BIS Revises AI Chip Export Policy for China From Presumption of Denial to Case-by-Case Review

Summary

On January 13, 2026, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) released a final rule revising the license review posture for exports of advanced AI chips to China and Macau. The rule shifts the review standard for commercially available NVIDIA H200-equivalent and AMD MI325X-equivalent chips, and chips with lesser performance, from a "presumption of denial" to "case-by-case review." The rule became effective January 15, 2026. Exporters must meet specific certificati