China proposes controls on 23 AI technologies while excluding APIs

China has opened a public consultation on adding 40 technologies to its national catalog of prohibited or restricted exports. The package covers 23 artificial intelligence technologies, five in biomedicine and 12 related to photovoltaic manufacturing. In AI, the government identifies large models, agents, computing clusters and information processing.

The revision is not yet a final rule. The Ministry of Commerce and Ministry of Science and Technology are accepting comments from October 16 through November 15, 2026. A temporary measure nevertheless began with the consultation: exporters must register covered technology transactions before proceeding, including transfers that have started but remain incomplete.

The controls target technology, not every form of access

The most important distinction is between transferring technology and offering a service powered by it. Official guidance says an overseas localized deployment can fall under the regime when it moves restricted technology out of China. By contrast, providing a model through an API, app, website, software-as-a-service product or lightweight on-device deployment is not, by itself, treated as exporting the large-model technology.

The proposal therefore does not automatically block international use of Chinese AI services. Reuters assessed that companies such as DeepSeek and Alibaba could continue expanding foreign access through online services while Beijing gains greater oversight of sensitive technical transfers. That outcome is an inference from the announced structure, not a guarantee about the business decisions of any company.

The official notice also distinguishes open source and knowledge already made public. Technologies that have entered the public domain through open-source projects or academic papers would remain outside the catalog. For other activities, including releasing technology openly, building self-operated computing centers abroad, manufacturing chips overseas, conducting joint research and participating in international standards, the government promises automatic licenses or simplified procedures.

Temporary registration already changes transactions

While consultation continues, registration covers transfers of intellectual-property ownership, licensing Chinese technology for use abroad, and changing a technology’s owner or controller to a foreign entity. Companies must provide information about the parties, destination country or region, technology, intended use and estimated value. Registration is not the same as prohibition, but it gives regulators visibility before the final catalog takes effect.

The government says the controls are intended to prevent systems capable of autonomously generating or modifying malicious code from being used against critical infrastructure, defense or government services. The Associated Press also identified proposed controls for advanced models trained on sensitive national data and agents designed for critical environments. The proposal does not name specific companies or models.

A more granular boundary for AI circulation

The structure creates three practical layers. Knowledge already in the public domain remains free; remotely accessed services are separated from transfer of the underlying technology; and exports that move ownership, control or sensitive deployment abroad may require registration, licensing or prohibition. The distinction attempts to preserve international business while adding oversight to capabilities considered strategic.

For foreign developers and companies, the immediate change is not loss of access but greater importance for distribution format. Consuming an API differs from receiving model weights, training methods, agent systems or infrastructure for local operation. The final impact will depend on the catalog adopted after consultation, its technical thresholds and how licenses are applied. Until then, claims that China has banned exports of open models or ended international access go beyond what the published documents support.