Net change in entities on the U.S. BIS Entity List via Federal Register rules published between June 1 and August 12, 2026?

• My most likely prediction for the net change in entities on the U.S. BIS Entity List is -0.35, with a 50% chance of falling between -3.36 and 1.66.
• The 73-day forecast window falls entirely within a one-year “tactical truce” and a formal stay of the Affiliates Rule, which is effective until November 9, 2026.
• As of mid-May 2026, no Federal Register rules amending the Entity List have been published for over six months, indicating a robust administrative pause.
• The May 14–15, 2026, Beijing summit between Presidents Trump and Xi confirmed the continuation of existing trade frameworks, reducing the likelihood of a mid-summer escalation.
• While the most probable outcome is zero (no qualifying rules), historical data shows that when BIS does act, it typically designates entities in “batches” of 20 to 70, creating a significant positive tail in the distribution.
• Budgetary requests for FY 2027 suggest a massive increase in BIS enforcement capacity, but this is unlikely to manifest in Federal Register rules until the current policy stay expires in late 2026.

Key figures

Historical context

Historically, the BIS Entity List has been a dynamic tool of U.S. foreign policy, often characterized by ‘batch’ additions rather than a steady trickle. In early 2025, the list grew significantly with rules published on March 28 (82 entities total), September 16 (32 entities), and October 9 (26 entities). These actions were largely focused on China, Russia, Iran, and Pakistan. However, the regulatory environment shifted dramatically following the October 30, 2025, Busan summit. On November 12, 2025, the BIS published a final rule that both removed one entity and stayed the ‘Affiliates Rule’ expansion. Since that date, there has been a complete cessation of Federal Register rules amending the list. This six-month gap is highly unusual compared to the activity levels seen in early 2025, reflecting a ‘tactical truce’ that has held through the most recent Trump-Xi summit in May 2026. During this pause, the BIS has focused on civil penalties and settlements with existing firms (like Applied Materials and Teledyne FLIR) rather than adding new names to the list.

Tailwinds

• The BIS FY2027 budget request for $450 million (up 92%) includes funding for 290 new enforcement agents, suggesting a “backlog” of potential listings.
• U.S. Trade Representative statements in May 2026 were non-committal about extending the truce past November, which could lead to pre-emptive listings.
• Geopolitical tensions unrelated to the China truce (e.g., Iran and Russia programs) remain active and could trigger non-China-specific listing batches.
• Significant enforcement penalties in early 2026 (e.g., $252 million against Applied Materials) show the agency remains active even if new designations are currently paused.

Headwinds

• The formal stay on the “Affiliates Rule” expansion is legally binding through November 9, 2026, removing the largest potential driver of mass additions.
• The May 2026 Beijing summit ended with an agreement to maintain all existing trade agreements, signaling a desire for stability through the summer.
• No new Entity List rules have been published in the Federal Register for over 180 days, suggesting a durable policy pause.
• Removals from the list require a unanimous vote of the interagency End-User Review Committee (ERC), making net-negative rules historically rare and difficult to achieve.

Detailed reasoning

My analysis for the net change in the U.S. BIS Entity List during the June 1 to August 12, 2026, window is primarily informed by the current period of unprecedented regulatory inactivity and the high-level diplomatic “truce” between the United States and China. As of May 17, 2026, the Bureau of Industry and Security (BIS) has not published a rule amending the Entity List in over six months, with the last action occurring on November 12, 2025. This pause is not accidental; it is a direct consequence of the October 30, 2025, Busan summit, which established a tactical de-escalation framework. A central pillar of this truce is the formal stay of the “Affiliates Rule” expansion, which is effective through November 9, 2026. This rule would have automatically added hundreds of majority-owned subsidiaries to the list, but its suspension effectively freezes the most significant source of list growth.

Furthermore, the May 14–15, 2026, Beijing summit between Presidents Trump and Xi—occurring just two weeks before the start of the forecast window—was characterized by analysts as a “stalemate” that preserved the existing truce. While the U.S. Trade Representative has hinted that this truce might not be extended past its November expiration, there is little evidence to suggest a major policy reversal will occur during the summer of 2026. Because the question resolves to 0 if no qualifying rule is published, and the current administrative silence has lasted half a year, a net change of zero is the single most likely result.

However, I must account for the “batch” nature of BIS administrative actions. Historically, when the End-User Review Committee (ERC) decides to add entities, it does so in clusters. In 2025, rules were published in batches of 70, 32, and 26 entities. While the China-specific truce is holding, BIS still maintains active programs regarding Russia, Iran, and other regions. The Trump administration has requested a massive 92% budget increase for BIS in FY 2027 ($450 million), intending to fund 290 new export enforcement agents. This buildup of capacity suggests that even if the “Affiliates Rule” remains stayed, the agency is preparing for a more aggressive enforcement posture. If the current “silence” is broken by a non-China-related rule or a tactical batch meant to signal strength before the November midterms, the net change would likely jump immediately to the 20–40 entity range. Removals are considered highly unlikely to offset additions, as removals require a unanimous vote from the ERC (Commerce, State, Defense, Energy, and Treasury), whereas additions require only a simple majority. My prediction weights the “status quo” (N=0) most heavily but includes a tail of positive “chunky” outcomes to reflect these administrative patterns.

Key uncertainties

• A breakdown in the May 2026 summit “stalemate” could lead to a sudden resumption of listing batches as a retaliatory measure.
• The ERC could publish a rule purely for technical “clean-up” or removals, though this is rare and usually small (N near 0).
• Domestic political pressure in the U.S. ahead of the November 2026 midterm elections could incentivize a “tough on China” batch before the window closes in August.
• The definition of “entities” vs “entries” in the SUMMARY paragraph can occasionally lead to minor integer differences if rules are not precisely drafted.

Conclusion

• The most probable outcome is 0 net change (N=0) because the 73-day window falls squarely within a 12-month diplomatic “truce” and a formal stay of the Affiliates Rule.
• Any deviation from zero is likely to be positive and “chunky” (20–40 entities), as BIS typically processes listings in administrative batches rather than single additions.
• Decision-makers should monitor the Federal Register for any pre-emptive rules in late May, as a break in the current six-month silence would signal a shift in the “tactical truce” before the November 2026 U.S. midterm elections.

Question: net change in entities on the BIS Entity List published in the Federal Register between June 1 and August 12, 2026. Both forecasters note a clear downward trend in summer net additions (about 105–107 in 2022, 47 in 2023, 9–14 in 2024, and 0 in 2025) and point to a key policy change: a one‑year suspension of the “Affiliates Rule” after a US‑China trade deal on Nov 10, 2025, and a subsequent pause in Federal Register Entity List rules since then. One model (gemini3pro_1) places a high probability (66%) on a net change of 0, arguing the ongoing pause will likely persist through the short 73‑day window, with small chances of additions (targeting Russia/Iran) and very low odds of removals. The other (gemini3pro_2) is more cautious: about a 34% chance of 0, ~40% for small–medium additions (1–30 entities) as the US pursues evasion networks, and a tail risk of a large (>60) batch if geopolitics shift; it also notes removals are possible but historically rare. In short, both forecast low activity relative to 2022–23, but they disagree on how strongly to weight a zero outcome versus modest additions, with the main drivers being the Affiliates Rule suspension and geopolitical developments.

Forecast and Reasoning

Forecast: Probability distribution:

• 5.00% chance of value below -1.0
• 10.00% chance of value below 0.0
• 20.00% chance of value below 0.0001
• 30.00% chance of value below 0.0002
• 40.00% chance of value below 0.0003
• 50.00% chance of value below 0.0004
• 60.00% chance of value below 10.0
• 70.00% chance of value below 25.0
• 80.00% chance of value below 60.0
• 90.00% chance of value below 120.0
• 95.00% chance of value below 185.0

Forecast Reasoning

We are forecasting an integer net change in Entity List entities from BIS rules published in the Federal Register during 2026-06-01 to 2026-08-12.

Across analysts, the key disagreement is whether the late-2025 to mid-2026 publication freeze persists through the window (implying N=0), or whether BIS “unpauses” with one or more catch-up batches (implying tens to potentially >100 net additions). Forecasters 3 and 4 weight the freeze/truce dynamics heavily (median 0), while forecasters 1 and 2 lean more on pre-freeze base rates and expect a resumption within the 10.5-week window (medians 25–38).

I synthesize these by treating the outcome as a mixture of regimes:

1. Continued pause: a substantial probability that no qualifying rule publishes in-window, yielding exactly 0.
2. Partial resumption: one typical batch-sized rule (often net +10 to +70).
3. Backlog release / geopolitical trigger: a smaller but meaningful right tail where multiple rules or a large batch occurs, potentially pushing totals above the in-range upper bound.

Removals are possible but structurally harder (unanimity) and historically sparse, so net negatives are a low-probability left tail rather than a central scenario.

Given the strong evidence of an ongoing multi-month pause but also the non-trivial chance of an administrative/geopolitical “restart” within a ~2.5 month window, I keep the median essentially at 0 while allowing a wide, right-skewed tail. I express about ~5% probability mass beyond the open upper bound by placing the 95th percentile above 169.9975 (and not near the bound).

An amateur forecast would commonly do one of two things: (a) extrapolate from 2025 batch sizes and predict a fairly tight 20–60 range, ignoring the unusual multi-month publication gap; or (b) predict 0 with near-certainty, underpricing the possibility of a sudden restart/backlog release. My forecast explicitly models a pause-vs-resumption mixture, keeps a realistic (but small) left tail for net removals, and uses an explicit past-upper percentile to represent the chance of an unusually large summer catch-up. Confidence in improvement is moderate: the dominant uncertainty is political/administrative timing rather than a slowly varying trend.

Forecast rationale (numeric):

— Iteration 1 — Across the forecasts, the dominant view is that the net change in BIS Entity List entities over the June 1–August 12, 2026 window is most likely to be 0 or very close to 0, with the main uncertainty coming from whether the current publication pause continues.

Core factors driving the forecasts

• Extended pause in Entity List rulemaking: All rationales emphasize that BIS has gone several months without publishing Entity List updates, making no change the base case.
• U.S.-China truce/diplomatic restraint: The forecasts treat the ongoing truce as a major suppressing factor, lowering the chance of new designations during the short window.
• Short evaluation window: The roughly 73-day period is seen as too brief for a meaningful number of routine rules unless a backlog is released.
• Historical batch behavior: When BIS does act, it often does so in clusters/batches, not one entity at a time, so the distribution is not centered on small positive numbers.

Areas of consensus

• Median outcome near zero: All three models place the center of the distribution at or near 0 net change.
• High probability of inactivity: Each rationale assigns substantial probability to no qualifying rule publication.
• Right-skewed uncertainty: If activity resumes, it is more likely to come as a large positive batch than a small incremental change.
• Removals are uncommon: Negative net change is possible, but it is treated as a low-probability left tail because deletions from the Entity List are rare.

Main differences

• Exact probability of zero: The models differ somewhat on how likely a complete pause is, but all cluster around a large mass at 0.
• Tail size assumptions: Some forecasts are more cautious, allowing for very large additions if the backlog clears, while others keep the upper tail somewhat tighter.
• Scope of possible trigger events: One rationale stresses broader non-China designations (e.g., Russia or Iran), while another focuses more on a potential breakdown of the truce or a backlog-clearing rule.

Bottom line

The shared reasoning is that the most plausible outcome is no net change, but the forecast is bimodal: either continued inactivity or a sudden, sizable batch of additions if BIS resumes action. The downside tail from removals exists but is comparatively small.

— Iteration 2 — Across the forecasts, the main reasoning is that the U.S. BIS Entity List is likely to remain inactive or nearly inactive during the June 1–August 12, 2026 window because of a recently reaffirmed multi-month pause tied to the broader U.S.–China de-escalation/truce environment. That pause is treated as the dominant factor, making 0 net change the most likely outcome.

Key patterns in the reasoning:

• Strong baseline expectation of no action:
  All models emphasize the six-month lull in Entity List rules as the central signal. This creates a sizable probability that no Federal Register rule appears in the window.

• If action resumes, it is likely to be lumpy and addition-heavy:
  Historical behavior suggests BIS tends to publish batch additions rather than small, steady changes. If the pause ends, additions are expected to come in groups, often totaling tens of entities, with some models allowing for much larger batches.

• Right-skewed distribution:
  The forecasts consistently describe the outcome space as heavily skewed toward positive net additions if any rule appears, with a large mass at zero and a long upper tail for escalation scenarios.

• Removals are possible but much less likely:
  Net removals are treated as a thin left tail outcome—generally limited in size and associated with diplomatic concessions or narrow delisting actions.

• Backlog and broader sanctions policy matter:
  Some rationales note that paused or delayed activity in related sanctions areas, especially involving Russia and Iran, could produce a catch-up batch of listings. Conversely, a truce breakdown or major geopolitical shift could drive larger-than-normal additions.

Where the forecasts differ is mostly in how much upside risk to assign:

• One forecast centers on exactly 0 as the median.
• Others place the median slightly above zero, around 0–3, or a modest positive mean, reflecting the chance of a delayed batch being published.
• The tails vary in width, but all models preserve the possibility of both small removals and large addition bursts.

Overall, the shared view is: no net change is the single most likely outcome, but the distribution is asymmetric, with meaningful risk of a positive batch-addition surprise if BIS resumes issuing Entity List rules.

— Iteration 3 — Overall, the forecasts converge on a strongly right-skewed distribution with a median net change of 0 for the June 1–August 12, 2026 window.

Main reasoning patterns

• Recent publication pause is the dominant factor.
  All rationales emphasize that BIS has been in an unusually long lull in Entity List rulemaking, making no Federal Register rule in the window the most likely outcome.

• Recent U.S.–China diplomacy is seen as reinforcing the pause.
  The mid-May 2026 Trump-Xi engagement, along with the broader post-summit truce framework, is interpreted as lowering the near-term chance of new listings.

• If the pause ends, changes would likely come in batches.
  Rather than small incremental updates, Entity List actions are expected to arrive as clustered rules with multiple entities, especially if a backlog of Russia, Iran, or China-related designations is released.

• Removals are treated as rare and constrained.
  Negative net change is considered unlikely because delistings require a higher procedural threshold and are historically uncommon, so the left tail is thin.

Areas of consensus

• 0 is the modal and median outcome.
• No rule publication in the window is a substantial probability.
• The distribution is asymmetric: small downside risk, but a potentially large upside if BIS resumes active rulemaking.
• Any positive outcome is more likely to be a batch release than a single small action.

Main differences in emphasis

• One rationale places more weight on the duration of the publication pause and treats the zero outcome as especially dominant.
• Another is somewhat more explicit about a possible backlog release and assigns more weight to a larger positive tail.
• Estimates differ on how much probability mass sits at zero versus in small-to-moderate positive batches, but they agree on the overall shape: centered at zero with a long positive tail.

Summary of Forecasting Rationales

Forecasters agree that the net change in U.S. BIS Entity List additions during the summer 2026 window hinges on the tension between an ongoing diplomatic freeze and mounting political and international pressure to resume routine designations.

The Diplomatic Pause and Policy Shift The primary factor anchoring the forecasts is the unprecedented six-month pause in Entity List additions that began in November 2025. Forecasters note this freeze is directly tied to a “tactical truce” between the U.S. and China stemming from the Busan summit, alongside the formal suspension of the “Affiliates Rule.” To avoid jeopardizing fragile economic agreements, the administration has largely halted Commerce Department additions. Instead, enforcement has shifted toward alternative mechanisms, such as the Treasury Department’s Specially Designated Nationals (SDN) list, the Unverified List (UVL), and enhanced “Know Your Customer” guidelines. This dynamic strongly supports the possibility that the administration maintains the freeze, resulting in a stagnant list.

Catalysts for Resumption and Backlog Risks Despite the overarching truce, forecasters highlight several imminent catalysts that could break the pause and trigger a wave of new additions:

• Multilateral Summits: The G7 Summit in June and the NATO Summit in July are traditional venues for announcing coordinated, allied export controls. The U.S. may use these events to target non-China evasion networks—specifically third-country nodes supplying Russia and Iran—allowing them to project strength without violating the core China truce.
• Congressional Pressure: Bipartisan lawmakers are exerting intense pressure to close sanctions loopholes, a push that will peak during the summer FY2027 NDAA markups. The administration may be forced to execute targeted batches of additions to appease hawkish legislators.
• Administrative Backlog: The End-User Review Committee (ERC) has reportedly continued to conduct internal votes and draft rules during the pause. If the political freeze is lifted, the publication of this accumulated backlog could result in a massive “catch-up” surge of listings.

The Rarity of Removals Forecasters are unanimous in constraining the lower bound of their estimates due to the structural mechanics of the ERC. Removing an entity from the list requires a unanimous interagency vote, an exceptionally rare occurrence. Consequently, significant negative net changes are highly improbable, limiting the downside strictly to isolated administrative clean-ups and ensuring the distribution of outcomes is heavily skewed toward either a maintained pause or a sudden positive spike.

Agent Forecast (discrete, confidence: low)

• 0: 58.0%
• 171+: 1.5%
• 32: 1.0%
• 26: 1.0%
• 82: 0.8%

Base Rate: Biden 2024: 520 entities/year → ~104 entities per 73-day window. Trump 2nd term: ~140/year equivalent with 81-day and 171-day gaps; current 2026 pace: 0 entities in 186+ days. Conditional on any resumption, historical Trump 2nd-term batch sizes: 13, 26, 32, 82 entities.

Initial Reasoning:

• As of May 17, 2026, BIS has published zero Entity List addition/removal rules since November 12, 2025 — a 186+ day gap driven by the US-China Busan summit trade deal (October 30, 2025) and the one-year Affiliates Rule suspension (November 10, 2025 – November 9, 2026).
• The May 2026 Trump-Xi engagement left this framework intact.
• BIS’s entire 2026 public agenda has been enforcement settlements (Applied Materials $252M penalty, Teledyne FLIR, Solventum, Coastal PVA), not new designations.
• Historical base rate is 520 entities/year (2024 Biden pace) or ~104/73-day window, but Trump’s second-term pace is far more episodic: long gaps (81 days in early 2025, 171 days mid-2025) punctuated by bursts.
• The June 1 – August 12 window falls within the Affiliates Rule suspension and the ongoing diplomatic accommodation, creating strong headwinds against resumption.
• However, 73 days is substantial, Russia/Iran programs remain nominally active, and the Affiliates Rule suspension does not legally prevent new distinct-entity listings.
• I assign 35% to N=0 (pause continues), with the remaining 62.5% spread across positive values with local probability peaks at historically typical rule sizes (26, 32, 82 entities) and 2.5% to small net-negative outcomes.

Key Uncertainties:

• Whether the US-China diplomatic framework will hold through August 12, 2026 — any breakdown in trade deal implementation could trigger rapid resumption of China-related Entity List actions
• Whether Russia/Iran-related designations might emerge as standalone rules despite the broader pause, since the Affiliates Rule suspension does not legally bar non-China listings
• If resumption occurs, magnitude is bimodal between a small batch (13-32 entities, the modal Trump-era rule size) and a large catch-up release (70-130+ entities)
• Whether unpublished but pipeline-ready NPRMs or pre-publication notices exist that the public record does not yet show
• Geopolitical shocks (escalation in Ukraine, major Iranian proxy incident with US-origin components, Taiwan Strait friction) that could override diplomatic constraints

Evidence Sources (9):

• Sanctions by the Numbers: 2024 Year in Review - CNAS
• BIS Suspends Affiliates Rule for One Year as Part of the US-China Trade Deal - Skadden
• Could the BIS Entity List Re-emerge as a Major Sourcing Risk? - Z2Data
• BIS News and Updates - Bureau of Industry and Security
• Revisions to the Entity List - Federal Register Nov 12 2025
• Federal Register API - BIS rules 2026
• BIS’s 2026 Enforcement Agenda Takes Shape - Torres Trade Law (April 13, 2026)
• Taking Stock: BIS Actions Under Trump Administration - ArentFox Schiff (March 2025)
• Suspended for One Year: U.S. Department of Commerce Expansion of End-User Controls - Covington

Grounding Facts (passed to reviewers):

1. Donald J. Trump is the current U.S. President, having held the Trump-Xi Busan summit on October 30, 2025.
2. On November 10, 2025, the Bureau of Industry and Security (BIS) issued a final rule suspending the Affiliates Rule for one year as part of a U.S.-China trade deal.
3. The Affiliates Rule suspension is effective through November 9, 2026, and will automatically expire on that date.
4. The suspension of the Affiliates Rule does not prevent BIS from adding new distinct entities to the Entity List.
5. As of May 17, 2026, no Entity List addition or removal rules have been published by BIS in the Federal Register during 2026.
6. BIS’s 2026 enforcement agenda, as of April 13, 2026, has focused on enforcement actions and does not publicly include new Entity List rules.
7. Since the Affiliates Rule was suspended in November 2025, the BIS’s Entity List has not been a major factor in trade compliance for most U.S. companies (as of April 15, 2026).
8. The last Entity List rule mentioned under Trump’s second term in the corpus was published on November 12, 2025, with no further rules explicitly noted through the provided excerpt.
9. In 2026, BIS announced enforcement settlements including a $252 million penalty against Applied Materials on February 12.

Draft: 0: 35.0%, 171+: 1.8%, 32: 1.2%, 26: 1.2%, -1: 1.0%

Reviewer Panel:

Reviewer (reasoning)

The forecast’s linchpin—that the Affiliates Rule suspension effectively freezes all new listings—misreads the rule’s scope and overweights a single base rate gap. It also leans on outdated Biden-era listing volumes rather than Trump-term episodic patterns, and fails to consider ongoing Russia/Ukraine and Iran sanctions momentum. Finally, the elaborate probability mass on dozens of nonzero outcomes is unsupported by any discrete signals of an imminent rule.

Objections:

• The Affiliates Rule suspension only alters deeming provisions, it does not bar new entity designations—so treating it as a de facto moratorium is flawed.
• The base rate should reflect Trump-XII administration’s past listing bursts tied to geopolitical events (e.g. Russia/Ukraine updates), not the steady Biden pace.
• There’s no analysis of the typical Federal Register pipeline (e.g. concurrent NPRMs or CIS notices), which could signal a June–August rule even if not yet published.
• (Optional third) The reasoning ignores that enforcement settlements often precede parallel listing actions under overlapping statutes, giving a credible pathway for a mid‐summer listing rule.

Reviewer (calibration)

The forecast identifies ‘strong headwinds’ against Entity List changes due to ongoing diplomatic accommodation and the Affiliates Rule suspension, yet assigns only a 35% probability to zero net changes. This appears contradictory, as the described policy context strongly suggests a continuation of the current pause. The distribution of 62.5% across a wide range of positive outcomes seems to underestimate the impact of the active policy of détente.

Objections:

• The forecast underweights the significance of the 186+ day pause and the explicit Affiliates Rule suspension (until Nov 2026) as evidence for a continued freeze on Entity List actions within the forecast window.
• While acknowledging ‘strong headwinds,’ the forecast’s probability distribution for positive net changes (62.5%) does not reflect the strength of these headwinds. It seems to over-rely on a historical ‘episodic’ pattern without adequately accounting for the specific, policy-driven nature of the current lull.
• The statement that BIS’s 2026 enforcement agenda ‘does not publicly include new Entity List rules’ is strong evidence for N=0, but its weight does not seem fully reflected in the final probability assignment.

Reviewer (fact-checker)

2 unsupported claim(s). Verdict: minor_issues

Unsupported claims:

• The May 2026 Trump-Xi engagement left this framework intact.
• Russia/Iran programs remain nominally active

Adjustment Rationale:

Adjusted P(N=0) from 0.35 → 0.58 in response to the calibration reviewer, who correctly identified that my draft’s qualitative reasoning (unprecedented 186+ day pause, US-China diplomatic framework, BIS’s 2026 enforcement-only agenda, explicit Affiliates Rule suspension through Nov 2026) implied stronger weight on a continued pause than 35% reflected. The ensemble signal (68%) and both reviewers independently pulled toward a higher zero-weight. I stopped short of 0.68 to preserve mass for Trump’s well-documented episodic burst pattern, where long pauses (81 and 171 days in 2025) have historically been followed by typical rule sizes (13, 26, 32, 82 entities). The reasoning reviewer’s technical point — that the Affiliates Rule suspension only alters deeming provisions and does not legally bar new designations — is correct, but the constraint operating here is diplomatic/political, not legal, so it does not change the directional adjustment. The fact-checker flagged two of my claims (Trump-Xi May 2026 framework intact, Russia/Iran ‘nominally active’) as inadequately sourced; I am treating both as inference rather than evidence and have softened my reliance on them. Concentrated remaining positive mass at historically observed Trump-era batch sizes (peaks at 26, 32, 82) and trimmed the long right tail.

forecast_sdk | 531.6s | research $0.8000 + reviewers $0.0093 + reconcile $0.2456 = $1.0550

TL;DR

I forecast N = 0 as the modal outcome, with a 56% probability of no qualifying rule and a mean net change near +13 entities.

Context

The question counts only BIS final or interim final rules that amend Supplement No. 4 to 15 CFR part 744, published in the Federal Register from June 1 through August 12, 2026, using the “entities added” minus “entities removed” counts in each rule summary. Address-only entries, aliases, typographical changes, and broad policy rules that do not add or remove named Entity List entities score 0.

The current state is quiet. I found no 2026 BIS Entity List amendment rule through May 17, 2026 in the Industry and Security Bureau Federal Register record; the latest qualifying Entity List amendment I found was the November 12, 2025 rule removing one China entity and removing six aliases from another entry (Federal Register, 2025-19858). The same Federal Register issue stayed the Affiliates Rule through November 9, 2026, while saying BIS would continue to evaluate national-security and foreign-policy interests related to non-listed affiliates (Federal Register, 2025-19846).

Evidence

The historical base rate is high. I used the prior June 1-August 12 windows from 2017 through 2025, with unit = net distinct entities, coverage window = Federal Register publication dates in each annual 73-day window, sample size = 9 annual windows, and vintage = public Federal Register text available on May 17, 2026. The mean is +35.9 entities, the median is +44, and 8 of 9 windows had a positive net change. I count the June 21, 2023 correcting amendment as +1 because its summary says it added an inadvertently omitted entity; if the resolver treats that correction as 0, the historical mean falls by only 0.1 entity.

That base rate cannot be used raw. The latest no-action spell is long: from the November 12, 2025 removal rule to May 17, 2026 is 186 days with no qualifying Entity List amendment that I found (Federal Register, 2025-19858; BIS Federal Register archive). The previous long quiet spell, from the March 28, 2025 additions to the September 16, 2025 additions, was 172 days and already produced a zero in the 2025 target-season window (Federal Register, 2025-05426; Federal Register, 2025-17893). I read this as a real policy and process signal, not just ordinary calendar noise.

The signal is not strong enough to make zero overwhelming. The Entity List is not only a China tool. Recent rules covered China, Iran, Pakistan, South Africa, Turkey, the UAE, India, Singapore, Taiwan, and Russia-related diversion networks (Federal Register, 2025-05426; Federal Register, 2025-17893; Federal Register, 2025-19508). Also, BIS rules state that the End-User Review Committee adds entries by majority vote, but removals and modifications require unanimity, so negative outcomes are rare and usually small (Federal Register, 2022-14069).

My final distribution puts 56% on N = 0, 2.5% on a negative net, 41.2% on positive values from 1 to 169, and 0.3% above 169.9975. The mean is about +13.5 if the upper-tail bin is represented by 180. The 90th percentile is in the low 40s. The positive mass is centered around single-rule batches in the 10-45 range, with smaller mass on 70-120 entity batches because those have occurred, but are less likely during the current truce-like period.

What’s non-obvious

The simple historical answer is too high. Summer Entity List activity was common in 2017-2024, but the 2025 summer window was already zero and the current drought is longer than the 2025 drought. A model that just says “8 of the last 9 windows were positive” misses the regime break.

The simple political answer is also too low. The Affiliates Rule suspension reduces one source of China-linked escalation, but it did not suspend ordinary named Entity List additions, and the rule itself says BIS will continue evaluating national-security and foreign-policy interests during the stay (Federal Register, 2025-19846). If the pause breaks, the result is more likely to be a positive batch than a negative rule, because removals are procedurally harder and historically much smaller.

Limitations

The main missing variable is the closed ERC pipeline. Federal Register publication is visible only at the end of the process, and Entity List rules often arrive as final rules with little public warning. A prepared Russia, Iran, cyber, military-end-use, or transshipment batch could appear inside the window without a public lead time.

The historical sample is small: 9 comparable annual windows and a few dozen rules. Classification also has edge cases. Corrections and address-only entries matter because the resolution uses entity counts, not entry counts. I handled the 2023 correction as an entity addition because its summary says it added an omitted entity, and I excluded address-only additions such as the 2024 high-diversion-risk addresses and the 2025 three addresses. That choice moves the historical mean by far less than the policy uncertainty moves the forecast.

Forecast: Net Change in BIS Entity List Entities (June 1 – August 12, 2026)

Median: 3.95 entities

Rationale

• Dominant scenario is continued pause (44–65% probability). The 6+ month publication gap since November 2025 is historically unprecedented and reflects a formal diplomatic constraint tied to the Affiliates Rule suspension through November 9, 2026. The May 2026 Trump–Xi summit produced no explicit release of this constraint, leaving the pause as the baseline expectation.

• Meaningful tail probability for non-China rules (20–28% probability). Iran, Pakistan, and Russia-related entity listings remain active in the ERC pipeline and are not explicitly covered by China-focused diplomatic agreements. A single modest batch targeting these regions could add 10–40 entities without breaking the China truce.

• Lower but non-negligible risk of China rule resumption (12–20% probability). The May summit’s ambiguity—no new commitment but also no explicit release of constraints—leaves room for the administration to interpret silence as permission. Z2Data’s April 2026 analysis noted the administration may use the Entity List as leverage through Q3 2026, suggesting late-summer action is possible.

• Structural asymmetry favors additions over removals. ERC voting requires a majority for additions but unanimity for removals. Net removals are historically rare (1 entity removed in all of 2025) and would require a deliberate diplomatic concession, making the left tail thin.

• Batch-size distribution is right-skewed. Historical precedent shows batches of 13–70 entities when BIS publishes. The weighted average of scenarios (combining 55–65% at zero with 35–45% distributed across 10–85 entity ranges) produces a median near 0 but a mean of 15–30, consistent with the forecast median of 3.95.