China starts interim filing for outbound AI technology transfers as firms review delivery, licensing and control changes
China’s Ministry of Commerce and Ministry of Science and Technology on Oct. 16, 2026 issued Announcement No. 48, proposing to add 40 technologies across artificial intelligence, biomedicine and photovoltaics to the Catalogue of Technologies Prohibited and Restricted from Export, with 23 items tied to AI. While the catalogue revision is open for public comment through Nov. 15, the authorities have already launched a pre-export interim filing requirement for technologies listed in the annex. The filing scope goes beyond outright transfers of ownership. It also covers overseas licensing, situations where a domestic technology owner or actual controller becomes a foreign entity, and exports that have already started but are not yet complete. The article says AI companies should immediately review overseas deployment plans, licensing deals, R&D cooperation and equity transactions against actual technical deliverables rather than contract labels alone. It also lays out what companies should prepare: a deliverables list covering model weights, code, documents, deployment scripts, support permissions and update services; records for open-source disclosures; ownership and control-chain checks for financing or M&A; filing materials through the Ministry of Commerce platform; contract clauses that leave room for regulatory procedures; and a parallel review of cross-border data flows under the Personal Information Protection Law.




