Summary

  • The July 2026 BIS "UAE Rule" moved the UAE from EAR Country Groups D:3/D:4 into Country Group A:5, and Supplement No. 8 to EAR Part 740 named Group 42 Holding Ltd (including G42 Cloud Technology LLC) and Core42 Technology Projects LLC as entities that may receive advanced computing items without a license. Covington & Burling analysis of the July 2026 BIS rule
  • That no-license authorization automatically expires on April 6, 2027 unless those entities become US companies — a corporate-conversion trigger, not a routine review date. Covington & Burling on the automatic expiry clause
  • The authorization stack beneath it remains modest relative to announcements: a November 19, 2025 permission to purchase the equivalent of up to 35,000 Nvidia Blackwell GB300 chips each for G42 and Saudi Arabia's Humain Reuters on the November 19, 2025 purchase authorization, against a May 2025 draft — never confirmed at scale Reuters reporting on the May 2025 draft — that sketched 500,000 chips per year for the UAE, about 100,000 of them for G42.
  • On the construction side, the flagship 5GW campus is being redrawn: Reuters reported on September 11, 2026, citing six unnamed sources, that a single Abu Dhabi campus is being reconceived as a network of distributed, hardened data centers after the Iran war, with air defenses and underground construction under consideration. G42 said work is progressing as planned. Reuters on the post-war redesign of the 5 GW campus
  • The first concrete milestone — Stargate UAE's initial 200MW, promised by Mubadala managing director Khaldoon Al Mubarak in December 2025 to be "in place and ready" in Q3 2026 — has passed its target window without independent confirmation of energization in the sources inspected for this article. The National on the Q3 2026 first-phase target

The public record around G42 tends to be sorted into three buckets: what is approved, what is announced, and what is operating. A fourth bucket now matters more: what expires. The July 2026 rule created a named-entity privilege with a built-in countdown. Its sunset is not contingent on regulatory displeasure or a future review — it is a date-certain expiry with one specified escape route, becoming a US company.

The precise legal test for that conversion (incorporation, redomiciliation, acquisition, or an ownership threshold) is not defined in the sources available for this article, which is itself a source of uncertainty for anyone planning multi-year compute deployments against this entitlement.

The relationship between the layers is also unclear. The November 2025 authorization — a purchasing permission for the equivalent of up to 35,000 Blackwell GB300 chips, estimated by Reuters at roughly $1 billion for that quantity, conditioned on "rigorous security and reporting requirements" — predates the Supplement No. 8 entitlement. Whether the two are cumulative, sequential, or partially superseding is not established in public reporting inspected here.

What is established is the direction of travel: from a draft figure of 500,000 chips per year for the UAE (May 2025, attributed to unnamed sources and never confirmed at that scale) to a named-entity authorization with an 18-month fuse.

Meanwhile the physical buildout is being re-planned rather than commissioned. The September 2026 Reuters report describes the 5GW project moving from a single campus toward distributed hardened sites — a design change whose cost and schedule effects Reuters could not determine. G42's own position, that work is "progressing as planned" and specifics are subject to "continuous review," sits in tension with the reporting it responds to. On the operating side, the confirmable base remains what prior BTW coverage documented: Khazna Data Centers operating around 650MW reported capacity, a company plan to add over 1GW of hyperscale capacity across multiple countries by 2030 Khazna's announced capacity plan, and a 200MW Microsoft-G42 expansion announced November 5, 2025 Reuters on the Microsoft-G42 announcement — announcements and plans, not energized compute.

The same July 2026 rule also names US-headquartered Amazon, Apple, Google, Meta, Microsoft, OpenAI, Oracle and X.AI as eligible recipients of advanced computing items in the UAE, and indicates MGX would receive a favorable license-review policy. Covington & Burling's summary of the eligible recipients That pairing is the quiet tell: the US firms' eligibility is not time-boxed the way the G42 and Core42 entitlement is. The asymmetry makes the sunset clause read less like a facilitation and more like a conversion mechanism — a structured incentive toward US corporate identity for the two named UAE entities.

For readers tracking deployment risk, the mechanism is straightforward. Compute availability in the UAE through this channel now depends on an entity-specific authorization with a fixed expiry. Every long-lead decision — chip orders, power contracts, tenancy commitments at Stargate UAE or Khazna facilities — must either complete before the fuse burns down, survive on a different legal basis after it, or be contingent on a corporate restructuring whose terms are unknown. None of the gigawatt announcements changes that arithmetic.