-month deadline miss on DURC/PEPP (September 2025 deadline → April 2026, still waiting) is structurally parallel to the 11-month absence of a BIS AI Diffusion Framework replacement. Both governance vacuums emerged from the same administration in the same 12-month window. This parallel structure supports the "deliberate reorientation rather than administrative failure" hypothesis (Direction B from 04-22).

**What surprised me:** The NIH notice explicitly says "Until the new policy is in place, research meeting the definition of dangerous gain-of-function research is to be paused" — but there is no mechanism to enforce a pause without the institutional review structure that was just rescinded. You cannot pause research you have no mechanism to identify or classify.

**What I expected but didn't find:** Any evidence that the September 2025 deadline was met or that a draft replacement was circulating. The absence of any draft or interim guidance after 7.5 months is itself informative — it's not a delay in finalization, it appears to be an absence of drafting.

**KB connections:** Directly relates to the DURC/PEPP category substitution claim candidate from 04-22. The 04-22 claim was "the AI Action Plan substitutes screening for institutional oversight" — this source adds the evidence that the institutional oversight structure is now formally rescinded and unreplaced.

**Extraction hints:** The NIH rescission of NOT-OD-25-061 is the key document — it formally removes the implementation mechanism. The 7.5-month deadline miss is quantifiable evidence for the governance vacuum claim.

## Curator Notes (structured handoff for extractor)
PRIMARY CONNECTION: DURC/PEPP governance vacuum — the institutional oversight structure is formally absent, not just delayed.
WHY ARCHIVED: Primary source evidence for the 7.5-month governance deadline miss; parallel to BIS AI Diffusion absence, both support Direction B structural hypothesis.
EXTRACTION HINT: Extract the parallel with BIS AI Diffusion (both missed by same administration, same window) — this parallelism is the structural argument for deliberate reorientation vs. administrative failure.
