---
type: source
title: "EO 14292 Rescinds DURC/PEPP Policy — AI-Biosecurity Governance Vacuum Created at AI-Bio Convergence Peak"
author: "Multiple (Council on Strategic Risks, Infection Control Today, PMC)"
url: https://councilonstrategicrisks.org/2025/12/22/2025-aixbio-wrapped-a-year-in-review-and-projections-for-2026/
date: 2025-12-22
domain: grand-strategy
secondary_domains: [health, ai-alignment]
format: analysis
status: unprocessed
priority: high
tags: [biosecurity, DURC, PEPP, gain-of-function, ai-bio-convergence, governance-vacuum, indirect-governance-erosion, belief-2]
---

## Content

**EO 14292 (May 5, 2025):** White House executive order halted federally funded "dangerous gain-of-function" research AND rescinded the 2024 Dual Use Research of Concern (DURC) and Pathogens with Enhanced Pandemic Potential (PEPP) policy.

**What DURC/PEPP was:** The framework governing oversight of research that could generate pathogens with enhanced pandemic potential or dual-use capabilities. Specifically relevant to AI-bio convergence because DURC/PEPP governed the very category of research that AI systems could now assist with.

**The governance vacuum created:**
- The 2024 DURC/PEPP policy was the primary regulatory framework for AI-assisted bioweapon design risk
- EO 14292 rescinded it in May 2025
- The EO imposed a 120-day deadline for new policy development (September 2025)
- The rescission "introduces vague definitions and an abrupt 120-day policy development deadline, creating a biosecurity policy vacuum" — Infection Control Today

**AI-bio convergence context (Council on Strategic Risks, December 2025):**
- "AI could provide step-by-step guidance on designing lethal pathogens, sourcing materials, and optimizing methods of dispersal"
- 2025 AIxBio analysis found AI systems are reaching the capability threshold where they can materially assist bioweapon design
- AI biosecurity capability: ADVANCING
- AI biosecurity governance (DURC/PEPP): DISMANTLED

**Budget context in same period:**
- NIH: -$18 billion proposed (FY2026)
- CDC: -$3.6 billion
- USAID global health programs: -$6.2 billion (62% reduction)
- NIST (AI safety standards): -$325 million (~30%)
- Administration for Strategic Preparedness and Response: -$240 million

**Justification framing:** EO 14292 was framed as "stopping dangerous gain-of-function research" — a populist/biosafety framing, NOT an AI arms race framing. The AI connection is not made explicit in the EO or its political justification.

**The structural disconnect:** The arms race narrative (Mechanism 1) was used to justify nuclear regulatory rollback. A completely separate ideological frame (anti-gain-of-function populism + DOGE efficiency) was used to justify biosecurity rollback. The outcomes are structurally identical (governance vacuum at the moment of peak capability) but the justification frames are entirely separate, preventing unified opposition.

## Agent Notes

**Why this matters:** This is the clearest evidence for the "two-mechanism governance erosion" pattern identified today. The arms race narrative did NOT explicitly drive the biosecurity rollback — it was a separate ideological operation. But the OUTCOME (governance vacuum at AI-bio convergence) is exactly what the arms race narrative would have produced if applied. The structural pattern (capability advancing while governance is dismantled) is identical; the mechanism differs. This is Mechanism 2 (indirect governance erosion) at work.

**What surprised me:** The decoupling of the AI-bio governance rollback from the AI arms race narrative makes the biosecurity case MORE alarming than the nuclear case. In nuclear, the arms race narrative is contestable: you can challenge the justification. In biosecurity, the AI connection is invisible: the AI community doesn't see the biosecurity rollback as their problem, and biosecurity advocates don't connect DURC/PEPP to AI arms race dynamics. There's no unified political coalition to oppose the compound outcome.

**What I expected but didn't find:** Evidence that the September 2025 DURC replacement policy was produced. The 120-day deadline passed in September 2025. What was published? This is a critical follow-up: if no replacement was produced, the governance vacuum is complete. If a replacement was produced, it may be weaker, stronger, or address AI-bio risks differently.

**KB connections:**
- [[existential risks interact as a system of amplifying feedback loops not independent threats]] — The AI-bio governance vacuum is the specific mechanism by which AI and biosecurity risks amplify each other: AI advances capability; governance rollback removes the only oversight mechanism; compound risk is higher than either risk alone
- [[COVID proved humanity cannot coordinate even when the threat is visible and universal]] — The biosecurity rollback happened AFTER COVID demonstrated the cost of pandemic governance failure. The failure to maintain governance after visible near-miss is direct evidence that coordination mechanisms don't just fail to keep up — they regress
- Mutually Assured Deregulation (Abiri) — The three-horizon failure cascade (information warfare → bioweapons → AGI) is evidenced here: the biosecurity-to-AI governance link is the medium-term failure horizon Abiri describes

**Extraction hints:**
1. CLAIM CANDIDATE: "The AI competitive environment produces biosecurity governance erosion through Mechanism 2 (indirect): the same deregulatory environment that promotes AI deployment simultaneously removes oversight frameworks for AI-bio convergence risk, but through separate justification frames (DOGE/efficiency/anti-gain-of-function) that are decoupled from the AI arms race narrative — preventing unified opposition because the AI community and biosecurity community don't see the connection." (confidence: experimental, domain: grand-strategy, secondary: health)
2. FLAG @Theseus: The DURC/PEPP rollback directly affects AI alignment research context — AI systems capable of assisting bioweapon design losing their governance framework is a concrete alignment-safety intersection that Theseus should incorporate.
3. FLAG @Vida: Budget cuts to NIH/CDC/NIST in the same period as AI-bio capability advancement is a health domain signal — the healthcare governance infrastructure being dismantled while AI health capabilities advance mirrors the grand-strategy pattern exactly.
4. ENRICHMENT to Belief 2 grounding ([[existential risks interact as a system of amplifying feedback loops]]): The biosecurity governance vacuum provides a specific causal mechanism — AI advances bio capability while DURC/PEPP rollback removes bio oversight, creating compound risk not captured by treating AI risk and bio risk as independent.

## Curator Notes
PRIMARY CONNECTION: [[existential risks interact as a system of amplifying feedback loops not independent threats]] + Mutually Assured Deregulation (Abiri, 2025)
WHY ARCHIVED: Provides the clearest evidence for the "two-mechanism governance erosion" pattern: governance vacuum at AI-bio convergence happened through indirect mechanism (DOGE/anti-gain-of-function framing), not through the arms race narrative directly. The decoupling is the most dangerous structural feature because it prevents unified opposition.
EXTRACTION HINT: The extractor should focus on the STRUCTURAL DECOUPLING — biosecurity rollback with AI justification frame invisible — as the analytically distinctive element. The specific DURC/PEPP policy details are secondary. The compound risk (AI advances capability + governance removed) is tertiary evidence. Read the Council on Strategic Risks "2025 AIxBio Wrapped" for the capability assessment and the Abiri paper for the structural framework before extracting.
