China drafts export limits on 23 AI technologies, models included

China drafts export limits on 23 AI technologies, models included

16 October 2026: China's Ministry of Commerce (MOFCOM) and Ministry of Science and Technology have proposed adding 40 key technologies in artificial intelligence, biomedicine and solar power to the country's catalogue of technologies prohibited or restricted from export. Twenty-three of them are AI technologies covering large models, agents, computing clusters and information processing.

Not yet independently verified. We have read MOFCOM's spokesperson Q&A but not the text of Announcement No. 48, so the technical thresholds and the end of the comment period (reported as 15 November) rest on a Cloud Security Alliance research note. We will update this when it can be confirmed, and remove this note.

The two ministries published the draft as Announcement No. 48 of 2026 on 16 October and opened it for public comment. At the same time they put in place an interim rule that is already binding: before exporting any technology on the draft list, an exporter must register it on MOFCOM's technology trade management platform.

What would be banned and what restricted

Of the 40 technologies, 14 would be prohibited from export and 26 restricted. MOFCOM's spokesperson gave examples of each. On the prohibited side: AI-driven generation and mutation of malicious code. On the restricted side: AI-assisted vulnerability discovery. The other examples named come from cell and gene therapy and from polysilicon and perovskite solar manufacturing.

MOFCOM says most of the listed technologies carry specific technical thresholds and that products made with them fall outside the controls. A research note by the Cloud Security Alliance, which read the announcement, reports that a frontier model would be restricted if it meets any one of three tests: training compute of 10^26 operations, two trillion parameters, or a place among the global top ten.

API access is not an export, local deployment is

The answer that matters most to buyers outside China concerns how Chinese models reach them. MOFCOM says offering a restricted model through API calls, app or web interaction, SaaS applications or lightweight on-device deployment is not a technology export. Deploying a restricted model locally abroad is, although deployment on a Chinese company's own overseas cloud can qualify for automatic licensing.

Open source is treated gently. Technology already in the public domain through open-source release or academic publication would stay outside the controls, and open-sourcing AI technology, building and running computing centres abroad, chip tape-out abroad and joint research all qualify for automatic licensing, which MOFCOM says means export "basically as soon as it is declared".

The registration rule already in force

From the announcement's publication until the revised catalogue takes effect, exporters must register before exporting a listed technology. Exporters judge for themselves whether a technology falls within the list. Registration covers transferring ownership of a technology abroad, licensing it for use abroad, and a change of the technology's owner or controller to a foreign entity; exports already under way but not finished are included.

For a company outside China that licenses model weights from a Chinese developer, or plans to run a Chinese model on its own servers, the practical change is that its supplier now has a registration step before it can deliver, and may need a licence once the catalogue is final.

Sources

• MOFCOM: Spokesperson answers questions on revising the Catalogue of Technologies Prohibited and Restricted from Export, 16 October 2026
• Cloud Security Alliance: Research note, China AI export controls, Announcement 48, 23 October 2026