The BIS Affiliates Rule (50 Percent Rule) Readiness Checklist (2026)

A fill-in working checklist for trade compliance teams preparing for the BIS Affiliates Rule. Covers what the rule actually does (aggregation across owners and across lists, cascade/carry-forward, the rule of most restrictiveness, and why exactly 50% is in while below 50% is not automatically out), where ownership data typically breaks, and a six-phase preparation list from scoping through governance. The rule is currently stayed until 9 November 2026 — the suspension text says "absent a future extension", so the sheet is built to work whether the rule returns on schedule or the stay is extended. Based on primary sources (90 FR 47201, 90 FR 50857, 15 CFR). Designation is a regulatory classification, not a judgement about a company; final determinations rest with your export-control officer and the authorities' current guidance.