China proposes export curbs on 40 technologies, including AI models and agents
The proposed bans and restrictions are not final, but temporary registration requirements take effect immediately. Beijing draws a distinction between transferring AI technology and selling access to it.
China’s Ministry of Commerce and Ministry of Science and Technology propose adding 40 technologies to the export catalogue—23 related to AI—with 14 barred and 26 restricted. Exporters must already register covered transfers while the public consultation proceeds. The controls target specific techniques rather than AI exports broadly: API access and ordinary app or SaaS use are excluded, while deploying restricted technology overseas may fall under the rules. The final catalogue and its scope are still pending.
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AI proposals distinguish techniques: AI-driven malicious-code generation and mutation would be prohibited, while AI-assisted software-vulnerability discovery would be restricted.
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Registration covers ownership transfers abroad, domestic technology licensing for overseas use, and changes that give an overseas entity ownership or control.
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Transfers already underway but not completed are covered by the interim registration requirement.
China says it wants AI technology to remain open to international cooperation. Its October 16, 2026 policy announcement pairs that promise with an immediate compliance requirement: exporters must register transfers of listed technologies while officials seek comments on proposed bans and restrictions. The proposed catalogue additions cover 40 technologies, including 23 related to AI.
Specific techniques, not a blanket AI ban
The Ministry of Commerce and Ministry of Science and Technology opened a public consultation on revising China’s technology export catalogue. Their proposal spans AI, biomedicine and solar technology. Across those fields, officials would prohibit exports of 14 technologies and restrict another 26.
The AI portion covers large models, agents, computing clusters and information processing. Examples show how the proposed rules distinguish between techniques: AI-driven malicious-code generation and mutation would be prohibited, while AI-assisted discovery of software vulnerabilities would face restrictions.
The Commerce Ministry says such malicious-code technology could threaten critical infrastructure, defense systems and sensitive government networks if obtained by malicious actors. It presents the controls as safeguards against misuse and loss of human control, rather than a general halt to AI exports.
Model access and technology transfers get different treatment
For AI companies serving foreign customers, the ministry identifies a central test: does the activity transfer restricted technology from inside China to another country? Once the measures formally take effect, deploying a model containing restricted technology locally overseas would fall within the technology-export rules. Deployment on a company’s own overseas cloud could qualify for automatic licensing.
Selling access is treated differently. The ministry says providing API calls—software connections that let customers use a model—would sit outside its large-model technology-export controls. So would app or website interactions, software-as-a-service applications and lightweight deployment on local devices, even when the underlying model falls in the restricted category.
Officials also propose leaving technology already in the public domain through open-source releases or academic papers outside export management. Other activities would receive automatic licensing or similar streamlined treatment, including releasing AI technology as open source, operating company-owned computing centers abroad, overseas chip fabrication and joint research using foreign resources.
The ministry says most proposed entries have specific technical thresholds, and products manufactured using the technologies are outside the management scope. It says the vast majority of AI technology would remain freely exportable after implementation.
Registration starts before the catalogue is finalized
The temporary requirement is already operative, unlike the proposed final bans and restrictions. From the announcement’s publication until the revised catalogue takes effect, exporters must register covered transfers through the Commerce Ministry’s technology-trade system. Exporters must assess whether their technology falls within scope; transfers already underway but not completed are also covered.
Transfers requiring registration include
Transferring ownership of covered technology abroad.
Licensing technology in China for use overseas.
Changing the owner or actual controller of technology in China to an overseas entity.
The Associated Press places the announcement against intensifying technology competition with the United States and other countries. Beijing rejects a country-specific reading: the ministry calls the revision routine and says it targets no particular country, region or entity. It also promises to adjust the catalogue as technologies develop, removing entries that are no longer advanced.
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