Israel’s system for safeguarding dangerous biological agents remains so under-regulated and fragmented that pathogens or sensitive scientific knowledge could slip into hostile hands with alarming ease, a State Comptroller Report revealed on Tuesday.
The audit paints a picture of a regulatory framework that has existed solely on paper for 16 years but has never been implemented in practice – a vacuum growing riskier by the day as artificial intelligence accelerates the accessibility of advanced biological capabilities.
State Comptroller Matanyahu Englman did not mince words, cautioning that the findings “should keep government ministers up at night,” given their direct implications for public safety.
He stressed that the post-October 7 landscape only heightens the state’s obligation to correct the failures his office identified, pointing to “severe shortcomings” across multiple domains. The warning places the gaps squarely in the realm of urgent national-security risks – not bureaucratic oversights.
The State Comptroller’s Office examined 43 recognized institutions in Israel that hold or research disease-causing biological agents – ranging from hospitals and academic labs to private companies – alongside the national bodies responsible for overseeing them: the Health Ministry, the Biological Research Regulation Council, the Defense Ministry, the National Security Council, and Israel Police.
The review took place between August and November 2024, and what emerged is a system with no functioning enforcement structure, unclear lines of responsibility, and no systematic way to protect the country from the dangers inherent in dual-use research.
The law governing this field – the Regulation of Research into Biological Disease Agents – was passed in 2008, meant to ensure that labs holding or studying dangerous pathogens did so under strict regulatory conditions.
But from the moment it was enacted until the close of the audit last November, no health minister has ever issued the regulations the law requires. Two technical updates were published in 2017 and 2020, but those dealt only with updating the list of organisms covered by the law, not with enforcement, licensing conditions, lab-security standards, emergency procedures, or screening requirements. In effect, the most sensitive biological work in Israel has been operating without the legal infrastructure the Knesset had originally intended for it.
Across the 43 institutions examined, 22 – more than half – were found to have significant biosecurity deficiencies; only 24 institutions responded to the comptroller’s questionnaire. Six said they do not hold any biological agents, while 18 others, including all four of Israel’s BSL-3 laboratories – high-security research facilities equipped to work with dangerous airborne pathogens under strict safety and access controls – provided substantive replies.
Those four highest-security labs do operate institutional security units, but the report makes clear that this alone is not enough; even among them, gaps persisted in documentation, risk analysis, and emergency preparedness.
Required risk surveys often incomplete or missing entirely
In many other institutions, the audit found more troubling results. Required risk surveys – meant to identify vulnerabilities in labs working with dangerous agents – were often incomplete or missing entirely. Security units in a few facilities failed to provide updated instructions for lab procedures or did not consistently enforce them.
Some labs had not properly screened personnel with access to harmful pathogens, while others lacked sworn declarations attesting to the absence of prior security-related convictions, an omission the comptroller warned carries direct national-security implications.
Emergency preparedness was inconsistent and, in places, inadequate, the report further found. Some institutions had no viable emergency-response plan for biological incidents, while others had not conducted drills or carried them out in a manner consistent with realistic threat scenarios. Physical security measures varied sharply between institutions, and in facilities holding pathogenic agents, the State Comptroller’s Office found gaps in access control, monitoring, and surveillance.
Another acute vulnerability stemmed from the lack of any structured intelligence-sharing mechanism between the security agencies represented on the Biological Research Regulation Council and the council itself.
Although the council includes officials from the NSC, Defense Ministry, and police, there is no formal process for transferring intelligence related to biological terror threats, attempts to acquire dangerous materials, or concerns tied to specific institutions or researchers. Both the police and the NSC emphasized the seriousness of this gap in their responses to the draft audit; the Comptroller warned that without a structured flow of intelligence to the council, Israel’s biosecurity posture is compromised at its foundation.
The report also examined the rapidly advancing field of synthetic biology, concluding that Israel has no regulatory framework at all for overseeing DNA synthesis. While the EU, United States, and Australia screen DNA orders and maintain oversight systems to prevent the misuse of synthetic constructs, the comptroller found that Israel has not advanced comparable regulation – despite repeated recommendations from the national council. With AI tools now enabling the rapid design of biological systems, the comptroller cautioned that Israel’s regulatory vacuum leaves the door open to scenarios that other countries have spent years preparing against.
The audit further found that oversight of dual-use scientific publications, a cornerstone of global biosecurity policy, is equally absent. Since 2008, the national council has never discussed guidelines for handling sensitive research results that could be weaponized, and no mechanism exists for pre-publication review.
Police and NSC officials disagree over jurisdiction, and the Health Ministry has not acted to fill the gap. In an era where AI allows anyone to retrieve, combine, and operationalize complex scientific data, the Comptroller warned that the lack of oversight could help hostile actors plan or execute a biological attack.
These findings echo patterns the comptroller has documented in previous years regarding Israel’s preparedness for high-impact threats – namely, a persistent gap between legislative intent and governmental execution.
Englman issued a sharp directive to the Health Ministry, urging it to immediately regulate synthetic biology, finalize regulations governing pathogen research, and coordinate inter-ministerial oversight and intelligence mechanisms.
The failures identified “may increase the risk of leakage of pathogens or sensitive knowledge to hostile or criminal actors,” he said, and could meaningfully ease the path toward biological terror. In an era defined by rapid technological change and global proliferation of biological tools, the comptroller warned on Tuesday that Israel cannot afford another year – let alone another decade – of regulatory paralysis.
The report shows that 16 years after the Knesset sought to put guardrails around some of the most sensitive scientific work in the country, those guardrails still do not exist, despite the escalating risks.