중국이 AI 에이전트를 포함한 23개 AI 기술에 대한 수출 통제를 제안했으며, 이는 반도체를 넘어 규제를 확대하는 조치다.

For the first time, Beijing is proposing outbound export controls on AI technologies, targeting the export of Chinese AI intellectual property and infrastructure. The draft catalogue covers 40 technologies, 23 of which target the AI stack directly.

China's Ministry of Commerce and Ministry of Science and Technology issued Announcement No. 48 of 2026 on October 16, signaling a fundamental shift in the nation's approach to AI governance. Previous regulatory efforts focused on restricting inbound access to foreign models or managing the behavior of domestic AI agents. This proposal instead targets the export of Chinese AI intellectual property and infrastructure.

The 23 AI-stack technologies range from large language models (LLMs) and AI agents to computing clusters and chip design methodologies. Under the proposal, 14 of the technologies would be prohibited from export, and 26 would be restricted, requiring specific licenses for transfer. The scope is granular. It covers model weights and source code that exceed performance thresholds, specifically models with two trillion or more parameters or models ranking in the world's top 10 on performance and safety benchmarks. For AI agents, the controls apply to those designed for sensitive environments, including national defense and critical information infrastructure.

This move creates a bidirectional squeeze on the global agent infrastructure stack. Builders and investors have long navigated U.S. restrictions on advanced compute, which limit China's access to high-end hardware. Now China is mirroring that strategy by regulating the outflow of its own frontier AI software and IP. The proposal requires that any cross-border transfer of technology ownership, IP licensing, or change in control to overseas entities undergo a registration process. The interim measure took effect on October 16, even though the final catalogue remains under public consultation until November 15, 2026. Transactions that have already begun but are not yet complete are also subject to the registration requirement.

Despite the breadth of these controls, the proposal includes carve-outs that preserve current operational pathways for Chinese AI firms. Technologies already in the public domain through open-source releases or academic publications are excluded from the restrictions. The proposal also distinguishes between technology transfer and service access. While the overseas deployment of restricted AI models is controlled, API and SaaS access remains exempt. This allows companies such as DeepSeek and Alibaba to continue serving global customers through cloud-based interfaces without triggering the new export licensing requirements.

For builders and infrastructure providers, the distinction between service access and technology transfer is critical. The proposal targets underlying assets, such as the on-premise redistribution of model weights or the self-hosted deployment of advanced Chinese agents, rather than the consumption of AI capabilities through an API. However, the inclusion of chip design tools and EDA vendors in the registration requirements adds a new layer of diligence for firms involved in cross-border M&A or collaborative hardware development. Deal timing and ownership-change diligence are now essential components of any transaction involving Chinese AI assets.

As the industry awaits the close of the public comment period, questions remain about how the registration requirements will be enforced. The immediate implementation of the interim measure suggests a high priority on monitoring the movement of frontier IP. Builders operating in the agent space should assess their reliance on Chinese-developed model weights and the potential impact of these controls on their supply chains. While the current carve-outs provide a degree of stability for cloud-based operations, the regulatory landscape for AI infrastructure is entering a more restrictive phase, in which the movement of software is treated with the same strategic sensitivity as the movement of silicon.