Export Policy
GPT-5.6 Deployment Now Requires Per-Customer Clearance
Export controls that once applied at the model level now require approval for each customer. The granularity of regulation just got finer.
The unit of approval is now the customer
According to THE DECODER, deploying GPT-5.6 now carries a new condition: per-customer government clearance. Previously, export rules targeted the model itself, leaving the choice of which companies to serve to the provider's discretion. Under the change, each recipient must pass a government review.
Until six months ago, export controls operated at the model level, and per-company vetting was not required. Regulators appear to have judged that the model's capabilities crossed a threshold, narrowing the exit point for distribution.
Regulation granularity, before and after
What enterprises should do now
Add an application step to procurement
If GPT-5.6 is on your roadmap, budget time for government clearance separately from the contract itself.
Inventory your downstream recipients
Prepare for per-customer review by mapping out end users and resellers.
Scope the impact
Startups and individual developers face no immediate effect. Prioritize based on your scale.