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

On October 16, 2026, China's Ministry of Commerce and Ministry of Science and Technology issued Announcement No. 48, adding 23 AI technologies to the export control catalogue, including frontier model weights, agent architectures, and AI-enabled offensive cyber capabilities with specific technical thresholds. The announcement imposes an immediate pre-export registration requirement for restricted technologies, while the catalogue additions remain open for comment until November 15, 2026. Key controls target large-scale model weights meeting compute or parameter thresholds, advanced AI agents for critical infrastructure, and transfers of ownership or licensing to foreign entities, though API and SaaS access do not count as exports.