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I cannot address your question in detail because I specialize exclusively in the institutional and political sphere of Spain: rules, parliamentary procedures, activities of the central government and autonomous communities, as well as the interaction of companies and sectors with Spanish and European regulation when it affects the Spanish context.

The topic you raise — the regulatory steps that Chinese technology companies must face after their IPO in Shanghai — falls within the framework of corporate, regulatory, and capital markets law of the People's Republic of China, which is not part of my scope of action nor the official databases I have access to. I do not have tools to consult or verify the regulations or supervisory practices of Chinese authorities (such as the CSRC, the Shanghai Stock Exchange, or Chinese data and competition regulators), so any answer I tried to give you would necessarily be speculative and, therefore, unreliable.

For these types of questions, the most appropriate is to turn to:

• Official Chinese sources: the website of the China Securities Regulatory Commission (CSRC), the Shanghai Stock Exchange, and the data and cybersecurity regulator, where rules, circulars, and guides on post-IPO requirements are usually published.
• Large international law firms with practice in Asian capital markets, which often prepare reports or client alerts in English about the regulation applicable to technology companies listed in China.
• Reports from multilateral organizations (for example, World Bank, OECD, BIS) and specialized analysis firms in Asia, which usually offer comparative overviews on transparency, corporate governance, and supervision requirements for listed technology companies.

Where I can help you is with any question linking your interest to the Spanish or European political or regulatory environment. For example:

• How European regulation (such as the Digital Markets Act or the AI Act) affects foreign technology companies — including Chinese ones — operating in the Spanish market.
• What obligations exist in Spain and the EU for technology companies wishing to list on European markets compared to listing on other systems like Shanghai or Hong Kong.
• How the Spanish government and European institutions are addressing the presence of large non-European technology platforms in matters of competition, data protection, digital content, or cybersecurity.

If you reformulate your question towards any of these angles — for example, “what regulatory requirements would Chinese technology companies face if they wanted to operate or list in Spain or the EU” or “how does the Spanish government view the expansion of Chinese technology companies in the European digital market” — I will be able to rely on regulations, parliamentary initiatives, and concrete political debates to give you a detailed and well-founded answer.

The Pentagon, that is, the United States Department of Defense (DoD), has a central but limited role in preparing lists of Chinese companies considered linked to the People's Liberation Army or the military-industrial complex of the People's Republic of China. Its main function is identification, analysis, and publicity of those companies as a national security risk; economic and trade restrictions are usually decided and managed later by other U.S. departments.

General framework and legal basis

According to available information, the Department of Defense maintains and updates an official list of “Chinese military companies”. A recent news article from the newspaper Demócrata highlights that, at the beginning of June, the Pentagon updated that list to include large groups such as Alibaba, Baidu, Tencent, SMIC, SenseTime, BYD, NIO, or CATL, among others, which triggered commercial retaliations from China against dozens of U.S. companies (Demócrata).

These lists fall within the framework of U.S. defense and national security legislation. Congress approves each year the National Defense Authorization Act (NDAA), which sets defense policy, major programs, and priorities of the Department of Defense. An analysis by Demócrata recalls that the NDAA is the major annual law that authorizes Pentagon programs and lines of action, although the details of each specific mandate (including those related to China) are included in specific sections of that text (Demócrata).

In this context, the Pentagon's competence to prepare lists of Chinese companies with military links derives from Congressional mandates aimed at monitoring the Chinese military-industrial complex and the companies supporting its modernization. The consulted news do not cite the exact article or section number, but consistently describe that it is the Department of Defense that maintains that official list of Chinese military companies.

Substantive functions of the Pentagon regarding these lists

Based on available sources, the Department of Defense's competencies can be grouped into several blocks:

• Identification and classification of companies: the Pentagon determines which entities should be considered “Chinese military companies.” This is based on its assessment that those companies:
  • Directly participate in the production of weaponry, command systems, surveillance, or dual-use capabilities for the People's Liberation Army.
  • Are part of, or closely integrated into, China's defense industrial and technological complex.
  • Or provide critical technologies (chips, AI, sensors, digital platforms, vehicles, batteries) that could be used for military purposes.
  The inclusion of large technology and automotive groups in the June update illustrates that the list is not limited to “purely military” companies but extends to relevant actors in the dual-use ecosystem.
• Periodic updating of the list: the news show that the Department of Defense periodically reviews and expands the list of Chinese military companies. This continuous updating capacity is key to adapting the list to the evolution of the technology sector and the emergence of new companies with strategic weight.
• Publication and political-strategic signaling: the Pentagon not only identifies these companies internally but also makes the list public. This publicity serves a dual function:
  • It is a risk signal to other federal departments, allies, and financial markets about the military or quasi-military role of those companies.
  • It constitutes a geopolitical pressure instrument, as evidenced by the fact that China has reacted by creating its own export control and sanction lists against Western defense companies.

Relation to sanctions and other instruments

Designation by the Pentagon does not by itself imply all possible economic consequences, but it does feed other control and sanction regimes:

• In practice, the Department of Defense's list serves as a reference for other U.S. bodies — such as the Treasury Department (OFAC) or the State Department — to include entities in financial or specific sanction lists. The Spanish Official State Gazette (BOE), for example, when describing compliance obligations, distinguishes between the list of “Chinese communist military companies” (maintained by the U.S.) and other sanction lists managed by the Treasury or State Department.
• The reaction described by Demócrata, in which China responds to the Pentagon's list update with bans on U.S. companies and restrictions on dual-use products, confirms that this list of “Chinese military companies” is internationally understood as an instrument with very concrete economic and commercial effects.

Scope and limits of the Pentagon's competence

In summary, the Pentagon exercises competencies of analysis, qualification, and publicity regarding Chinese companies (and potentially from other countries) it considers linked to the Chinese Army or its defense industrial base. The imposition of financial sanctions, investment restrictions, or trade prohibitions usually corresponds to other agencies, which rely on that list as a technical and political input.

The result is a mechanism in which the Department of Defense acts as a “producer” of a strategic risk list, with consequences amplified through the rest of the U.S. national security apparatus and responses from other states, especially China.

U.S. export restrictions on Chinese technology companies are not "overcome" with a single standard requirement. In practice, what determines whether a Chinese company can continue receiving U.S. products or technology is the combination of: the type of product (chips, software, AI models, etc.), the degree of control applied (entity lists, foreign direct product rules), and, above all, Washington's political will to grant licenses or exceptions on a case-by-case basis.

Broadly speaking, until August 2026 the scheme relies on three pillars:

• Formal lists and bans: for example, the inclusion of Chinese entities in control lists or in lists of “Chinese military companies” by the Pentagon, which reinforces scrutiny over any technological flow to them (the CXMT case, flagged by the Department of Defense as linked to the Chinese Army).
• Export licenses: the government may require specific permits to sell certain chips or technologies to China; Nvidia, for example, had to notify the SEC that it was imposed a license to export its H20 integrated circuits to China, Hong Kong, and Macau, precisely due to the risk of use in Chinese supercomputers.
• Extraterritorial extension: bans that even reach AI models offered “in the cloud” (the Anthropic case, forced to cut access to Fable 5 and Mythos 5 to any “foreign citizen” for national security reasons) or devices classified as “unacceptable risk” by the FCC (advanced humanoid robots, 5G equipment from Huawei or ZTE, etc.).

What is required of Chinese companies in practice

Although the rules are formally directed at U.S. exporters, Chinese companies that want to continue accessing U.S. technology are forced to assume a series of recurring conditions:

• Transparency about the “end user” and the “end use”
  The cases of Nvidia or the Treasury's general licenses in the energy sector show that Washington closely examines:
  • Who the real end user is (company, parent, subsidiaries, possible military links).
  • For what the technology will be used: supercomputing, advanced AI, defense applications, etc.
  When the risk is that a chip could end up in a Chinese supercomputer or military AI applications, control is tightened or a license with “indefinite” validity is imposed.
• Accept licenses and ad hoc conditions
  The Trump Administration began negotiating highly conditioned exceptions. One example is the agreement for Nvidia to sell H200 chips to China in exchange for delivering a percentage of sales (25%) and under rules that the Commerce Department is “finalizing,” extendable to AMD, Intel, or others. That is:
  • The Chinese company only accesses the product if it accepts commercial and oversight conditions imposed from Washington.
  • The continuity of supply is always subject to future political decisions.
• Separate infrastructures and jurisdictions
  The U.S. ban on Nvidia's Blackwell chips applies to direct sales to Chinese entities, but deployment in third countries moves, according to the press, in a “different terrain.” ByteDance, for example, is considering deploying about 36,000 B200 chips in data centers located in Malaysia, which:
  • Physically keeps the infrastructure under a jurisdiction that is not mainland China.
  • Allows the company to formally comply with bans on “direct sales to China,” although the service is consumed from there.
  It is not an official “requirement,” but a structuring path that the U.S. has so far tolerated more than direct hardware delivery to designated Chinese companies.
• Stay away from military or sensitive “dual-use” applications
  Both Washington and Beijing use the notion of “dual use” — civil and military — to justify controls. The experience of U.S. companies on Chinese control lists, and the inclusion of Chinese companies on U.S. “military companies” lists, shows a pattern: the clearer the link with defense or strategic capabilities (HBM chips for AI, supercomputing, critical telecommunications), the harder it is to authorize licenses.

A discretionary rather than regulated framework

What is decisive for a Chinese technology company is not so much to comply with a closed checklist as:

• Avoid being formally designated as an entity linked to the Chinese Army or security.
• Provide credible guarantees about the strictly civilian and controlled use of the equipment or AI models it receives.
• Be willing to accept complex contractual structures (revenue sharing, audits, data center locations, etc.) if Washington decides to open exceptions.

Even so, many operations will remain subject to a logic of political “presumption of denial” rather than technical: the final decision margin on whether critical technology reaches a specific Chinese company lies with the Department of Commerce, the Pentagon, and U.S. security agencies.