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Export controls have taken on an increasingly important role in U.S. policy, particularly for advanced technologies, but U.S. firms report that license reviews administered by the Bureau of Industry and Security (BIS) are taking longer on average and providing less visibility into application status. Extended and uncertain licensing timelines affect firms operating in globally competitive and time-sensitive markets, shaping competitive outcomes where foreign suppliers operate under faster or more predictable systems. At the same time, rigorous interagency review of sensitive technology transfers, especially to countries of concern, is deeply necessary for national security. The resulting policy challenge is not whether export controls are necessary, but whether the current licensing process delivers timely, transparent, and predictable outcomes while effectively protecting sensitive dual-use technologies. This report uses new survey evidence from U.S. technology exporters to benchmark the current licensing process and its impact on U.S. firms.
The CSIS Economics Program surveyed U.S. exporters on their recent experiences with the BIS license review process. The survey, distributed through the Semiconductor Industry Association (SIA), the Information Technology Industry Council (ITI), and Semiconductor Equipment and Materials International (SEMI), received 31 substantive responses from senior export compliance professionals at major U.S. technology and semiconductor firms. All responses are kept fully anonymous.
The results indicate that respondents are experiencing extended licensing timelines and reduced visibility into application status, with implications for U.S. competitiveness. Firms reported that review times have extended well beyond statutory guidelines, communication between BIS and applicants has broken down, and U.S. firms are losing customers and revenue to foreign competitors who do not face the same delays. This report presents detailed survey findings and corresponding policy recommendations focused on oversight, transparency, and staffing.
The CSIS Economics Program administered the survey electronically between January and March of 2026. The survey was distributed through three major industry associations: SIA, ITI, and SEMI.
The survey instrument contained six sections covering company information, licensing activity, business impact, competitive landscape, mitigation strategies, and process feedback. A total of 41 responses were recorded. Of these, 10 respondents started the survey but did not complete any section beyond the screener, leaving 31 who provided substantive answers. All percentages cited in this report use the number of valid respondents for each question as the denominator.
To avoid multiple responses from the same company, the survey instructions requested a single response from the director of trade compliance or similar function.
Respondents also identified themselves based on the following categories:
The survey was distributed through industry associations whose members have a direct interest in export licensing policy outcomes. This distribution method introduces the possibility of self-selection bias, as respondents with negative experiences may have been more likely to participate. The authors have attempted to characterize this and other methodological limitations transparently:
Key Finding: 56 percent of respondents reported average license review times exceeding 180 days, well beyond the 90-day statutory benchmark. 33 percent reported waits of over 300 days. In comparison, the average licensing time in 2023 was 38 days.
Under the Export Administration Regulations, BIS is required to resolve or refer license applications to the president no later than 90 calendar days from when they are received. Title 15, Section 750.4 of the Code of Federal Regulations establishes a framework in which BIS has nine calendar days to conduct an initial review of an application, after which it may be referred to other agencies. Referred agencies then have 30 days to provide a recommendation. If agencies disagree, the matter is escalated to the Operating Committee and, if necessary, to the Advisory Committee on Export Policy. The clock can be stopped in only a few specified circumstances, such as while waiting for an applicant to reply to a request for more information. This framework implements the timelines in Executive Order 12981, which was codified by the Export Control Reform Act of 2018.
The BIS Annual Report for fiscal year 2023 reported an average processing time of 38 days. The survey respondent’s average processing times are dramatically longer, with the caveat that the sample is skewed toward a subset of semiconductor-related exports.
According to the survey, 78 percent of respondents reported that review times increased over the past 12 months, with 67 percent of all respondents describing the increase as “significant.” Multiple respondents stated that applications destined for certain countries (mainly China) appear to be held at the final approval stage pending internal policy guidance from BIS leadership.
Key Finding: 76 percent of respondents reported more than $10 million in exports delayed by pending license reviews. More than half of all respondents reported losing business or contracts.
Among the respondents who disclosed the dollar value of delayed exports:
More than half (54 percent) of respondents reported losing business or contracts as a direct result of licensing delays. Several noted they have stopped pursuing certain opportunities entirely because licensing timelines have become too unpredictable.
The survey found that delays have damaged relationships with existing customers for 62 percent of respondents, with 27 percent describing the damage as significant. Respondents described customers actively seeking alternative suppliers not subject to U.S. licensing requirements, and multiple respondents noted that customers increasingly view U.S. firms as unreliable suppliers.
Respondents also reported incurring inventory holding costs (42 percent), reputational harm (42 percent), legal and consulting fees (35 percent), and late penalties (12 percent). Several firms reported engaging law firms with personal connections to BIS officials as a means to obtain status updates—an informal access system that disadvantages smaller firms.
Notably, 88 percent of respondents reported that international competitors produce comparable products. The most frequently cited competitor countries were China (65 percent), the European Union (52 percent), Japan (39 percent), and South Korea (35 percent).
Among respondents aware of foreign licensing timelines, the reported contrast is substantial. Firms stated that most allied nations completed reviews in 60 days or fewer, compared to 6 to 12 months or longer in the United States.
When asked whether foreign competitors faced comparable controls, 43 percent said no, 39 percent said yes, and 17 percent were unsure.
Twenty percent of respondents said they were restructuring their business operations to avoid items under certain export control classification numbers. Forty percent had hired external consultants or legal counsel to help them obtain licenses, and 85 percent said they now factor export licensing delays into their sales cycle planning.
Key Finding: 100 percent of respondents cited review length as a primary challenge, and 71 percent also cited lack of transparency as a key issue. Only 8 percent rated BIS as “very responsive” to inquiries, while 38 percent rated it as somewhat or very unresponsive.
Respondents raised specific concerns: long periods before licensing officers are assigned to applications, lack of BIS staff with sufficient semiconductor technical expertise, and particularly long delays for deemed exports. Multiple respondents described BIS as having been a model agency that has recently broken down.
Multiple respondents indicated that China-destined licenses appear systematically held at final review pending BIS leadership policy guidance. China is a primary market for 77 percent of respondents, and 88 percent have foreign competitors—including domestic Chinese firms.
Firms listing China as a primary export market reported a median review time of 210 days, compared to 135 days for non-China exporters (n=20 and n=7, respectively). While the small sample limits statistical precision, the direction is consistent with the reported disproportionate delays for licenses to China.
Several caveats are warranted: China-destined applications may involve genuinely more complex national security considerations, and the survey did not ask respondents to compare China-destined processing times to other destinations.
That said, the pattern raises concerns: If a policy-level hold is in effect, communicating this to applicants with estimated timelines would allow firms to plan rather than wait indefinitely.
Improving the predictability, transparency, and administrative performance of the licensing process would strengthen both the effectiveness of export controls and the ability of U.S. firms to compete in global technology markets. The survey findings paint a picture of an agency under strain, with real-world consequences for U.S. industry. The challenges appear primarily administrative in nature and therefore resolvable within existing authorities. Relatively simple process and staffing changes could meaningfully change the trajectory and improve the effectiveness of export controls as a national security policy instrument.
Philip A. Luck is the director of the Economics Program and Scholl Chair in International Business at the Center for Strategic and International Studies (CSIS) in Washington, DC. Kate Koren is the deputy director of the Economics Program and Scholl Chair in International Business at CSIS.
The authors would like to thank the Semiconductor Industry Association (SIA), the Information Technology Industry Council (ITI), and SEMI for their assistance in distributing this survey to their members. These organizations helped facilitate access to respondents but did not fund this research, design the survey instrument, review the results prior to publication, or otherwise influence the analysis or conclusions presented here. The authors also thank Hugh Grant-Chapman, Thibault Denamiel, and David Yang for their research assistance for this piece.
This report was prepared by the Scholl Chair in International Business at the Center for Strategic and International Studies (CSIS). The Scholl Chair is supported by a generous grant from the Scholl Foundation. No other direct sponsorship contributed to this report.
