BIS: End-user Changes and Recordkeeping Requirements

The Commerce Department’s Bureau of Industry and Security has issued a notice in the Federal Register establishing a process for parties to request changes to the authorized end-user, end-use, and/or destination associated with certain hardware authorizations and Open General Licenses.

The notice was filed for public inspection on January 20, 2026, and is scheduled for publication on January 21, 2026 (FR Doc. No. 2026-01018). The five-page document outlines procedural requirements for submitting change requests, including the information applicants must provide and the conditions under which BIS will review and act on such requests.

According to the notice, the process is intended to address circumstances in which an authorization holder seeks to modify previously approved parameters—such as a change in the identity of the end-user, the nature of the end-use, or the ultimate destination—without submitting a new license application.

The notice also clarifies the scope of eligibility and the review standards BIS will apply.

The action takes effect upon publication and applies to covered hardware authorizations and Open General Licenses administered by BIS.

Request to Change End-user, End-use and/or Destination of Hardware and Open General Licenses

Screening, Non-Disclosure Recordkeeping

BIS also issued a notice addressing requirements for screening records and non-disclosure agreements in connection with BIS-administered authorizations.

The notice was filed for public inspection on January 20, 2026, and is scheduled for publication on January 21, 2026 (FR Doc. No. 2026-01017).

The four-page document sets out recordkeeping expectations related to screening activities and specifies when non-disclosure agreements are required, as well as the minimum elements such agreements must contain.

According to the notice, the requirements are intended to support BIS oversight and compliance by ensuring that parties retain adequate documentation of screening processes and protect sensitive information obtained in the course of those activities. The notice also clarifies the scope of applicability and the duration for which records must be maintained.

The provisions take effect upon publication and apply to parties subject to BIS screening and related compliance obligations.

Screening Records, and Non-Disclosure Agreements