Frontier Log

China Asks for Registration, Not Approval

by Zhu Liang

What China's Announcement No. 48 asks of AI exporters, and the Chinese open-weight releases since, as the official texts date them.

Three bullets above a timeline and a decision tree: on Oct 16, China's commerce and science ministries proposed export controls on 23 AI technologies, among them large models and agents; until the revised catalogue takes effect, exporters must register before any export; once it does, a licence is needed only for what it lists as restricted. Timeline: Oct 16, registration starts; Nov 15, comments close; the revised catalogue, date not set. Tree: exporting one of the 23 AI technologies; already open-sourced or published? Yes: out of scope. No: revised catalogue in effect? Not yet: register with the Ministry of Commerce, then export (in red). Yes: is it listed? Restricted: apply for a licence, review up to 30 working days, export with a licence. Prohibited: no export.

China's AI Exports: Register Now, a Licence Only If Listed

What exporters do now and under the catalogue

Until the revised catalogue takes effect, exporters register and then export. Once it does, a listed technology needs a licence if restricted, after a review of up to 30 working days, and may not be exported if prohibited.

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A list of dates. Oct 16: China requires registration to export AI. From the Ministry of Commerce (MOFCOM) and the Ministry of Science and Technology (MOST); export controls proposed on 23 AI technologies, among them large models and agents; registration required before any export, from that day; technology already open-sourced or published is out of scope. Oct 17: DeepSeek-V4.1-Flash-1017 launches, with weights. Oct 19: MiniMax M3.1 Flash launches, without weights. Oct 23: MiniMax says it has registered, in a filing to the Hong Kong exchange. Oct 23: MiniMax M3.1 Flash weights released. Oct 24: Kimi K3.1 Pro launches, without weights (Moonshot AI). Nov 4: Kimi K3.1 Pro weights expected. Nov 15: comments on the rule close, expected. The rule and MiniMax's registration are in red.

China's AI Export Registration

One lab says it has registered so far

Since Oct 16, exporting any of 23 AI technologies requires registration, not a licence. DeepSeek launched with weights the next day; MiniMax and Moonshot launched without, and only MiniMax has said it registered, in a filing to the Hong Kong exchange.

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Timeline

DateWhat happened
China's Ministry of Commerce (MOFCOM) and Ministry of Science and Technology (MOST) require a licence to export a technology the catalogue restricts国家对列入《中国禁止出口限制出口技术目录》的限制出口技术实行许可证管理，凡出口国家限制出口技术的，应按本办法履行出口许可手续。MOFCOM and MOST, ministerial order
MOFCOM and MOST propose adding 23 AI technologies to the export control catalogue人工智能领域包括大模型、智能体、算力集群、信息处理相关23项技术；对已通过开源、发表学术论文等方式进入公共领域的技术，不纳入管理范围。MOFCOM and MOST, government announcement
MOFCOM and MOST require registration before exporting them, from the same day自本公告发布之日起，至《中国禁止出口限制出口技术目录》正式修订并实施之日止，技术出口经营者在出口本公告附件所列技术前，应当在商务部业务系统统一平台技术贸易管理信息应用（https://ecomp.mofcom.gov.cn）登记。MOFCOM and MOST, government announcement
MOFCOM and MOST take comments until Nov 15公众可在2026年10月16日-11月15日期间，通过以下途径，就新增技术范围、指标、管控政策、便利措施等提出意见MOFCOM and MOST, government announcement
DeepSeek releases DeepSeek-V4.1-Flash-1017 with open weightsOpen-source release Get DeepSeek-V4.1-Flash-1017: Hugging Face: https://huggingface.co/deepseek-ai/DeepSeek-V4.1-Flash-1017DeepSeek, news post
MiniMax launches M3.1 Flash, its weights to followModel weights will be released later.MiniMax, blog post
MiniMax tells the Hong Kong exchange it has registeredthe Company has duly completed the technology export registration procedures with the Ministry of Commerce required for the open-source release and overseas licensing of certain recently released and upcoming modelsMiniMax, HKEX announcement
MiniMax releases M3.1 Flash's weightsMiniMax, Hugging Face model page
Moonshot AI launches Kimi K3.1 Pro, weights by Nov 4Full model weights will be released by Nov 4, 2026.Moonshot AI, blog post

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