On November 5, 2026, the White House issued NSTM-6, a memorandum from National Security Advisor Marco Rubio and OSTP Director Michael J. Kratsios that attaches the National Policy for Nucleic Acid Synthesis Screening. The Policy conditions federal life sciences funding on buying synthetic nucleic acids and benchtop synthesis equipment only from “Adherent Suppliers”, and it sets a phase-in schedule that reaches customers in 2027. The NIH Office of Science Policy also flagged the release (NIH OSP). Everything below is drawn from the memorandum text (PDF on whitehouse.gov).
What the Policy says
The memorandum states that the Policy implements Executive Order 14292 (Improving the Safety and Security of Biological Research), replaces the 2024 Framework for Nucleic Acid Synthesis Screening, and on full implementation also replaces the 2023 HHS Screening Framework Guidance. It says existing guidance “has relied on self-attestation rather than independent verification”. Until full implementation, the Policy tells parties to keep drawing on the relevant portions of the 2023 HHS guidance, which stays in effect. For background on the executive order, see CASRAI’s earlier coverage: Executive Order 14292 and biological research security.
Who is covered
- Customers: all recipients and subrecipients of federal funds that procure synthetic nucleic acids or benchtop nucleic acid synthesis equipment. The memorandum describes this as applying to “all recipients of Federal life sciences funding”.
- Suppliers: providers, manufacturers and third-party vendors, expressly including core facilities, plus resellers of new and used benchtop equipment.
- Order size: the objective is to cover any order of 50 or more nucleotides, consistent with the 2023 HHS guidance baseline.
The Policy supplements, and does not replace, export controls, the Biological Select Agents and Toxins regulations, and the U.S. Government Policy for Stopping High-Risk Life Sciences Research (dated July 20, 2026).
Implementation schedule
Table 1 of the Policy counts days from release of the Policy (day 0). The calendar dates below are CASRAI’s arithmetic assuming day 0 is November 5, 2026; the Policy itself gives day counts, so confirm dates against agency notices.
| Step (per Table 1) | Day | Approx. date |
|---|---|---|
| NIST issues screening standards, benchtop equipment standards, and screening test and evaluation protocols | 90 | February 3, 2027 |
| NIST begins testing and verifying screeners and maintaining a list of verified screeners | 100 | February 13, 2027 |
| HHS publishes the initial list of Adherent Suppliers | 160 | April 14, 2027 |
| Customers procure all synthetic nucleic acids through Adherent Suppliers | 250 | July 13, 2027 |
| Customers procure all benchtop equipment through Adherent Suppliers | 340 | October 11, 2027 |
The Policy says implementation starts immediately on publication, but the funding-term requirements below apply from the date of full implementation in Table 1.
What suppliers must do to be “Adherent”
- Submit every in-scope order to a screener verified by NIST, and not rely on an unverified screener.
- Run know-your-customer (KYC) checks at onboarding, with periodic re-verification, covering identity, institutional affiliation, foreign affiliation and the legitimacy of the stated use.
- Report flagged orders to appropriate federal authorities (the Policy names the FBI, Commerce and BIS as possibilities).
- Retain screening and order records, and customer interactions, for no less than 8 years, and provide them to NIST and federal authorities on lawful request.
The supplier keeps final say over whether to fulfil or deny an order; a screening determination does not itself authorise or refuse fulfilment.
Benchtop synthesizers
Control is enforced at the equipment. Tier 1 (the default) is networked authorization: the unit starts synthesis only on a valid, unexpired authorization from a verified screener. Tier 2 is bounded offline operation, allowed only to the extent NIST verifies it against published standards. Manufacturers must supply equipment that keeps tamper-resistant records and synchronizes records and screening software at least quarterly. Manufacturers of obsolete equipment are encouraged to offer buy-back or trade-in.
What federally funded institutions need to do
The sections below combine what the Policy requires with CASRAI’s reading of what offices will need to prepare. The reading is editorial, not an agency instruction.
Procurement and purchasing
- The Policy requires customers to demonstrate that all synthetic nucleic acid purchases (by day 250) and all benchtop equipment purchases (by day 340) go through Adherent Suppliers. The first HHS list of Adherent Suppliers is due by day 160.
- Customers should give a supplier information sufficient to verify the legitimacy of an order under current NIST standards.
- Inventory current oligo, gene synthesis and synthesizer vendors, including core-facility and reseller channels, and flag any not likely to be listed. This is a practical suggestion rather than a stated requirement.
Biosafety and research compliance
- Funding agencies are to require record keeping for any procurement, receipt or exchange of sequences of concern or benchtop equipment, and to require that such transfers use a contractual or transactional agreement such as a material transfer agreement.
- At a minimum those agreements must bar exchanges with researchers in a Covered Nation or otherwise barred under the listed NDAA provisions and the entities of concern list, to the extent that information is public.
- Agencies are to include a term on intra-institutional sharing of synthetic nucleic acids between known individuals when sequences do not include a sequence of concern.
Sponsored programs and enforcement exposure
- Awards made before the Policy’s release can be covered: agencies are to establish common terms that apply to them on the date of full implementation.
- Compliance is to be treated as material to payment decisions for purposes of the False Claims Act (31 U.S.C. 3729(b)(4)).
- A violation by a funded individual may be treated as a violation by the employer or institution. Penalties may include immediate revocation of ongoing federal funding and ineligibility for up to 5 years.
- An agency head may grant a case-by-case exception for a health or national security mission, after consulting the President’s science and national security advisers.
What is not yet known
NIST standards, the screener list, the Adherent Supplier list, agency award terms and the standardized reporting procedures are all still to come. NIST’s role is stated as “subject to the availability of funding”. Institutions should watch NIST, HHS and their own funding agencies for notices and not treat day-count dates here as final.
Related reading
- AI-designed bacteriophages and the biosecurity screening gap
- Executive Order 14292 and biological research security
