The first two names on the register

The open question when the proposal landed on 16 October was whether registration would work as a record or as a filter. Six days after the temporary registration requirement began, a CCTV-affiliated account reported that DeepSeek and MiniMax had completed the process. Neither the ministry nor the companies supplied public registration records in the reporting reviewed for this article.

The two are the Chinese labs whose open releases travel furthest, and both kept to their release schedules that week: DeepSeek open-sourced DeepInfer, its inference framework, on 20 October, and MiniMax released its M3.1 Flash weights on 23 October. Those dates describe the companies' release schedules. They are not evidence about how the registration system treated either filing.

There is also a sourcing limit readers should keep. The completion news comes from one account, Yuyuan Tantian, affiliated with state broadcaster CCTV, and reassurance is part of its message: it urged companies to remain calm, and described the revision's core as drawing boundaries rather than restricting AI technology exports. That does not make the registrations invented. It does mean the first public account of the system working is the regulator's own side telling the story. The state-media disclosure presents the new registration process as compatible with continued international AI distribution. The reported DeepSeek and MiniMax cases are consistent with that message, but without public filing records, processing times or refusal statistics, they cannot establish how the system operates more broadly.

What the filing actually covers

The temporary rules, set out in Announcement No. 48 of 16 October, attach to transactions, not to downloads. Registration is required before exporting a technology listed in the announcement where a company transfers technology ownership overseas, including intellectual property; licenses domestic technology for use outside China; sees the owner or actual controller of the technology become a foreign entity; or falls into another circumstance MOFCOM expressly designates by notice or similar means. It applies even to exports already under way but not finished, and filings go through the technology trade management application on the commerce ministry's unified business platform.

Three mechanisms need to stay separate. Registration is the filing above: a pre-export record of a covered transfer, made by the exporter. Automatic licensing is a different thing, a simplified licensing route the commerce ministry spokesperson described for specified situations under the proposed catalogue, including open-sourcing AI technology, Chinese companies building and running their own computing centres overseas, joint research using overseas resources, and deploying a restricted model on a company's own overseas cloud; the spokesperson said such cases would basically achieve “report and export”. A restrictive export licence is different again: the authorisation a restricted technology would need once the catalogue takes effect. The reported completions concern the first mechanism only.

The boundaries around the filing duty are where the practical meaning sits. Technology that has already entered the public domain, through an open-source release or an academic paper, is outside the proposed management scope; that is a statement about a technology's status, not a way to escape a filing for a transfer already under way. Serving a restricted model through an API, an app, a web interface or a SaaS product does not count as exporting the large-model technology, and neither does lightweight deployment on a device. Local deployment of a restricted model overseas does count.

The stated reason for the restricted list is narrow and security-framed. The commerce ministry spokesperson named AI-driven generation and mutation of malicious code, which could be used to attack critical information infrastructure, defence and core government systems, among the technologies proposed for prohibition, and AI-assisted vulnerability discovery among those proposed for restriction.

What changes, and what does not

For a team outside China building on Chinese open models, the position after this week is specific rather than dramatic. Hosted access is unchanged on the ministry's own account. Where a filing duty arises, it sits with the exporter and the transaction (an ownership transfer, a licence, a change of control), not with everyone who downloads public weights; whether a given arrangement needs registration, or later a licence, depends on the technology and the deal. The ministry also says the vast majority of AI technologies will remain freely exportable once the measures are formally in force.

Public consultation closes on 15 November. The next decisive development will be the final catalogue and its implementation rules, for which the notice does not establish a publication date.

Sources

  1. [1] Ministry of Commerce and Ministry of Science and Technology, Announcement No. 48 of 2026, 16 October 2026 (draft revision of the Catalogue of Technologies Prohibited or Restricted From Export opened for public comment; temporary pre-export registration: the registration period, the filing platform, in-progress exports, and the four registration triggers, including other circumstances MOFCOM designates; read in the original Chinese, official text as released by the Ministry of Commerce)Read source
  2. [2] Ministry of Commerce spokesperson, Q&A on the catalogue revision, 16 October 2026 (public-domain exclusion; API, app, web, SaaS and lightweight on-device access outside large-model export management; overseas local deployment inside it; automatic licensing for specified situations, described as basically “report and export”; the vast majority of AI technology remains freely exportable; read in the original Chinese)Read source
  3. [3] Yuyuan Tantian disclosure of 22 October 2026, as reported by Reuters on 23 October 2026 (both companies completed the registration procedures, and completed open-sourcing and overseas licensing use; Reuters relaying the state-media account)Read source
  4. [4] Tech360, “DeepSeek and MiniMax Clear Export Registration as Beijing Calms Fears”, 23 October 2026 (relaying South China Morning Post reporting on the Yuyuan Tantian disclosure; filing triggers and the ministry spokesman's exclusions)Read source
  5. [5] EL7.AI, “DeepSeek, MiniMax Complete Overseas Use Procedures”, 23 October 2026 (reporting Hsin Pao; transitional registration period, unified-platform filing route, already-begun exports clause, malicious-code rationale, 15 November consultation close)Read source
  6. [6] CryptoBriefing, “DeepSeek and MiniMax reportedly first to clear China's new AI export registration”, 23 October 2026 (corroboration of the first-completion framing, citing Reuters on the proposal's scope)Read source
  7. [7] Background on this site: “China Wants to Licence AI Model Exports. API Access Is Exempt.”, alfw.ai, 16 October 2026, the original proposal and its exclusionsRead source