Context

In June 2023, the UK Cabinet Office published an updated national BSS to replace the previous 2018 Biological Security Strategy. The updated BSS includes a high-level summary of the strategy’s implementation plan, outlining short, medium, and long-term commitments to facilitate the delivery of 15 priority BSS Outcomes.

In 2024, the BSS’s Lead Minister, the Chancellor of the Duchy of Lancaster, published a short written statement on BSS implementation one year in, and CLTR published an independent progress tracker. Our first-year key findings indicated that particular progress had been made in responsible innovation efforts (Outcome 5) and in activities to mitigate antimicrobial resistance (Outcome 7). However, more detail was required in the high-level implementation plan summary, progress on the National Biosurveillance Network (Outcome 9) was needed, and the Government had yet to develop biological event response plans set out in the BSS or conduct a national exercise at the time of our review.

Second-Year Progress Review

In the second year since the release of the 2023 BSS, there is evidence that UK Government departments have made tangible progress across several short-term commitments that build on their activities in the first year. It is worth noting that the strategy’s governance architecture—including a Coordination Unit in the Cabinet Office, a designated lead Senior Minister (the Chancellor of the Duchy of Lancaster), and Senior Responsible Officer (a deputy National Security Adviser)—represents a significant advance in structure over the 2018 strategy and provides a replicable model for wider cross-government strategic delivery.

Below, we list four priority BSS Outcomes (and their lead departments) that have achieved notable progress up to June 2025:

1. Outcome 1 – The Biothreats Radar (Cabinet Office)
2. Outcome 4 – Regular domestic and international exercising of our collective preparedness and defences to biological threats (Cabinet Office)
3. Outcome 5 – The UK is a leader in responsible innovation (Department for Science, Innovation and Technology [DSIT])
4. Outcome 11 – A strengthened microbial forensics capability (Ministry of Defence [MOD])

However, our independent review also identifies three areas requiring urgent attention: the continued lack of a sufficiently detailed public implementation plan; critical delays in delivering the National Biosurveillance Network (Outcome 9); and challenges in securing the sustained funding required for long-term capability development.

Notable Progress

Outcome 1 – The Biothreats Radar

The Biothreats Radar (BTR) is rightly placed as a flagship commitment of the BSS. It intends to “provide a comprehensive overview of high-priority biosecurity threats from across the world to support ministers’ and senior officials’ decision-making process” making use of open-source information and official threat assessments.

Led by the Cabinet Office, the BTR’s first iteration launched in May 2025, featuring event-based surveillance, real-time threat monitoring, and human health system capacity tracking—with plans to extend coverage to animal and plant health. The BTR was also showcased as a “capability spotlight presentation” at the Council on Strategic Risk’s Berlin Biosecurity Dialogue and at the University of Cambridge’s CSaP conference in June 2025, indicating it has progressed to the stage where select international experts may witness its functioning as well as apply lessons learned to similar national Biothreats Radar initiatives.

However, the BTR’s full operational capability is exposed to significant risk due to critical operational dependencies. The system is designed to integrate data streams from the NBN (Outcome 9). Given the ongoing delays to the NBN (see Recommendation 2), the BTR’s potential will be severely limited, as it will lack essential data feeds required for comprehensive threat analysis.

The Government’s 2025 BSS Implementation Report stated ambitions for the next twelve months also include “Operationalising the foundational capabilities for a National Biosurveillance Network in the National Situation Centre… to provide input to the new Biothreats Radar.” However, if the NBN fails to deliver within the next 12 months—which it currently shows signs of continued stall (see Recommendation 2)—it seems unlikely that the BTR can reach its full potential as it will lack essential NBN data streams.

We suggest that the BTR aims to reach its “initial operating capability” status in the next twelve months, and that the “full operating capability” status of the BTR is more clearly defined, accounting for NBN data feeds. See Recommendation 2 for more information.

Outcome 4 – Regular domestic and international exercising of our collective preparedness and defences to biological threats (CO)

Our 2024 assessment revealed that, based on public knowledge, no biological-event-related exercises had taken place between the release of the 2023 BSS and our assessment, and limited progress had been made in developing a roadmap to inform a “set of tested response plans”. In May 2024, the previous government’s lead minister for the strategy announced plans for a 2025 exercise. It remained to be seen whether the shortcomings identified in historical exercises and the government’s response to COVID-19, as outlined in the UK COVID-19 Inquiry’s module 1 findings, would be addressed.

In January 2025, the Cabinet Office confirmed: “The country’s preparation for future pandemics will be stepped up by the largest ever national response exercise due to be held in the Autumn.” We welcomed the Cabinet Office on confirming the Tier-1 level of Exercise Pegasus— a national-level exercise involving ministerial participation and the activation of Cabinet Office Briefing Rooms (COBR) across all four nations of the UK.

The key purpose of Exercise Pegasus is to simulate a realistic pandemic scenario in order to “assess the UK’s pandemic response capabilities more broadly across government,” and is the first of its kind in nearly a decade. Exercise Pegasus will test cross-government coordination, inequality considerations, information management, and scaling capabilities across all four UK nations between September and November 2025, covering three phases: emergence; containment; mitigation, with a fourth phase, ‘recovery’ set for 2026.

The comprehensive scope, from ministerial decision-making to local response capabilities, demonstrates that the government is taking important first steps to address critical weaknesses identified in the COVID-19 Inquiry and is committed to making the UK better prepared and more resilient to future potential biological events of pandemic-level scale and impact.

As stated in the 2025 Strategic Defence Review: “MOD will provide critical input to exercises and plans for renewed national resilience responses… The Cabinet Office-led Home Defence Programme will connect the country’s preparation for future bio-related threats and will be critical for the largest-ever UK pandemic response exercise scheduled for this Autumn.” With this in mind, the success of Exercise Pegasus will partially depend on the proper inclusion of relevant BSS outcomes capabilities (e.g., integrating the MOD-led UK microbial forensics capability and developing therapeutics and vaccines within 100 days).

The importance of generating post-exercise findings, lessons, and recommendations within the first few months, as recommended in the UK Covid-19 Inquiry module 1 report, cannot be overstated. Timely reporting will enable the implementation of action plans ahead of new exercises or a real event. The timely release of post-exercise reports, action plans and guidance will be critical for tracking progress and demonstrating improved UK pandemic preparedness, resilience and response capabilities.

Exercise Pegasus advances the Cabinet Office’s medium-term commitment to coordinated biosecurity exercises—a vital development important for national resilience. Regular exercising remains the best credible method for assessing preparedness capabilities and building the institutional trust and operational skills essential for effective crisis response.

Outcome 5 – The UK is a leader in responsible innovation

Our 2025 assessment reveals that the UK has taken numerous steps which demonstrate its commitment to leading in responsible innovation. However, there is still more work to do, especially in leveraging the biosecurity benefits of AI-enabled biological tools while mitigating their risks. Outcome 5 contained several initiatives, each discussed in turn below:

Synthetic Nucleic Acid Screening

In October 2024, DSIT published voluntary guidance for synthetic nucleic acid screening as part of a package of responsible innovation announcements, aimed at speeding up the safe acceleration of strategic technology use within the UK. This represents an important step, at the forefront of international efforts, towards mitigating the growing biosecurity risks presented by the misuse of this rapidly advancing technology while enabling and championing legitimate use. The BSS outlines the option to “put [synthesis screening] guidance on a statutory footing if it is deemed necessary and appropriate.” We believe that the net effect of doing so would be beneficial to the UK and the world, and encourage DSIT to further explore legislative and policy options for mandatory synthetic nucleic acid screening.

Biosecurity Leadership Council

Our 2024 review noted the formation of a UK Biosecurity Leadership Council to provide the government advice on emerging biosecurity risks. In January 2025, the Council was renamed the Engineering Biology Responsible Innovation Advisory Panel (RIAP)—a rebrand with a reduced scope and biosecurity removed from its stated terms of reference: “provides a two-way permanent feedback loop with UK industry/academia and government to support policy development for responsible innovation and biosecurity”. It is unclear whether and how the current government is receiving external, independent advice on biosecurity policy after this change.

AI and the Life Sciences

In January 2025, the UK Government also published its AI Opportunities Action Plan. This is a truly world-leading framework for seizing the benefits of AI, and it is notable that a U.S. AI Action Plan followed soon after. However, biology and the life sciences are mentioned only twice in the entire action plan, and it does not discuss how the UK can leverage AI to transform life sciences research and the economy, nor how to do so in a safe, secure, and responsible manner. Appointing an AI Sector Champion for the life sciences is sensible (Action 48), but likely does not go far enough by itself. We agree wholeheartedly that the Government should strategically steer the generation of future large-scale data collection efforts (Action 8)—and the recent OpenBind announcement is a first step—but there needs to be significantly more work on precisely defining where and how the UK should develop a strategic advantage and a greater recognition of the dual-use risks of some data generation. This can tie well within a broader focus on defensive acceleration.

Emerging Risks

Outcome 5 covered responsible innovation, including of anticipated developments that have occurred since the BSS release in 2023. In December 2024, an article in the journal Science detailed the concerns of several notable scientists on the creation of mirror life. In June 2025, the Government Office for Science published a Science Advice Note on the topic, representing the views of a panel of UK experts, including from CLTR, which convened in January 2025 to address the following question:

“What are the main risks and opportunities associated with researching and developing ‘mirror life’, including along the pathway of development from cell components to self-replicating cells?”

The note tackled a defining challenge for biosecurity governance: distinguishing between benign mirror components (therapeutic molecules, advanced materials) and potentially dangerous mirror organisms (self-replicating systems) under the catch-all “mirror life” label. This distinction is vital for proportionate regulation, as a blanket-ban approach may halt beneficial advances in therapeutics and materials, whilst targeted restrictions on self-replicating systems will help address credible biosecurity concerns. The note provides accessible science advice to help UK policymakers navigate this complex regulatory challenge and demonstrates clear UK leadership in responsible innovation, setting the tone for other nations to follow.

Regulatory Innovation Office

The UK has also set up a Regulatory Innovation Office (RIO), which the Secretary of State for Science Innovation and Technology announced in October 2024. The purpose of the RIO is to help position Britain as “the best place in the world to innovate by ensuring safety, speeding up regulatory decisions and providing clear direction in line with our modern industrial strategy”. Standing up as an office within DSIT, the RIO’s immediate focus will be on priority areas with significant potential to drive innovation in support of the Government’s mission to grow the economy, including engineering biology, a key technology domain relevant to the BSS. This initiative demonstrates a government-level recognition of the barriers to current economic growth and a commitment to put the UK at the forefront of responsible innovation.

Pandemic Agreement

When it comes to international leadership, the UK has helped lead negotiations on the landmark World Health Organisation (WHO) Pandemic Agreement adopted in May 2025, which aims to ensure equitable access to medical countermeasures and accelerate sample sharing under a new Pathogen Access and Benefit Sharing system. However, CLTR could not find any evidence of new progress made on the UK–U.S. Strategic Dialogue on Biological Security, which raises questions around which other bilateral and multilateral initiatives (WHO aside) the UK will lead on, in 2025-2026, to shape international, responsible innovation standards in the life sciences and biotechnology.

Outcome 11 – A Strengthened Microbial Forensics Capability

Outcome 11 is a One Health initiative, delivered by the MOD, which will strengthen the UK’s microbial forensic capabilities and “deter actors from using offensive weapons due to the severe repercussions if attributed to them”. It has demonstrated notable in-year progress, building on the previous year. In May 2024, the UK Microbial Forensics Consortium (UKMFC) held a bioinformatics workshop, “attended by over 20 leading bioinformaticians from all sectors and all UK nations” – marking “the first time bioinformaticians from government genomics laboratories have come together to consider the microbial forensics question”.

The UKMFC held its first in-person consortium event, opened by the Cabinet Office Parliamentary Secretary, in November 2024. This saw cross-sector representation from across UK government departments and agencies, as well as the U.S. Federal Bureau of Investigation and CLTR. Presentations from leaders in the microbial forensics and biosurveillance communities were delivered alongside a workshop activity to inform enhancements to future UKMFC capability. The consortium aims to “continue to develop microbial forensic analysis capability against a spectrum of threats (especially in the new era of synthetic biology)” and “be able to attribute the misuse of biological hazards and act as a deterrent to hostile use”.

In December 2024, a £1 million, MOD-funded, Defence and Security Accelerator (DASA) competition was launched: “Future-proofing Biosecurity by Strengthening the UK’s Microbial Forensic Capability,” seeking “novel technology options to enhance the UK’s Microbial Forensic capability” and move a range of technology options from low to medium Technology Readiness Levels. This fast-paced competition is designed to accelerate capability development in forensic sciences and will end by 31 December 2026.

The UKMFC is currently focused on human health, not “One Health”, though it does aim to attain a “One Health” approach in capability, eventually comprising: “frontline biosurveillance laboratories from the clinical, veterinary, plant, food and aquaculture sectors across all four nations of the UK”.

The UKMFC is working to build new tools, capacity, and skills across ten laboratories in biological detection and attribution—a highly ambitious, but necessary endeavour to ensure the UK is prepared for the future. Tangible progress has been made in developing what is set to be a critical sovereign biosecurity, attribution, and deterrence capability. However, no central government funding has been announced for the UKMFC to date. With the threat landscape and new technologies rapidly evolving, it is crucial that such capabilities are adequately resourced and attract the greatest talent from across all sectors to support this national security imperative. Deterrence will become increasingly important in a world of evolving and converging threat vectors.

Recommendations

Recommendation 1: Address the NBN delays through an updated outcome delivery framework

The National Biosurveillance Network (NBN) is an ambitious outcome that, if delivered in full, will help provide the UK with a world-class early warning biological outbreak detection system and protect the UK public from emerging biological threats.

In our first-year progress review, we found that May 2024 updates from UKHSA indicated early procurement rounds did not achieve the full suite of deliverables, highlighted underspending, and indicated that time delays and the complexity of the Government’s biosurveillance activity could hinder the NBN’s delivery and ultimate effectiveness.

At the 2024 UKHSA conference, there was a distinct lack of mention of the NBN. There has since been a lack of publicly available information indicating that the NBN is still active and on track to deliver on time. A Secretary of State for Health and Social Care tender for an independent evaluation of the NBN in July 2025 does not suggest that Outcome 9 is currently set to deliver as originally anticipated. CLTR believes there is a credible risk that the comprehensive disease surveillance system described in Outcome 9 of the BSS will not be fully realised or delivered on time.

The NBN is also essential for the full operational functionality of the Biothreats Radar, a flagship commitment of the BSS. The NBN is the foundational “software” required to provide the BTR with meaningful, real-time data. We recommend that the delivery framework for the NBN be revised and brought closer in line with other proven delivery frameworks (e.g., the MOD capability delivery framework), leveraging best practices to improve delivery speed and governance. This revised delivery framework at the outcome level may be applied more widely to other BSS outcomes as required.

The Cabinet Office announced in July 2025 a recruitment opportunity for a project manager to lead the delivery of the NBN’s initial operating capability, which we welcome. With the addition of a nuanced NBN capability delivery framework, including select capability artefacts (e.g., NBN user and system requirements documents), the NBN can be brought on track and deliver the intended effect.

Recommendation 2: Align BSS funding with other national strategic ambitions to achieve long-term resilience

The Biological Security Strategy directly calls upon multiple government departments to work closely with each other as well as industry and academia to achieve its vision. Delivering enhanced biosecurity and resilience at the national level within a complex and evolving threat environment requires dedicated skills, resources, and capabilities. Some of these capabilities will be exquisite in nature with little obvious commercial value; however, they remain critical to national security and deterrence.

An example is the UK microbial forensics capability. Building on the strong foundations of the MOD’s chemical and biological analysis and attribution capability, the UK microbial forensics capability intends to deliver a ‘One Health’ approach to the identification and attribution of deliberate biological misuse. However, since the strategy was launched in 2023, the MOD has received no new funds directly from the central government for developing the UK’s microbial forensics capability (as far as we can determine from a search of the publicly accessible literature). This highlights a systemic challenge: securing long-term, strategic funding for UK biosecurity resilience. Many essential capabilities, such as microbial forensics, lack obvious commercial markets yet are critical for national security and deterrence. This creates a market failure that requires a strategic, state-led investment solution.

The 2025 UK Industrial Strategy has established a £27.8 billion National Wealth Fund (NWF) with a mandate to “crowd in private finance” and support long-term growth. Crucially, the NWF has been given a “new strategic steer… to consider investments in technologies with civil and military applications and support supply-chain resilience”. While this is currently framed in economic and conventional defence terms, there is a clear opportunity to explicitly extend this mandate to biosecurity resilience. The NWF is perfectly positioned to act as a patient, strategic state investor, de-risking foundational technologies like platform vaccine technologies or pathogen-agnostic detection and diagnostic systems that have immense societal value in a crisis but are often too speculative for traditional venture capital. By tasking the NWF to invest in these areas, the government can directly align its economic growth mission with its national security mission, creating a well-funded, strategic mechanism to solve this critical market failure.

Recommendation 3: Publish a detailed public implementation plan for the purposes of transparency and public accountability

Consistent with our 2024 analysis, we reiterate the need for a more detailed public implementation plan. The absence of defined timelines for ‘short’, ‘medium’, and ‘long-term’ commitments remains a core weakness. The latest government implementation report shows a positive trend, containing more information than the previous implementation report, and sets out intentions for the next 12 months, which is welcome. However, the BSS itself still lacks defined timeframes for ‘short’, ‘ medium’ and ‘long-term’ commitments. As noted in the COVID inquiry’s Module 1 report, the BSS “lacks deadlines by which actions should occur and by which the government’s progress could be measured. The public cannot know if the government has failed if the government itself is unwilling or unable to describe and set objective tests by which its actions can be measured, nor can the officials whose job it is to implement such a strategy”.

Equally important as setting delivery timelines is defining the requirements for the 15 Outcomes and how their success will be measured. We therefore recommend adopting Stretching, Measurable, Achievable, Relevant, and Time-bound (SMART) objectives for outcome capabilities, in line with the civil service performance management framework. We recommend iterating on and releasing an updated public high-level implementation plan as a short-term cross-cutting commitment activity, providing timeframes for delivery where appropriate. This increased transparency will help improve independent scrutiny and progress assessments, foster greater trust with the public, whilst ensuring the detailed, private implementation plan is better geared to deliver measurable effects across its 15 outcomes – and achieve increased national resilience – in line with the strategy vision.

Biosecurity is National Security. Ring-fencing investment in biological detection, surveillance, and attribution for national imperatives now will ensure the UK meets its commitment to build resilience against a spectrum of threats by 2030. Public safety is achievable with the right investments, but these must begin now.

Suggested citation: Payne, Oliver and Cassidy Nelson. 2025. “Two Years On: An Independent Assessment of the UK’s Biological Security Strategy Implementation”. The Centre for Long-Term Resilience. https://doi.org/10.71172/3te2-hhgm