US BIS extends suspension 50% rule coming into force until 10 January 2027

9 November 2026

The US Bureau of Industry and Security (BIS) has published a final rule extending the suspension of the 50% rule to its export control list under the Export Administration Regulations (EAR) until 10 January 2027.

BIS introduced the 50% rule, also known as the Affiliates Rule, in September 2025. It extends Entity List restrictions to any entity that is at least 50% owned, directly or indirectly, by one or more listed entities. BIS suspended the rule for 1 year in November 2025, following a US–China trade agreement.

When the rule takes effect, unlisted subsidiaries of listed entities will face the same licence requirements as their listed owners. Exporters will need to check who owns their customers and other parties to a transaction, not only whether those parties are named on the Entity List.

While the rule is suspended, the position before September 2025 applies. Entity List licence requirements apply only to entities named on the list. An unlisted company is not caught just because a listed entity owns it. See our US export control pages for overviews and guidance on US export controls and the Entity List.