The draft has defined limits. Underlying technologies would face export restrictions if a model is trained on what officials call important data, if it has at least 2 trillion parameters, or if it ranks in the global top 10 on criteria including performance, usage and safety. Open-source material is excluded. Access through application programming interfaces, websites, apps and software-as-a-service platforms would remain outside the restrictions, according to Reuters. Most technologies would still be exportable, and licensing would be simplified for some. The registration requirement for covered technologies takes effect immediately, on October 16, 2026. Public comment runs until November 15, after which Beijing will issue a final version. Details of how the registration process will work are not yet public.
The draft follows rising US-China technology restrictions and consultations in July 2026 with firms including Alibaba and ByteDance, which focused on limits on data transfers. Chinese models named as examples of those that could fall under the rules include Moonshot AI's Kimi K3 and Alibaba's Qwen3.8-Max. The move also lands against a fragile trade truce struck last month, under which both countries agreed to cut tariffs and open an AI dialogue. Companies in cross-border deals, IP licensing or AI model distribution should assess now whether their transactions trigger the interim registration requirement, since it applies while the comment period is open. The rules are still a proposal, so the final scope could change before November 15.