Biology is Changing, and the BWC is Falling Behind: What Should Russia Do?

The Biological and Toxin Weapons Convention (BWC) remains a key element of the existing global biosecurity architecture, but it was created for a different technological world. Today, the accelerated development of biotechnologies, the digitalization of biology and the opaque military activity of the United States and NATO expose the Convention’s structural weaknesses and require Russia not only to insist on preserving the prohibition norm but also to advocate the institutional strengthening of the BWC regime—from verification to the governance of dual‑use research.

In 2022, Russia, Belarus, Venezuela, China, Syria, Zimbabwe, Nicaragua and Cuba signed a joint statement calling for the activation of BWC mechanisms to obtain answers regarding U.S. military biological activities in Ukraine. Later that year, Russia for the first time initiated the procedure under Article VI of the BWC—theoretically the most stringent instrument, allowing a State Party to file a complaint with the UN Security Council about an alleged violation. However, the proposed resolution was not adopted: only two votes in favor (Russia and China), three against (the United States, the United Kingdom and France) and ten abstentions. Nevertheless, on 12 June 2026, the Office of the Director of National Intelligence of the United States published a press release declassifying documents concerning U.S.-funded overseas biolaboratories. According to the published data, this network comprises more than 120 laboratories in over 30 countries, including more than 40 facilities on the territory of Ukraine. If, as claimed, one of these facilities houses a storage of biological weapons created back in the Soviet period, this could be regarded as a violation of the BWC. In addition, the documents indicate that some facilities are classified as biosafety level BSL‑3, which implies work with serious or potentially lethal pathogens and requires strict biosafety measures.

Apart from the United States, the attitude to the BWC of some other NATO member states is also a cause for concern. In 2026, five out of 32 NATO members failed to submit their reports under the Confidence‑Building Measures (CBM) framework. Of the 27 reports that were submitted, only 19 are publicly available, and two countries (the United States and Belgium) submitted two reports each—one public and one with restricted access—and withdrew part of the information from open access. In May 2026, Russia’s Permanent Representative to the UN Office in Geneva, Gennady Gatilov, in a statement to the plenary meeting of the Conference on Disarmament, accused Germany of running its own military biological program in Ukraine. These suspicions are reinforced by the fact that in 2026, for the first time in 40 years, Germany did not submit its CBM report. Taken together, the absence of a verification mechanism and the lack of mandatory, regulated information‑sharing on biosafety‑related developments create an institutional vacuum in which the BWC is drifting from a control instrument toward an arena for political accusations.

On the one hand, the BWC has created a powerful political‑legal stigma attached to biological weapons: openly declaring the existence of such programs has become politically impossible. On the other hand, the regime struggles when it comes to early detection of suspicious activity, investigation of disputed situations, and confirmation or refutation of allegations. Without institutional strengthening and genuine scrutiny of the most powerful players in the biological domain, the regime increasingly risks turning into a declaration of good intentions. It is precisely the combination of reinforcing the prohibition norm and demanding genuine, rather than selective, transparency on the part of the leading actors that can turn the BWC from a “moral standard” into a truly effective tool for managing biological risks in the contemporary world.

The Biological and Toxin Weapons Convention (BWC) remains one of the key elements of the existing international security system, enshrining a direct prohibition on the development, production and stockpiling of biological weapons and removing such activities from the realm of normal state policy. The problem is that the environment in which the BWC operates has changed dramatically: biology has become more mass‑scale, digital and commercially significant. The extent to which treaty norms and institutions keep pace with this new reality determines not only the Convention’s reputation but also its ability to manage biological risks effectively.

To illustrate this logic, consider a simple metaphor. A kitchen knife is an ordinary household tool, indispensable in everyday life, yet under different circumstances it can easily become a weapon. Something similar is happening with modern biotechnologies: they are indispensable for medicine, agriculture, epidemiological surveillance and bioshield systems, but with the right (or rather, wrong) intent they can serve as a basis for developing biological weapons.

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New Biology and the Bio‑Based Economy

Since the adoption of the BWC over half a century ago, biology has undergone several technological “revolutions.” As early as the beginning of the 2000s, experts predicted the emergence of a global bioeconomy. Today, however, it is a multi-trillion-dollar industry, and biotechnology has become one of the key foundations of future economic growth. For the BWC, this is not an abstract backdrop. The subject of regulation is no longer at the periphery of the economy, as it was in the 1970s; it has moved to the center of attention—into mainstream medicine, agriculture, industry and energy. The more sectors rely on biotechnologies, the more actors potentially fall within the Convention’s scope—from large transnational corporations to small research laboratories.

The cost of obtaining biological data has also fallen dramatically. One striking example is the dramatic decline in the cost of sequencing an entire human genome. In the early 2000s, sequencing a single human genome cost hundreds of millions of dollars; by 2023, the price had dropped to approximately $500–1,000, extending access beyond elite research institutions to a wide range of hospitals, clinics, and commercial service providers. At the same time, large‑scale genetic testing programs, including prenatal screening, have expanded and are now supported by tailored insurance products and state‑funded assistance programs.

The practical implication for the BWC regime is obvious: what used to be the prerogative of a narrow circle of state institutions is becoming part of routine medical and research practice. The Convention, which was written for a world of large‑scale state programs and military facilities, is increasingly confronted with a form of biology that is distributed, network‑based, and heavily digital.

Another important transformation concerns how access to dangerous capabilities is configured. In the 1970s, key competencies and infrastructure were concentrated within large government programs. Today, a significant share of biological capabilities is distributed among clinics, private companies, universities, biobanks, contract research organizations and IT platforms.

The object of regulation is becoming increasingly unlike a classical “warehouse of pathogens.” Increasingly, biosecurity risks are associated with:

• Digital sequence databases
• Software tools for design and analysis
• DNA synthesis services and automated laboratory platforms
• The cross-border exchange of biological data, software, and algorithms

Traditional control tools—export controls, on‑site inspections, accounting of materials—were designed for the circulation of tangible objects and centralized infrastructure. In the context of digital and distributed biology, their applicability is limited. Against this backdrop, unilateral accusations that Russia is violating its biological obligations, accompanied by the refusal of the United States and a number of its allies to disclose key parameters of their own military and related biological projects, are perceived as a characteristic example of double standards.

Normative Foundations and Verification Under the BWC

The BWC was opened for signature in 1972 and entered into force in 1975, closing a fundamental “gap” in the 1925 Geneva Protocol, which prohibited the use of bacteriological agents in war but said nothing about the development and production of such agents. For this reason, the Convention is rightly regarded as the first global treaty to outlaw an entire class of weapons.

The Convention consists of 15 articles that establish:

• A general prohibition on the development, production, stockpiling, acquisition, and transfer of biological and toxin weapons
• An obligation to destroy existing stockpiles or divert them to peaceful purposes
• A requirement for States Parties to adopt national measures to implement the Convention
• Mechanisms for consultation and complaints, as well as provisions on assistance, peaceful cooperation, and periodic review of the BWC’s implementation

The Convention's core obligation is set out in Article I, under which States Parties undertake never, under any circumstances, to develop, produce, stockpile, or otherwise acquire or retain microbiological or other biological agents or toxins "of types and in quantities that have no justification for prophylactic, protective, or other peaceful purposes," as well as corresponding means of delivery. Articles II–IV then specify stockpile destruction, prohibition of transfer and national implementation, while Articles V–VI describe procedures for consultations and the submission of complaints to the UN Security Council.

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It is important that the BWC was deliberately drafted not as a list of prohibited substances, but as a broad functional prohibition. The decisive criterion is therefore not the identity of a particular microorganism or toxin, but the purpose and scale of the activities in which it is used. This design has a dual effect. On the one hand, it makes it possible to apply the Convention to new technological classes—synthetic biology, genetic engineering and so on. On the other hand, it leaves a wide scope for disputes over where legitimate peaceful or defensive research ends and projects that are, in substance, incompatible with the BWC regime begin.

The main challenge facing the BWC today is not that the prohibition itself is openly contested. Rather, the difficulty lies in drawing a clear distinction between permissible and impermissible activities—a task that is much harder than it was in the 1970s, when the regime was being formed.

The BWC’s original flaw is the absence of a full‑fledged verification protocol. The most serious attempt to fill this gap was made in the 1990s by the Ad Hoc Group of governmental experts, which worked on a draft protocol providing inspections and procedures to verify compliance. The negotiations were halted in 2001, when the United States refused to support the proposed regime, citing the threat to “national security and commercial secrets” of the U.S. pharmaceutical industry. Since then, the BWC’s institutional architecture has remained vulnerable.

There have been attempts to partially compensate for this deficit through Confidence‑Building Measures (CBM), which provide for the voluntary exchange of information on relevant facilities, national research programs, unusual disease outbreaks, vaccine production, etc. Under the agreed procedures, such CBM reports are to be submitted by States on an annual basis by 15 April. Nevertheless, data shows that information exchange under the BWC remains incomplete and uneven. A record number of reports (122) was observed in 2025, yet this represented only 65% of all BWC States Parties. Moreover, until 2021 the number of reports submitted had never exceeded half of the total membership. In 2026, only 100 State Parties submitted reports, which represents just over half of the Parties to the Convention. Furthermore, the accessibility and content of these reports vary significantly. Thus, only one third of the reports were publicly available in 2026, only 72% contained declarations on the exchange of data on research centers and laboratories, and information on past activities under offensive and/or defensive biological research and development programs was provided in 36% of the reports.

Russia and several other countries have repeatedly pointed out that the U.S. position largely obstructs progress towards a legally binding verification mechanism. In addition to the dissolution of the Ad Hoc Group, the United States generally provides limited information about its biodefence programs in the CBM framework. A 2006 report by the Arms Control Association (ACA) noted that the United States had failed to include classified projects in its annual CBM declarations, which undermined confidence in the good faith of the U.S. biodefence program. Among such projects were Project Jefferson (reproducing a genetically modified strain of anthrax), Project Clear Vision (reconstruction and testing of a Soviet biological bomb) and Project Bacchus (construction of a mock production facility for anthrax). The Association’s experts also recommended that the U.S. government include in its CBM declarations “a comprehensive list of all of its biodefense activities, including classified projects.” The situation has not changed to this day: according to experts from Johns Hopkins University (2024), there are still “concerns regarding the completeness and accuracy of CBM submissions,” and access to most reports remains restricted, undermining confidence in the BWC regime and confirming the persistent problem of insufficient transparency on the part of the United States. In the same year, the Commander of the Russian Chemical, Biological, and Nuclear Defense Troops, Igor Kirillov, stated that the United States' blocking of international verification initiatives for the BWC “excludes the possibility of checking operations of laboratories either in the territory of the United States or outside its borders.”

In 2022, Russia, Belarus, Venezuela, China, Syria, Zimbabwe, Nicaragua and Cuba signed a joint statement calling for the use of BWC mechanisms to obtain answers regarding U.S. military biological activities in Ukraine. Later that year, Russia for the first time initiated the procedure under Article VI of the BWC—theoretically the most stringent instrument, allowing a State Party to file a complaint with the UN Security Council about an alleged violation. However, the draft resolution was not adopted: there were only two votes in favor (Russia and China), three against (the United States, the United Kingdom and France) and ten abstentions. Yet even if it had been approved, another difficulty would have arisen: the Convention contains no guidance on the type and procedure of investigations under Article VI.

Nonetheless, on 12 June 2026, the Office of the Director of National Intelligence of the United States published a press release on the declassification of documents relating to U.S.-funded overseas biolaboratories. According to the published data, this network comprises more than 120 laboratories in over 30 countries, including more than 40 facilities on the territory of Ukraine. It has been alleged that one of these facilities houses a biological weapons stockpile dating back to the Soviet period. If such a stockpile does indeed continue to exist and is being maintained in its current form, this could constitute a violation of the BWC, given that both the United States and Ukraine are States Parties to the Convention. The document also states that some facilities are classified as biosafety level BSL‑3, which implies work with serious or potentially lethal pathogens and requires strict biosafety measures. The press release also mentions Executive Order 14292 of 25 May 2025, which limits federal funding and strengthens oversight of “dangerous gain‑of‑function research on biological agents and pathogens.” However, the Order does not prohibit such research as such, so the legal and factual qualification of the activities at these facilities remains an open question.

In addition to the United States, the approach of some other NATO member states to the BWC also raises concerns. In 2026, five of the 32 NATO members—Albania, Germany, Greece, North Macedonia and Turkey—failed to submit their CBM reports. Of the 27 reports submitted, only 19 are publicly available, and two countries (the United States and Belgium) submitted two reports each—one public and one with restricted access—and withdrew part of the information from open access. In May 2026, Russia’s Permanent Representative to the UN Office in Geneva, Gennady Gatilov, in a statement to the plenary meeting of the Conference on Disarmament, accused Germany of conducting its own military biological program in Ukraine. These suspicions are reinforced by the fact that in 2026, Germany, for the first time in 40 years, did not submit a CBM report. Taken together, the absence of a verification mechanism and of mandatory, regulated information‑sharing on biosafety‑related developments creates an institutional vacuum in which the BWC risks becoming less a control instrument than an arena for political accusations.

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Dual-Use Research, Grey-Area Activities, and Terminological Challenges

A specific set of issues is associated with dual‑use research. Modern projects in synthetic biology and genetic engineering can alter the properties of pathogens, affect their resistance to existing prophylactic and therapeutic measures, complicate diagnostics and circumvent existing bioshield systems. Formally, many such activities are described as defensive, preventive or “purely scientific.” In BWC terms, this is always a matter of interpretation: what exactly is to be regarded as “peaceful” and “protective” purposes, how to assess the scale and design of an experiment, and what requirements should be imposed on the risk‑management environment.

The broad wording of Article I, on the one hand, makes it possible to extend the prohibition to any new forms of biological weapons. On the other hand, it complicates the classification of activities that fall into the grey area between permissible and prohibited conduct. In the Russian interpretation, research that, taken together, generates an offensive capability—even if formally framed as “defensive” or “diagnostic”—runs counter to the spirit and letter of the BWC. The limited willingness of the United States and its allies to discuss such projects in a transparent format only reinforces suspicions and suggests that the institutional weakness of the BWC regime is being used as a convenient “cover.”

A separate set of issues concerns terminology. In the Russian language, the following terms are still not always clearly distinguished:

• biosafety (биобезопасность) – the safe handling of biological materials
• biosecurity (биозащита) – protection against unauthorized access and misuse
• biodefense (биологическая оборона) – preparedness to counter deliberate biological threats

This distinction is important when discussing the future of the BWC. Different weaknesses of the regime require different responses. In some areas, the priority lies in strengthening laboratory practices and the accounting of biological materials; in others, it is enhancing international transparency and export controls; and in still others, regulating biodata and improving investigative mechanisms. For Russia, correctly differentiating these concepts is important both as an element of domestic policy and as an argument in international discussions.

The discussion above leads to a straightforward conclusion: the BWC remains an indispensable pillar of international biological security, but its original design does not match the realities of the “new biology.” The contemporary context—a mass bioeconomy, cheaper biodata, the digitalization of research, and the expanding range of actors—has exposed four key shortcomings of the current regime:

• the absence of a legally binding verification mechanism
• limited transparency
• difficulties in qualifying dual‑use research
• the weak adaptability of existing control mechanisms to digital and platform‑based biology

Against this background, possible directions for strengthening the BWC could include:

1. Revisiting the idea of a verification protocol. This does not necessarily mean a direct return to the failed Ad Hoc Group model, but rather the search for a compromise that would allow the most sensitive types of activities to be subject to scrutiny without harming genuinely peaceful research and legitimate commercial interests.
2. Enhancing transparency measures. Transparency and confidence‑building measures could be developed towards a more standardized and gradually expandable format in which all participants would have a clear understanding of the minimum “mandatory package” of information. Particular attention should be paid to large military and transboundary biological programs.
3. Adapting to digital biology. There is a need for an international discussion on how to regulate the circulation of hazardous genetic sequences, digital tools and DNA synthesis services, without disrupting legitimate scientific and medical collaboration. For Russia, an emphasis on non‑discriminatory access to legitimate biotechnologies and tools is important, rather than a technological “fencing off” of a select group of countries.
4. Developing national systems for biosafety, biosecurity and biodefence. The more resilient national infrastructures there are, the fewer incentives states have to pursue covert offensive programs. This implies the need for comprehensive strategies in which issues of laboratory practice, accounting, epidemiological surveillance, and bioincident response are logically integrated with international obligations under the BWC.

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On the one hand, the BWC has indeed created a powerful political‑legal stigma attached to biological weapons: openly declaring the existence of such programs has become politically impossible. On the other hand, the regime struggles to fulfil the tasks of early detection of suspicious activity, investigation of disputed situations, and confirmation or refutation of allegations. In practice, the BWC functions better as a framework for political condemnation and delegitimization than as a full‑fledged monitoring and investigative instrument, and this is no longer sufficient in the era of the “new biology.” Without institutional strengthening and genuine scrutiny of the most powerful players in the biological domain, the regime increasingly risks turning into a declaration of good intentions. It is precisely the combination of reinforcing the prohibition norm with the requirement for genuine, rather than selective, transparency on the part of the leading actors that can turn the BWC from a “moral standard” into a truly effective tool for managing biological risks in the contemporary world.