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TLDR
China's draft AI export rule requires registration for models over 2 trillion parameters, but open releases can get automatic licensing. Moonshot's Kimi K3.1 Pro (2.8T parameters) is the first model affected, with weights promised by November 4th. The real question is whether registration clears before that date, as the final rule isn't due until mid-November.
Key points
Kimi K3.1 Pro has 2.8 trillion parameters, exceeding the 2 trillion threshold in China's draft export rule.
Moonshot has promised free weights for K3.1 Pro by November 4th.
The draft rule requires registration before exporting weights, but open releases may get automatic licensing.
Deep Seek and MiniMax have already completed registration under the draft rule.
The final rule is expected after comments close in mid-November, after the promised weight release date.
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Transcript (captions)
KimiK 3.1 Pro has 2.8 trillion parameters past the 2 trillion line in China's new draft AI export rule. Moonshot's promised the free weights by November 4th. It's earlier KimiK 3 is
the same size, but its weights are already public, so the rule leaves them alone. K3 1 Pro is Moonshot's first release that has to clear it. The obvious read, cross the line, and the
weights can't leave China. The draft doesn't say that. It asks Moonshot to register before exporting, and the Commerce Ministry spokesperson says open releases get an automatic license.
The scariest thing in the text is a form. Picture a customs desk, but for technology. A model has to check in there if it meets any one condition. It's size, it's training compute, or a
ranking among the world's leading models. What's controlled is the core. Weights, checkpoints, source code, training methods. Before any of it leaves the country, the company
registers with the Commerce Ministry. Weights that are already public, like the ones in K3, walk right past the desk. A brand new open release can't. It registers, then gets the fast lane,
automatic licensing. That split is how I read the announcement and the spokesperson together. The Ministry hasn't spelled it out. The customs picture breaks in one place. Nobody's
published what this desk checks, or how long the stamp takes. Deep Seek and MiniMax already went through. Six days after the draft, Yu Yuan 10 Tian, a social account tied to state broadcaster
CCTV, said both had finished registration and the open source paperwork. The report doesn't name the models, and their current flagships sit under the size line. So, the desk opens.
Nobody's shown yet how fast it opens for something this big. For you, it splits in two. The Ministry says the API you call today isn't an export at all. The weights are about timing. There's no
word on whether Moonshot has filed, and the final rule only comes after comments close in mid-November, after the weights are due. If you're building on these weights, I'd plan for the promised date,
and keep the API as your fallback. Nothing the draft bans the release. So, the real question is a date. Does Moonshots registration clear before November 4th?