Export License Processing Times in 2026

BIS entered 2025 with 585 funded positions and a budget that had roughly doubled over the prior decade (GAO-25-107431, June 2025). None of that mattered when the February freeze hit. After the "hold without action" directive, multiple rounds of policy-driven pauses, and a SNAP-R platform migration that forced every user to re-register by June 30, 2025, the agency entered this year carrying the longest processing backlog in over three decades (Export Compliance Daily). If you filed an application last quarter and haven't heard back, welcome to the club.

Key Takeaways

• BIS's statutory processing deadline remains 90 calendar days from application registration (15 CFR § 750.4), but real-world timelines stretched to 120–180+ days through much of 2025 due to repeated administrative freezes.
• The February 2025 "hold without action" directive paused all new applications filed after February 5, with no formal announcement or end date (Buchanan Ingersoll & Rooney, February 2025).
• Applications for NATO allies and Country Group A:5 nations moved first when holds partially lifted. China-destined applications involving advanced technology remained frozen longest.
• BIS decommissioned legacy SNAP-R on June 30, 2025, requiring individual account migration. Incomplete migrations leave your application stuck before it reaches a licensing officer (BIS.gov).
• The December 2025 H200 chip export policy shift introduced case-by-case review with supply assurance and capacity documentation requirements that add weeks to semiconductor filings (BIS Press Release, December 2025).

The 90-Day Clock That Stopped Ticking

Under 15 CFR § 750.4, every license application must reach resolution or Presidential referral within 90 calendar days of BIS registration. That regulation hasn't changed. The agency's ability to hit that timeline collapsed in early 2025 and never recovered.

On February 5, 2025, BIS licensing officers got instructions to place all new applications on "hold without action" (Buchanan Ingersoll & Rooney). No Federal Register notice. No formal guidance. Just a verbal directive tied to a policy review led by then-acting Undersecretary James Rockas, who had relatively little export control background according to multiple sources who spoke to Export Compliance Daily. Trade lawyers found out from their licensing contacts, not from the agency itself. One attorney described the situation as bringing industry to a grinding halt for an indeterminate amount of time. Nobody at BIS disputed it.

The backlog grew at roughly 400 new applications per day during the freeze (National Shooting Sports Foundation estimate, February 2025). That's not a typo. By mid-February, individual licensing officers had personal queues of 20–30 pending applications with zero authority to move any of them forward. BIS partially resumed processing for Country Group A:5 destinations later that month, then reinstated the broader pause in late March after Under Secretary Jeffrey Kessler took over. A 10% sample of 701 applications submitted between March 27 and early April 2025 showed only two had been referred to another agency for interagency review (Export Compliance Daily, April 2025).

Applications that should have cleared in 30–45 days sat untouched for months.

Where Processing Times Actually Stand

Before the freeze, BIS had been trending faster. The agency's own data showed average processing times dropping steadily through early 2025, mostly from quicker handling of low-sensitivity EAR99 items and less interagency friction on allied-nation shipments. All of that progress evaporated. Exporters who filed through mid-2025 reported wait times of 120 to 180 days, with some China-related filings exceeding six months.

The staffing picture made recovery harder. Multiple senior career officials departed during the policy review period, including regulation writers with decades of institutional knowledge. Trade lawyer Reid Whitten of Sheppard Mullin told Export Compliance Daily that getting new leadership up to speed takes real time, and that gap directly disadvantages American exporters.

We've been tracking the patterns across our client base. The picture breaks down like this:

Allied destinations (NATO, Country Group A:5): Processing has largely normalized to 30–60 days for non-sensitive items. The December 2025 Syria sanctions relaxation under Executive Order 14312 opened EAR99 exports to Syria without individual licenses, which pulled one category out of the queue entirely and freed up some licensing officer bandwidth.

China and Macau, advanced computing: The December 2025 H200 policy shift moved these from presumption of denial to case-by-case review but piled on significant new documentation burdens. Applicants must now demonstrate that exports won't reduce domestic semiconductor supply, that Chinese purchasers maintain compliance programs, and that products passed independent U.S.-based security testing. Each of those requirements adds its own review cycle. Figure 90–150 days minimum if your paperwork lands clean on the first submission, which in our experience happens less than half the time for first-time China filings. And that's optimistic.

Everything else: Wildly inconsistent. A straightforward 600 series part for a European defense contractor might clear in 45 days. But try sending a dual-use sensor package to a Middle Eastern distributor with thin compliance history and no established relationship with BIS? That one could easily sit four months while interagency reviewers at Defense and State go back and forth about it.

The SNAP-R Migration Problem Nobody Mentions

BIS decommissioned legacy SNAP-R and its self-management software on June 30, 2025 (BIS.gov). Not just the company account. Every individual user had to migrate their personal credentials separately. A compliance team of 15 people needed 15 individual migrations completed before the cutoff, and anyone who missed that deadline lost submission access entirely.

We saw cases through late 2025 where compliance teams only discovered unmigrated accounts when trying to file a new application. Weeks of administrative scrambling before the regulatory clock even started running. The updated SNAP-R brought better security and electronic document attachment, but the transition created genuine chaos on top of a system that was already buckling.

If your team hasn't verified that every SNAP-R user completed migration, handle it this week. An unmigrated account means you can't file, can't check application status, can't respond when a licensing officer asks follow-up questions. BIS won't grant extensions because your IT department missed their cutoff date.

What Actually Triggers Interagency Delays

The single biggest variable in license processing has always been interagency review. BIS doesn't approve sensitive applications on its own. Defense, Energy, and State each weigh in on dual-use items, and disagreements feed into an escalation process that eats weeks.

Items controlled for nuclear nonproliferation (NP Column 1) or missile technology (MT) reasons trigger automatic Defense and Energy review, adding 30–45 days beyond BIS's internal processing if nobody objects. When there's a dispute, that timeline stretches further. Applications involving Entity Listed parties in China face presumption-of-denial reviews with heightened documentation requirements, and BIS added over 80 Chinese entities to the Entity List in March 2025 alone, with another 32 in September and 29 in October (Federal Register, 2025). The September 2025 Affiliates Rule (90 FR 47214) extended those controls to cover affiliates of designated entities, which means your end-user's parent company, subsidiaries, and joint ventures all need screening before BIS will touch the application.

Then there are the edge cases nobody plans for. We watched one application clear BIS, clear interagency, pass every hurdle, and then OFAC dropped a new SDN designation on the end-user the week before shipment. The license became worthless overnight. Two separate regulatory regimes running on two separate timelines with zero coordination on designation timing.

The Mistake That Costs You 60 Extra Days

Returned Without Action. RWA. Three letters that make compliance managers lose sleep.

BIS returns applications that lack complete information: missing ECCN classification, vague end-use descriptions, incomplete consignee details, unsigned end-use certificates. A returned application doesn't count against the 90-day clock. You refile from scratch and your place in the queue resets to zero.

Across the RWAs we've reviewed, the common thread has been applicants treating the SNAP-R form as a checkbox exercise instead of building a case that answers every question a licensing officer would ask. Spending two extra days assembling complete documentation before you hit submit saves 60–90 days of restart time in a system that already can't keep up.

Pre-submission consultations through BIS's Outreach and Educational Services Division (202-482-4811) remain available and criminally underused. For first-time filers or transactions involving unfamiliar destinations, that call flags missing elements before they become RWA triggers. Worth every minute of hold time.

Planning Around Uncertainty

Heading into 2026, the regulatory mess created a planning problem that no spreadsheet can handle. Processing times shift based on destination, item sensitivity, end-user history, and whether BIS happens to be mid-policy-review when your application lands. The 90-day statutory deadline exists on paper but carries no enforcement mechanism when the agency holds applications for policy alignment reasons.

File early and file complete. If you know a shipment will need a license in Q2, get that application in now. Build 120-day license lead times into sales commitments for anything outside NATO and A:5 countries. We've seen too many deals fall apart because someone promised 60-day delivery on a shipment that required a BIS license to a non-allied destination, and the application sat untouched for three months.

Run restricted party screening before you file, not after. The Affiliates Rule means a clean screen on your direct customer may miss a parent or subsidiary sitting on the Entity List. Catching that before submission prevents the cascading delay of an RWA, or worse, a denial that creates a compliance record haunting every future application you submit. We cannot overstate how much damage a single denial creates for your filing history.

This piece doesn't cover DDTC/ITAR licensing timelines, which operate under separate procedures and weren't directly affected by the 2025 BIS freeze. And it doesn't address the October 2025 government shutdown's additional impact on processing capacity, which was a separate disruption layer that compounded everything described above.

We've tracked multiple cases across our client base where an affiliate hit discovered during BIS review added eight to twelve weeks on top of already-stretched timelines (Lenzo screening data, 2025). The pattern repeats constantly. Platforms like Lenzo consolidate restricted party screening across OFAC, BIS Entity List, and EU sanctions lists into one check, flagging the affiliate connections that the Affiliates Rule now requires before filing. Catching a hit before you file beats discovering it in an RWA letter eight weeks later.

FAQ

How long does a BIS export license actually take right now? Allied nations (NATO, Country Group A:5) are processing in 30–60 days. China-related applications involving controlled technology run 90–150+ days. Interagency review from Defense, Energy, or State adds 30–45 days on top of that. The statutory maximum remains 90 calendar days (15 CFR § 750.4), but BIS has repeatedly held applications beyond that window without formal explanation.

Can I request emergency processing? Yes. Call the Outreach and Educational Services Division at (202) 482-4811 with your Application Control Number. BIS will expedite when circumstances justify it (15 CFR § 750.4(h)), but emergency licenses carry shorter validity and still go through full substantive review.

What triggers a Returned Without Action? Incomplete ECCN classification, missing or unsigned end-use statements, vague end-user descriptions, absent supporting documentation like technical datasheets or purchase orders. An RWA resets your processing clock to zero. Pre-submission consultation with BIS licensing officers remains the most effective way to avoid this on complex filings, and almost nobody bothers to use it.

Does the SNAP-R migration affect pending applications? Applications filed before the June 30, 2025 legacy system cutoff migrated automatically. But if individual users haven't completed their personal account migration, they cannot submit new filings, check status, or respond to licensing officer questions. Verify every team member's access immediately.

How does the Affiliates Rule change pre-filing screening? The September 2025 rule (90 FR 47214) extended Entity List controls to affiliates of listed entities: parent companies, subsidiaries, joint ventures. You need to screen the entire corporate family of your end-user, consignee, and intermediaries before filing. Miss an affiliate connection and you'll trigger a Request for Information at minimum, which alone can add three to six weeks of delay on top of already-stretched processing. The worst-case outcome? A denial that flags every single future application from your company for enhanced review.