On May 5, 2025, President Trump issued Executive Order 14292 ("Improving the Safety and Security of Biological Research"), which significantly altered ( in words only) the U.S. federal oversight process for gain-of-function (GOF) and pathogen enhancement research.

Status as of Late 2025/Early 2026

On the surface sound great.

The reality in 2026?

Not much changed as the pathogen 🦠 work continues . The only main change included end of the GOF work funding overseas… As of available information (into early 2026), the revised OSTP policy had not yet been fully issued or implemented 🤷‍♂️. Institutions continued operating under prior frameworks where applicable, with pauses on covered "dangerous GOF" work. Some agencies (e.g., NIH, USDA) conducted portfolio reviews and enforced suspensions.

In summary, the process shifted from a scheduled expansion of structured, institution-driven DURC/PEPP reviews (2024 policy) to an immediate pause on high-risk "dangerous GOF," in words only but the the policy is NOT even issued or implemented

a push for stricter federal oversight/enforcement/transparency, restrictions on foreign collaborations, and development of a more top-down framework remain an empty facade.

Pre-2025 Context (Leading Up to May 2025)

The 2017 HHS P3CO Framework (Potential Pandemic Pathogen Care and Oversight) provided guidance for reviewing research that could create or use "enhanced potential pandemic pathogens" (ePPPs), following a 2014 funding pause on certain GOF work.

In May 2024, OSTP released the U.S. Government Policy for Oversight of Dual Use Research of Concern and Pathogens with Enhanced Pandemic Potential (DURC/PEPP Policy). This consolidated prior DURC policies (2012/2014) and the P3CO framework. It introduced two categories of research requiring additional review/assessment at the proposal stage:

• Category 1: Focused on specific agents/toxins and experimental outcomes.
• Category 2: Broader, covering pathogens with enhanced pandemic potential.

It was set to take effect on May 6, 2025, expanding the scope of agents (e.g., to ~91), requiring PI/institutional/federal assessments, risk mitigation plans, and pre-funding reviews.

Key Changes from the May 5, 2025 Executive Order The EO paused implementation of the 2024 DURC/PEPP policy and directed a revision or replacement.BUT again, no new OSTP policy regarding biological pathogen enhancement research is issued or implemented as of now in may 2026.

Immediate Pause/Suspension

Federally funded "dangerous gain-of-function research" (broadly defined as work on infectious agents/toxins that enhances pathogenicity, transmissibility, or other harmful traits with potential for significant societal consequences) was to be suspended until a new policy is in place. Agencies (e.g., NIH) issued notices to review portfolios, terminate/suspend relevant projects, and rescind prior implementation guidance.

Ban on Funding in Certain Foreign Settings: Ends federal funding for such research by foreign entities in "countries of concern" (e.g., China) or places lacking adequate U.S.-equivalent oversight. Extends to other life sciences research posing threats.

The EO uses a specific "dangerous gain-of-function" definition emphasizing outcomes like enhanced harm, transmissibility, immune evasion, etc