China proposes controls on 23 AI technologies as export registration begins
The October 16 proposal excludes already-public technologies and distinguishes overseas deployment from remote service access.
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Proposal and immediate registration
China’s commerce and science ministries propose adding 23 AI technologies—large models, agents, compute clusters and information processing—to the export-control catalogue. Their October 16 notice covers 40 technologies overall; comments close November 15, 2026.
Affected technology transfers already require pre-export registration, including exports begun but unfinished. This temporary measure applies immediately; the proposed catalogue restrictions remain under consultation.
Deployment and service access
The ministry’s Q&A says overseas local deployment of restricted AI technology would fall within controls once implemented. API calls, app/web access, SaaS and lightweight on-device deployments would fall outside large-model technology export management.
Open-source treatment
Already-public technology released through open source or academic papers would be excluded. Qualifying future open-source releases, Chinese firms’ self-built, self-operated overseas compute centres, overseas chip fabrication, joint research and standards work could use automatic licensing. The proposal therefore distinguishes technology transfers from several common ways of accessing models.
Questions for an export project
Before a project moves ahead, identify the recipient, the team responsible for paperwork and the contract recording the transfer. Assign someone to check the final published rules before launch and keep that review with the project records.