China’s commerce and science ministries proposed export controls on 23 AI technologies on October 16, 2026. The measures are part of a wider draft covering 40 technologies in artificial intelligence, biomedicine and solar power.

The proposed restrictions are not final, but the temporary registration requirement for certain technology transfers is in force.

What the draft covers

The proposed AI categories include large models, AI agents, computing clusters and information processing. The Ministry of Commerce says technologies already in the public domain through open-source releases or academic papers would be excluded.

  • 23 proposed AI technology categories
  • 5 biomedicine technologies
  • 12 photovoltaic technologies
  • 14 of the 40 proposed additions classified as prohibited, and 26 as restricted

The Associated Press reported that the list includes AI technologies for generating or changing malicious code, some chip-design technologies, and tools intended for sensitive settings such as defense and critical infrastructure. The draft does not name specific AI models.

Registration applies during consultation

Companies must register certain transfers of technologies listed in the draft before sending them abroad, even while the proposed controls remain under review. The requirement covers transfers of ownership, licenses for overseas use, and cases in which a technology’s owner or actual controller becomes a foreign entity. It also applies to transactions already underway but not yet completed.

The two stages have different status: the proposed bans and restrictions await formal adoption, while the interim filing requirement is in force. China is accepting public comments through November 15, 2026. The ministries have not published a final revised catalogue.

Model technology and service access are treated differently

The Ministry of Commerce says the key question is whether the restricted technology itself moves from China to another country. Once the catalogue takes effect, overseas deployment of a restricted model would fall under technology-export management, according to the ministry.

By contrast, the ministry says API access, app or web interactions, and software-as-a-service using such models would not count as exporting the model technology itself. For overseas partners, including U.S. companies, that distinction separates transferring a model’s underlying technology from providing access to a service built on it. The scope could still change during consultation and before the catalogue is formally revised.