China's First Frontier AI Export Controls: Mofcom Announcement No. 48

On October 16, 2026, MOFCOM and MOST issued Announcement No. 48, proposing to add 40 technologies to China's export catalogue—23 of them in AI, covering frontier model weights, agent architectures, and offensive cyber capability—while an interim pre-export registration requirement is already in effect. The catalogue additions are a draft open for comment until November 15, 2026, whereas registration applies now, including to exports already started but not yet complete, and is triggered by licensing for overseas use or changes of ownership or control. MOFCOM says API, app, web, SaaS, and lightweight on-device use do not count as exporting a large model, but local deployment of a restricted model outside China does, and open-sourcing a new restricted model requires reporting under automatic licensing.