China’s draft AI export controls cover agents and giant models — what the proposal does

China’s Ministry of Commerce and Ministry of Science and Technology published a draft revision to the country’s export‑control technology catalog on October 16. An [English‑language government summary](https://en.chinadiplomacy.org.cn/2026‑10/17/content_118737303.shtml) says the proposal covers 40 technologies across artificial intelligence, biomedicine, photovoltaic power and other fields. [Associated Press reports](https://apnews.com/article/5ac381c0c6d6628bbea2e0da7d855a5b) that 23 of the entries concern AI. For an ordinary reader, this is a proposal about know‑how and model capabilities, not simply another restriction on physical processors. If finalized, it could shape which Chinese AI systems, methods and technical services companies can transfer abroad, license across borders or use in international partnerships. The draft is open for public comment through November 15. That means the listed thresholds and classifications remain proposals, and the final catalog may change.

The government summary says the prohibited category includes core technology for large AI models trained using sensitive national data. It also describes agents intended for highly sensitive settings such as national defence and critical information infrastructure. A prohibition is different from a licensing requirement: technology placed in the prohibited category could not be exported. The documents do not name individual companies or commercial products, and a model’s inclusion would depend on the final wording and the facts of a specific transfer. That distinction prevents a common overstatement. The draft does not say that every Chinese AI model or every AI agent is barred from international use.

The restricted category includes models with at least 2 trillion parameters or certain advanced capabilities, according to the government summary and AP. A restricted technology can still be exported, but only after the required review and license. Parameter count is one threshold, not a complete measure of performance or risk. The draft also refers to capability‑based criteria, so smaller systems could matter if they meet other conditions, while the presence of a large parameter count alone does not establish that a named product is covered without the complete technical and legal analysis. The practical consequence is more due diligence for cross‑border model deals. Buyers, investors and research partners may need to understand where a system was developed, what data and methods it uses, and whether a transfer includes controlled technical knowledge rather than only access to a hosted service.

In a separate [official explanation](https://www.mofcom.gov.cn/zwgk/zcjd/art/2026/art_b11d5c1e9374421e93e85dc87eba6e38.html), the Commerce Ministry says exporters covered by the accompanying announcement must register proposed technology exports through its unified business system before a formal catalog revision takes effect. The ministry describes the measure as a way to understand export demand, improve management and prevent risk. Registration is not the same as final approval, and it does not make every entry a permanent restriction. It does mean that companies cannot treat the consultation period as a no‑rules gap for the technologies named in the notice. Organizations considering a transaction should use the official Chinese text and specialist legal advice for the exact item. A summary cannot determine whether a particular license, research collaboration or cloud service is an export of controlled technology.

The United States and allies have used chip, equipment and software controls to limit China’s access to advanced computing. China’s draft shows a different form of leverage: restrictions on exporting some of the AI technology developed inside China. That does not make the two regimes symmetrical. They cover different jurisdictions, items and legal tests. It does mean global AI companies may face controls in both directions — on the hardware they can obtain and the models or know‑how they can move. The business effects will depend on the final catalog, implementation guidance and licensing practice. The strongest near‑term signal is procedural: the comment window closes November 15, while registration duties already apply to the announced technologies. *Figure by OpenTools Team; no third‑party expressive material used. It summarizes the official draft categories and consultation timeline without reproducing protected visual material.*