Will DeepSeek be added to the Chinese Military Companies list by June 30, 2027?

- [2025-12-18/19] Nine Republican lawmakers (Moolenaar, Garbarino, Crawford, Scott, et al.) sent a formal letter to the Pentagon urging it to add DeepSeek and 16 other firms to the Section 1260H list, citing a State Department official's claim that DeepSeek "has willingly provided and will likely continue to provide support to China's military and intelligence operations," citing its appearance in more than 150 procurement records for the PLA . https://homeland.house.gov/2025/12/19/chairmen-garbarino-moolenaar-crawford-lead-letter-asking-pentagon-to-list-deepseek-gotion-unitree-and-wuxi-as-chinese-military-companies/ - [2026-06-08] DoD/Department of War published its updated Section 1260H list (the question's baseline list), expanding it to 188 entities by adding 65 entities (17 parent companies and 48 subsidiaries)… Notable additions include Alibaba Group Holding Limited (Alibaba), Baidu, Inc. (Baidu), BYD Company Limited (BYD) and WuXi AppTec Co. Ltd. DeepSeek was not among the named additions. https://www.hklaw.com/en/insights/publications/2026/07/department-of-war-updates-section-1260h - [2026-06-08] Baker McKenzie's primary-source summary confirms the update was published via an official DoD press release and links the official PDF list, with no mention of DeepSeek among additions. https://sanctionsnews.bakermckenzie.com/us-government-updates-1260h-list-of-chinese-military-companies/ - [2026-06-17/18] Reuters reported separately (Commerce Dept Entity List, a different instrument than 1260H) that the US has held off adding China's AI startup DeepSeek, memory chipmaker CXMT and more than 100 other companies flagged as national security risks to a trade blacklist… DeepSeek, CXMT and other companies were approved by an interagency committee last year for addition to the Commerce Department's Entity List , with the White House deliberately delaying action to avoid escalating tensions with Beijing ahead of Trump's state visit to China. https://www.malaymail.com/news/world/2026/06/18/deepseek-cxmt-among-chinese-firms-awaiting-us-entity-list-action-as-washington-weighs-trade-risks/224127 - [2026-06-30] Per the June 8, 2026 1260H update, DoD procurement restrictions on listed entities took effect; a further restriction on contracting for goods/services produced by listed entities takes effect June 30, 2027 (the same date as this market's deadline), per DoD Procurement Restrictions: Effective June 30, 2026, DoD is prohibited from procuring goods, services, or technology from entities on the 1260H List. In addition, effective June 30, 2027, DoD is prohibited from contracting for goods and services produced or developed by an entity on the 1260H List . https://sanctionsnews.bakermckenzie.com/us-government-updates-1260h-list-of-chinese-military-companies/ - [2026-06-09] Separately, at least one newly listed company sued DoD in D.C. federal court seeking removal from the 1260H list, underscoring that the list remains subject to legal challenge and is not static. https://www.lexology.com/library/detail.aspx?g=d14c7a45-bf2a-4695-9356-608478fada1f - [2026-10-06] No subsequent DoD/Department of War announcement, Federal Register notice, or credible press report was found indicating any update to the 1260H list since June 8, 2026, nor any report that DeepSeek specifically has been added. A recent AI-industry morning brief from October 6, 2026 discussing Pentagon AI policy and DeepSeek news made no mention of 1260H listing. https://deepgains.substack.com/p/morning-brief-tuesday-october-6-2026-161 - [2026-10-06] Current DeepSeek news centers on commercial matters (model releases, a reported ~$12 billion Tencent-backed funding round) rather than any new US government listing action. https://deepgains.substack.com/p/morning-brief-tuesday-october-6-2026-161 NOT FOUND: No official DoD/Department of War announcement or Federal Register notice of a post-June 2026 update to the 1260H list; no confirmed report that DeepSeek has been added to either the 1260H list or the Commerce Entity List as of October 7, 2026; no scheduled date for the next 1260H list update before June 30, 2027 (the list has historically been updated roughly annually — Jan 2025, June 2026 — so a future update could plausibly land within the market window, but no confirmed schedule was found). BOTTOM LINE: As of October 7, 2026, DeepSeek is NOT on the official Section 1260H list (last updated June 8, 2026, with 188 entities, none of which is DeepSeek), despite sustained bipartisan congressional pressure since December 2025 to add it; a parallel Commerce Department Entity List action against DeepSeek was also reportedly approved internally but deliberately withheld by the White House as of mid-June 2026 for diplomatic reasons, suggesting political will exists but near-term executive action has been intentionally stalled.

- [2026-06-08] The DoW published the current 1260H list naming 188 entities (80 primary designees, 108 subsidiaries), an expansion from 134 in January 2025; it names 188 entities, primary designees and their explicitly identified subsidiaries , but DeepSeek was not among them. Source: https://sayari.com/resources/blog/1260h-list-update/ - [2025-12-18] Nine (later described as bipartisan) congressional lawmakers led by Reps. Moolenaar, Garbarino and Crawford sent a letter urging DoD/DoW to add DeepSeek, Gotion, Unitree, WuXi AppTec and 15 other firms to the 1260H list, arguing they "represent military-civil fusion contributors central to China's military modernization, internal-security operations, and power-projection capabilities" . Source: https://exportcompliancedaily.com/news/2025/12/23/Lawmakers-Urge-Adding-DeepSeek-Gotion-to-DODs-1260H-List-2512190085 - [2026-06-08/10] Of the firms named in the December 2025 letter, Unitree, WuXi AppTec and RoboSense (plus Hesai's affiliated sector) were added in the June 2026 update, per "First-time additions include state-empowered internet giants such as Alibaba and Baidu, EV big-shots BYD and NIO, one of the world's largest robotics firms – Unitree, biotech major WuXi AppTec, networking vendor TP-Link, LiDAR suppliers Hesai and RoboSense" — but DeepSeek, Gotion and Xiaomi were left off despite being explicitly requested. Source: https://takshashila.org.in/content/blogs/1260H-US-China-15062026.html - [2026-06-17/18] Reuters reported that an interagency committee had already approved DeepSeek (along with CXMT and 100+ other firms) for the separate Commerce Department Entity List "last year," but "DeepSeek, CXMT and other companies were approved by an interagency committee last year for addition to the Entity List" yet the listing was withheld, reportedly to avoid escalating tensions ahead of a Trump-Xi meeting. Source: https://www.taipeitimes.com/News/biz/archives/2026/06/18/2003859278 - [2026-06-21] A related outlet summarized that "an interagency US committee approved DeepSeek, CXMT and more than 100 other companies for addition to the Entity List. But the Commerce Department has not published those additions" , underscoring a deliberate political hold rather than a lack of evidentiary basis. Source: https://memeburn.com/us-holds-off-deepseek-blacklist-as-china-ai-tensions-rise-in-2026/ - [2026-06 (reporting)] A commentary piece noted the asymmetry explicitly: "the Pentagon found room for Alibaba, Baidu, BYD, ChangXin Memory Technologies and Yangtze Memory Technologies, but not DeepSeek. That omission matters because DeepSeek is not a side character in this fight" , tying the omission to DeepSeek's ties with China's national AI investment fund. Source: https://startupfortune.com/the-us-government-just-gave-deepseek-a-quiet-pass-while-blacklisting-more-than-100-other-chinese-firms/ - [2026-06-30] Law-firm analysis confirms the statutory base rate/pattern of updates: "Since its initial release with 47 entities, the Section 1260H List has expanded steadily across administrations" with updates in October 2022 (+13), January 2024 (+16/-3), January 2025 (+71/-6 to 134), and June 2026 (+65/-10 to 188) — an irregular ~12-18 month cadence rather than a fixed calendar date. Source: https://www.hsfkramer.com/notes/sanctions/2026-posts/us-department-of-war-expands-section-120h-list-to-188-chinese-military-companies - [2026-06-30] The statute requires the Secretary to publish updates "no less frequently than annually" through December 31, 2030, meaning a legally mandated refresh must occur sometime before June 30, 2027 (the market's deadline), giving at least one more scheduled opportunity for DeepSeek's addition within the window. Source: https://www.hsfkramer.com/notes/sanctions/2026-posts/us-department-of-war-expands-section-120h-list-to-188-chinese-military-companies - [2026-01 era] Prior precedent shows Pentagon action sometimes follows internal executive-branch signals well before formal listing — lawmakers noted they "applaud recent actions taken by the Department, including the addition of Tencent to the 1260H list in January, as well as reports that an October 7 letter from Deputy Secretary of War Stephen Feinberg informed the Armed Services Committees that Alibaba, Baidu, and BYD should be added" months before their actual June 2026 listing — suggesting a lag of roughly 6-8 months between internal recommendation and public listing for companies that do eventually get added. Source: https://homeland.house.gov/2025/12/19/chairmen-garbarino-moolenaar-crawford-lead-letter-asking-pentagon-to-list-deepseek-gotion-unitree-and-wuxi-as-chinese-military-companies/ - [2026-06] No equivalent internal recommendation letter or signal specific to DeepSeek's 1260H status (as opposed to the separate Commerce Entity List) has been reported; the only confirmed executive-branch stance is the broader "holding back" strategy on AI-sector Chinese firms described in Reuters coverage. Source: https://parameter.io/trump-administration-stalls-trade-blacklist-for-deepseek-and-100-chinese-tech-companies/ BOTTOM LINE: The historical base rate for a specifically, repeatedly-lobbied Chinese tech company eventually appearing on the 1260H list is moderate-to-favorable once an internal executive recommendation surfaces (e.g., Alibaba/Baidu/BYD took ~8 months from internal signal to listing), and the list has grown every cycle (47→188 entities); however, DeepSeek is a documented outlier that was explicitly requested by Congress in Dec 2025 but was deliberately excluded from the June 2026 update alongside a broader, admitted political pause on AI-related China blacklisting tied to trade-relationship management with Beijing, implying the base rate for DeepSeek specifically is lower than for a "generic" nominated firm. NOT FOUND: No evidence of an internal DoD/DoW recommendation letter specifically naming DeepSeek for 1260H designation (unlike the Alibaba/Baidu/BYD precedent); no confirmed date for a next scheduled 1260H list update in 2027; no official DoD/DoW statement explaining why DeepSeek was omitted from the June 2026 list.

YES means: DeepSeek (or its parent/subsidiary) appears on an updated Section 1260H list published by DoD/Department of War between now and June 30, 2027, 11:59 PM ET, regardless of enforcement or later withdrawal. - [2025-12-18] Nine House/Senate Republicans, led by Moolenaar and Garbarino, explicitly petitioned the Pentagon to add DeepSeek to 1260H, citing a senior State Department official's claim that DeepSeek "has willingly provided and will likely continue to provide support to China's military and intelligence operations," citing its appearance in more than 150 procurement records for the PLA , plus alleged GPU-smuggling via Southeast Asian shell companies — an evidentiary basis already on record that DoD would not need to newly build. (https://homeland.house.gov/2025/12/19/chairmen-garbarino-moolenaar-crawford-lead-letter-asking-pentagon-to-list-deepseek-gotion-unitree-and-wuxi-as-chinese-military-companies/) - [2026-01-29] Select Committee Chairman Moolenaar sent a further letter to Commerce Secretary Lutnick asserting DeepSeek is "now integrated into People's Liberation Army (PLA) systems and a demonstrated cyber security risk," and that it "routes Americans' data back to the PRC through infrastructure tied to a U.S.-designated Chinese military company...and runs on advanced NVIDIA chips restricted from export to China" — showing sustained, escalating congressional documentation of exactly the kind of military-tie evidence 1260H designation requires, continuing into 2026 rather than fading after the December 2025 letter. (https://chinaselectcommittee.house.gov/media/press-releases/moolenaar-nvidia-products-used-by-deepseek-people-s-liberation-army) - [2026-06-08] The June update demonstrates the Pentagon does act on congressional 1260H nomination lists: of the 17-19 firms named in the December 2025 letter, Unitree, WuXi AppTec, RoboSense, BOE and Tianma were all added, confirming Moolenaar's lobbying list has a strong hit rate even if DeepSeek itself was held back that cycle. (https://chinaselectcommittee.house.gov/media/press-releases/moolenaar-american-companies-governments-should-cut-ties-with-new-pentagon-listed-chinese-military-companies) - [2026-06-18] Reuters' reporting confirms DeepSeek already cleared the interagency national-security vetting bar for the separate Commerce Entity List — an interagency committee purportedly recommended the addition of the Chinese AI startup after a senior U.S. State Department official said that the firm supported Chinese military and intelligence operations — meaning the executive branch's own security agencies, not just Congress, have endorsed restrictive action against DeepSeek; a parallel 1260H addition would not require new fact-finding, only a political decision to publish. - [2026-09-23] The White House fact sheet from the Trump-Xi summit shows export controls were explicitly "kept off the negotiating table," per Daily Signal's analysis, and the renewed trade truce extension of only two months, far short of China's requested two-year extension, shows that the U.S. is not satisfied with China's follow-through — indicating Washington deliberately preserved its leverage/toolkit rather than permanently foreclosing future blacklisting actions against Chinese tech firms. - [2026-09-24] The truce extension runs only to January 2027, and President Trump and Chinese President Xi Jinping concluded a high-stakes, three-day state visit in Washington, securing an extended commercial truce and establishing a new dialogue on artificial intelligence, while fundamental geopolitical disputes remained largely intractable — leaving a full five-month window (February–June 2027) inside the market's deadline after the truce lapses, during which the political constraint cited for withholding DeepSeek action could ease or reverse, especially if trade talks sour. - [2025-10/2026-06 precedent] The Alibaba/Baidu/BYD case shows the precise mechanism and lag: Deputy Secretary of War Feinberg's internal recommendation reported around October 7, 2025 led to their formal 1260H listing by June 8, 2026 — roughly 8 months. If an analogous internal DoD recommendation naming DeepSeek were made at any point before roughly October 2026, a parallel ~8-month lag would land a listing squarely within the market's window (before June 30, 2027); the statute's "no less frequently than annually" cadence guarantees at least one more official list refresh before the deadline, providing a concrete publication vehicle. - [2026-06-30 statutory mandate] Per the law firm analysis already on record, DoD is statutorily obligated to publish updates "no less frequently than annually" through 2030, meaning a new 1260H list update is legally required to appear before June 30, 2027 — guaranteeing at least one additional list-publication event inside the window in which DeepSeek could be inserted without any new legislative or procedural hurdle. - [2026-06] Commentary explicitly frames DeepSeek's June 2026 omission as anomalous rather than evidentiary: Bloomberg described the coal deal as the summit's "most specific pledge" and "an easy promise to keep," underscoring that the Trump-Xi rapprochement so far has focused on narrow, symbolic economic wins (coal, tariff carve-outs) rather than a comprehensive tech-sector truce, leaving room for unilateral U.S. national-security actions like 1260H listing to proceed on a separate track unaffected by the trade deal. BOTTOM LINE: The core prerequisites for a YES are already in place — explicit, repeated, evidence-backed congressional demands; an interagency security clearance for parallel Commerce action; a statutorily mandated annual 1260H refresh before June 2027; and a historical ~8-month internal-recommendation-to-listing precedent (Alibaba/Baidu/BYD) — so if the Trump administration's politically motivated hold (tied to trade diplomacy) eases after the truce expires in January 2027, a DeepSeek listing in the subsequent legally required update is a plausible, mechanistically well-supported path to YES within the window. NOT FOUND: No confirmed internal DoD recommendation letter specifically naming DeepSeek for 1260H (distinct from the Commerce Entity List track); no announced date for the next 1260H list update; no post-June-2026 Federal Register notice or DoD statement indicating DeepSeek is under active review for the next cycle.

YES means: DeepSeek (or a parent/subsidiary of DeepSeek) appears on an updated, officially published Section 1260H list of Chinese Military Companies between now and June 30, 2027 — so this NO-case dimension documents why that addition is unlikely to occur in the window. - [2025-12-18] Nine House/Senate Republicans explicitly petitioned DoD to add DeepSeek to the 1260H list, citing State Department claims it supported PLA procurement, yet the subsequent June 2026 update included Alibaba, Baidu, BYD, NIO, Unitree, WuXi AppTec, TP-Link, Hesai, RoboSense, BOE, CALB, EVE Energy and JA Solar — DeepSeek was conspicuously absent despite being the headline ask (https://takshashila.org.in/content/blogs/1260H-US-China-15062026.html). - [2026-06-08] The actual DoD list update, confirmed via Federal Register notice, added 65 entities (17 parents, 48 subsidiaries) bringing the total to 188, with no DeepSeek entry (https://governmentcontractsnavigator.com/2026/07/22/dow-updates-section-1260h-list-expanding-compliance-obligations-for-government-contractors/). - [2026-06-17] Reuters-sourced reporting shows the parallel, evidentially-stronger Commerce Entity List track for DeepSeek was also frozen: Since late 2025, Jeffrey Kessler, under secretary of commerce for industry and security, has sought to avoid listing Chinese parties for fear of escalating tensions between the US and China , a policy stance that plausibly extends to the sister 1260H process run through the same interagency structure (https://english.aaj.tv/news/330460377/us-delays-blacklisting-deepseek-over-100-chinese-firms). - [2026-06-17] The scale of the freeze is unprecedented: The US has not posted any additions to its Entity List since October, the longest stretch between new postings in more than a decade , indicating a systemic, not DeepSeek-specific, executive-branch reluctance to escalate China tech designations (https://english.aaj.tv/news/330460377/us-delays-blacklisting-deepseek-over-100-chinese-firms). - [2026-06-17] Diplomatic sequencing explains the timing: the hold was explicitly tied to the White House has held off updating its blacklist to avoid escalating trade tensions with Beijing, especially in the lead-up to President Donald Trump's three-day state visit to China — and per the broader timeline, Xi reciprocated with a US state visit in September 2026, meaning the diplomatic incentive to avoid provoking Beijing persisted through at least Q3 2026 (https://www.tomshardware.com/tech-industry/deepseek-was-set-to-be-added-to-us-entity-list-for-supporting-chinas-military-and-intelligence-operations-report-claims-white-house-holds-off-to-avoid-escalating-tensions-with-china; https://en.wikipedia.org/wiki/2026_state_visit_by_Donald_Trump_to_China). - [2026-06] Commentary also identified a domestic economic disincentive specific to DeepSeek (unlike other designees): If the White House were to add DeepSeek to the Entity List, it would likely face a backlash from American companies looking to leverage cheaper alternatives from competing Chinese brands — a constituency argument that doesn't apply to Alibaba/Baidu/BYD and may make DeepSeek a harder political sell even in a future update (https://www.yahoo.com/news/politics/articles/us-almost-blacklisted-deepseek-contributing-232000190.html). - [2026-06-30] Even already-listed companies are contesting the designation process itself, showing the mechanism is adversarial and slow: WuXi AppTec "has disputed its designation and is pursuing all possible remedies," and Novogene has similarly challenged its own listing, illustrating that DoD faces active legal/political pushback that could make it cautious about further, more contested additions like DeepSeek (https://governmentcontractsnavigator.com/2026/07/22/dow-updates-section-1260h-list-expanding-compliance-obligations-for-government-contractors/). - [2026-07] Law-firm analysis confirms the 1260H list's cadence has been roughly annual-to-18-months (Jan 2025 → June 2026), suggesting the next scheduled update would plausibly land in late 2026 or a point before the statutory annual deadline in 2027 — but no confirmed date exists, and the June 2026 cycle's deliberate DeepSeek omission despite explicit congressional pressure is the closest direct precedent, arguing against a surprise mid-cycle addition (https://governmentcontractsnavigator.com/2026/07/22/dow-updates-section-1260h-list-expanding-compliance-obligations-for-government-contractors/). - [2026-10-07] No search turned up any DoD/DoW announcement, Federal Register notice, or credible report of a 1260H update since June 8, 2026, nor any indication that the stalled Commerce Entity List action on DeepSeek has been resolved — the status quo of DeepSeek's exclusion from all formal US blacklists has persisted for at least four months with no sign of imminent reversal. BOTTOM LINE: The strongest NO case rests on documented, deliberate executive-branch avoidance of designating DeepSeek specifically (for both trade-diplomacy reasons tied to the Trump-Xi summit cycle and a domestic-cost rationale unique to DeepSeek's popularity as a cheap US-market alternative), combined with the fact that the one concrete opportunity to add DeepSeek (June 2026) was used to list 65 other firms while pointedly excluding it — suggesting institutional reluctance rather than mere scheduling delay, and no confirmed mechanism forcing a different outcome before the window closes. NOT FOUND: No confirmed date for any 1260H list update after June 8, 2026; no evidence the White House's diplomatic "hold" on DeepSeek designations has lifted or is scheduled to lift before June 30, 2027; no official DoD explanation for DeepSeek's specific omission from the June 2026 list.