The DeepSeek removal order was published in the U.S. Federal Register on 20 October 2026 (FR Doc. 2026-21447, Docket No. DHS-2026-0628). The Department of Homeland Security filed the notice for public inspection on 19 October and published it the next day, announcing Exclusion and Removal Order No. 2026-01, signed by the Secretary of Homeland Security. The order was in fact issued on 24 July 2026, under the Federal Acquisition Supply Chain Security Act of 2018 (41 U.S.C. 1321-1328) and its implementing regulations, after review of a recommendation from the Federal Acquisition Security Council. That it only became public in October is the first thing to keep in mind when reading it.
The order does two things, not one
The first is a procurement exclusion: federal civilian agencies may no longer procure information technology products and services developed by Hangzhou DeepSeek Artificial Intelligence Co., Ltd (DeepSeek) or its affiliated entities, with affiliation defined under the federal acquisition rules at 48 CFR 2.101. The second is removal of what is already in place: DeepSeek and DeepSeek-affiliate products already inside civilian agency information technology must come out, and "third-party products and services developed using DeepSeek implementations" are in the removal scope as well.
The difference between the two determines how you check. The exclusion asks who the supplier is; the removal asks which model sits underneath. A third-party tool delivered under a different brand or a different interface does not pass simply because DeepSeek did not sell it, if its implementation layer uses DeepSeek.
Scope: federal civilian agencies only
The duty falls on U.S. federal civilian executive agencies; the information technology systems and procurements of civilian departments such as Treasury, State and Justice are covered. The order does not cover Department of Defense systems, and it does not cover national security systems, sensitive compartmented information systems or intelligence systems, which sit under other authorities. Ordinary companies and individual users are not bound by it: it is not a general ban aimed at the private sector, and it is not an export control. Reading it as "the United States has banned DeepSeek outright" misreads its scope.
DHS says DeepSeek models present multiple threat vectors: use by government employees or vendors may result in sensitive data being transferred to the PRC, prompts entered into the systems could be combined into actionable intelligence on U.S. persons and agencies, and the models themselves may contain malware or other security vulnerabilities. The notice also states that the decision followed review of the Federal Acquisition Security Council's recommendation and supporting evidence; it does not publish all of that evidence, so the above should be read as the regulator's risk assessment rather than as proven findings in individual cases.
What suppliers should do now: make model provenance explicit
For vendors supplying federal civilian agencies, the work this order creates is concrete. First, inventory every AI feature in the products you deliver and confirm which model and version sits underneath each one, including sublicensed, further-developed and wrapped implementations. Second, put model provenance in delivery documents and contract annexes, so you can produce it on request instead of reconstructing it after the fact. Third, if a product falls in the removal scope, line up a replacement model and a migration plan early; until removal is complete, strengthen network traffic monitoring and logging as agencies require. Fourth, note how narrow the exception channel is: an agency seeking an exemption or more time had to apply in writing within 60 days of the order's issuance, with a compelling justification, handled by the relevant team at the Cybersecurity and Infrastructure Security Agency (CISA). Because the order was issued on 24 July, that window had already closed by the time the notice became public in October, so latecomers can no longer count on exceptions to buy time.
The risk hides in dependencies you cannot see
Many agencies may never have bought DeepSeek directly, yet bought search, customer-service or document-processing tools that integrate DeepSeek's open weights. Checking brand lists will not find those dependencies; only a model-level bill of materials can answer "is it inside our systems at all". For suppliers, being unable to state which model sits underneath is moving from a transparency gap to a delivery failure. For agencies, the work does not end after one sweep either: the order requires the Secretary to review it within a year and annually thereafter, so removal and verification are continuing obligations, not a one-off cleanup.
