Activate existing biosecurity powers to address AI-enabled risks

Dear Minister,

Australia has one of the world's most rigorous biosecurity frameworks, and a new gap has emerged that it is well-placed to close. AI and synthetic biology now pose increasing and novel risks that require immediate action from your department.

Synthetic nucleic acids can be used to develop vaccines, improve crops, and advance medical research, but also to engineer or construct pathogens. Australians can order custom nucleic acids from overseas providers. Previously, the key constraint in creating a biological weapon from synthetic nucleic acids was the knowledge required — expertise that was rare and hard to acquire. That has changed.

The International AI Safety Report 2026 confirms that general-purpose AI systems can now provide expert-level guidance on biological and chemical weapons development, including detailed laboratory instructions.¹ One study found an AI model outperforming 94% of domain experts at troubleshooting virology protocols.² Specific AI systems (biological foundation models) can generate genomes for viruses (bacteriophages) not previously seen in nature.³ Related techniques have already been used to design protein variants that evade the human immune system.⁴

Current AI practices do not adequately address this risk: only 3% of 375 biological AI tools surveyed have any safeguards,⁵ and where they exist, ways to circumvent the restrictions (jailbreaks) are common.⁶

A bad actor with AI guidance still needs the materials to act, and imported synthetic nucleic acids are a physical chokepoint. Australia's Biosecurity Import Conditions system (BICON) gives the Director of Biosecurity the power to impose conditions on all such imports — immediately, without new legislation. Members of the International Gene Synthesis Consortium, including leading providers such as Twist Bioscience, IDT, and GenScript, already screen orders for sequences of concern voluntarily. Yet, Australia's current import permit system does not require that synthetic nucleic acids be sourced from providers that screen, and bad actors could exploit that.

Australia has committed to reducing biosecurity risks to a very low level.⁷ The science now provides reasonable grounds for biosecurity officers to conclude that synthetic nucleic acids imported without safety screening pose an unacceptable risk under the Biosecurity Act 2015.

The US,⁸ New Zealand,⁹ the EU,¹⁰ and the UK¹¹ are each taking steps to address screening requirements. Australia can do the same, and without new legislation.

The National AI Plan says that regulators are responsible for identifying and addressing AI-related harms within their domains.¹² We call on you to act on that responsibility.

We recommend that:

1. A screening condition be applied to all BICON import permits for synthetic nucleic acids. Permits should require that synthetic nucleic acids be sourced from providers that screen orders for sequences of concern and, where sequences of concern are identified, verify customer identity and legitimacy. Appropriate mechanisms should be in place to verify provider compliance.
2. Applicants for higher-risk synthetic nucleic acid import permits are prioritised for the statutory fit and proper person test¹³ — a government background check that goes beyond provider screening — with the department publishing clear criteria for when and how the test is applied.
3. The department reviews the adequacy of the regime within its broader context, in consultation with relevant Commonwealth agencies, including the new AI Safety Institute, civil society, industry, and academia. The review should address progress made in AI and biotechnology as well as emerging issues such as domestic production of synthetic nucleic acids, control on benchtop DNA synthesisers, and mechanisms for verifying provider compliance.

These steps should be accompanied by appropriate transparency to signal to the public, the global community, and potential bad actors that Australia is taking action.

Implementing these measures is low cost.¹⁴ Screening is conducted digitally by the synthesis provider before dispatch, imposing no additional burden on Australian researchers, businesses, or the regulator. Free screening tools are available.^15,16 Major providers already screen voluntarily — this change targets the gap, not the norm.

This is an opportunity for Australia to address domestic risks and build on its world-leading biosecurity framework. As a founding member of the Australia Group, Australia has a track record of international biosecurity leadership. Mandating gene synthesis screening would be a significant step toward establishing a global norm and addressing AI-biosecurity risk.

Yours faithfully

The undersigned