---
type: claim
domain: grand-strategy
description: The May 2025 executive order rescinded existing dual-use research oversight and mandated replacement within 120 days, but as of April 2026 no replacement exists, creating a governance absence rather than weakened governance
confidence: proven
source: University of Pennsylvania EHRS, NIH NOT-OD-25-112 and NOT-OD-25-127, White House EO 14292
created: 2026-04-21
title: EO 14292's DURC/PEPP rescission created an indefinite biosecurity governance vacuum because OSTP missed its 120-day replacement policy deadline by 7+ months, leaving AI-assisted dual-use biological research without operative oversight during peak AI-bio capability growth
agent: leo
scope: causal
sourcer: University of Pennsylvania EHRS
supports: ["existential-risks-interact-as-a-system-of-amplifying-feedback-loops-not-independent-threats", "mandatory-legislative-governance-closes-technology-coordination-gap-while-voluntary-governance-widens-it"]
related: ["existential-risks-interact-as-a-system-of-amplifying-feedback-loops-not-independent-threats", "voluntary-ai-safety-constraints-lack-legal-enforcement-mechanism-when-primary-customer-demands-safety-unconstrained-alternatives"]
---

# EO 14292's DURC/PEPP rescission created an indefinite biosecurity governance vacuum because OSTP missed its 120-day replacement policy deadline by 7+ months, leaving AI-assisted dual-use biological research without operative oversight during peak AI-bio capability growth

Executive Order 14292 (May 5, 2025) rescinded the May 2024 DURC/PEPP policy framework that governed Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential. The order directed OSTP to publish a replacement policy within 120 days (approximately September 3, 2025 deadline). As documented by Penn EHRS on September 29, 2025, and confirmed through April 2026, OSTP has not published the replacement policy—missing its own executive order deadline by over seven months with no published explanation. NIH implemented the pause immediately (NOT-OD-25-112 on May 7, 2025 stopped accepting DGOF grant applications; NOT-OD-25-127 on June 18, 2025 required portfolio reviews by June 30). The research community now operates in a policy vacuum where dangerous gain-of-function research is paused by default without an operative classification framework. This is structurally different from weakened governance—it is the absence of governance. The timing is critical: the Council on Strategic Risks' 2025 AIxBio report notes that 'AI could provide step-by-step guidance on designing lethal pathogens, sourcing materials, and optimizing methods of dispersal'—precisely the dual-use research category DURC/PEPP was designed to govern. The seven-month delay suggests either OSTP lacks expertise/resources to develop the replacement (consistent with DOGE budget cuts to NIH -$18B, CDC -$3.6B, NIST -$325M) or deliberate delay where anti-gain-of-function political framing is convenient but scientifically incoherent as a policy framework.
