NVIDIA End-User Requirements and Certificate

Written and maintained by Haink's procurement and allocation advisory team · Updated September 2026

Export references verified as of 19 September 2026 against the eCFR, bis.gov and nvidia.com. Reviewed quarterly; next review December 2026.

An end-user certificate, also called an end-user statement, is a signed declaration by the party that will own and operate the GPUs. It states who that party is, where the hardware will be installed, what it will be used for, and that it will not be passed on to restricted parties or uses. For NVIDIA data-center GPUs it is normally requested by the supplier, OEM or distributor that sells or exports the hardware. NVIDIA does not publish a standard form for it. The document exists because US export rules put the duty to know the end user on the exporter, and because manufacturers and OEMs apply their own compliance on top of those rules. The certificate is one document in a chain: the end user, the installation address and the intended use have to agree with each other and with the company and site documents. A request fails when they don't, when the end user can't be named, or when the use or destination is restricted.

What is an end-user certificate for NVIDIA GPUs?

In GPU procurement, "End User Statement" and "End User Certificate" are used for the same kind of document. It is a written statement by the end user, signed by an official who can bind the company. It identifies the parties to the transaction, the installation location and the intended end use, and it carries commitments about re-export, transfer and prohibited uses.

Who signs it. The end user: the legal entity that will own and operate the hardware. Where the purchaser is a different company, such as an integrator buying for a client, the purchaser's details appear as well and both may be asked to sign.

Who asks for it. The party that sells or exports the hardware: the supplier, the OEM or the distributor. Their compliance function reviews it, and the OEM channel reviews it before committing supply. NVIDIA may take part in a technical, ecosystem or end-user review, depending on the product, the volume, the destination and the supply route. It does not take part in every order.

Is there an official NVIDIA form? NVIDIA's export regulations page publishes ECCN and HS classifications by part number. It does not describe an end-user statement or provide a form (checked 19 September 2026). The form a buyer receives therefore comes from the selling or exporting party, and its layout differs between suppliers. The information it asks for differs much less, and is set out below.

Is it a government form? Usually not. The Export Administration Regulations (EAR) contain one formal end-user document, the Statement by Ultimate Consignee and Purchaser in 15 CFR §748.11, made on Form BIS-711 or on company letterhead. The regulation makes it mandatory for licence applications that include "600 Series Major Defense Equipment", not for GPUs, although BIS "may require" it case by case for other applications (eCFR text current as of 16 September 2026, checked 19 September 2026). The statement a GPU buyer is asked for is normally the supplier's due-diligence document. Where a licence is needed, the exporter decides which supporting documents go with the application.

Why does a legitimate GPU supplier ask for it?

Because the exporter carries the duty to know its customer. BIS's "Know Your Customer" guidance, Supplement No. 3 to Part 732 of the EAR, says that when red flags appear "you have a duty to check out the suspicious circumstances". It also warns against self-blinding: a seller that avoids asking questions does not protect itself by doing so (eCFR text current as of 17 September 2026).

Because BIS asks for it specifically for AI chips. On 13 May 2025 BIS published industry guidance to prevent diversion of advanced computing integrated circuits. Among its due-diligence steps, it recommends that exporters "seek an end-user certification with detailed information on all proposed transaction parties", and that they request a written attestation from the data center that the end user is authorised to operate there and that the site has the infrastructure to run the hardware (guidance still published on bis.gov, checked 19 September 2026).

Because the vendor has its own rules. Manufacturers and OEMs apply commercial compliance on top of the regulation, and that layer is not published. It is why a supplier may ask for an end-user statement for a destination where no export licence is required. How the regulatory layer and the vendor layer differ is explained in why passing BIS is not the same as being shipped.

A supplier that asks these questions is doing what a supplier connected to a reviewing party has to do. What it means when a seller asks none of them is covered in how to verify a GPU supplier.

What does a GPU end-user statement contain?

Forms vary by supplier. Their content tracks the information list in the BIS counter-diversion guidance of 13 May 2025 and the vendor's own requirements. Each item has a reason, and each has a typical way to fail.

The full document set that surrounds the statement, including company registration, the data-center agreement and logistics details, is listed in what is needed before the supplier or OEM channel.

How are the end user, site and use checked together?

The statement is not read field by field. It is read as one chain, in which each link tests the one before it.

1. End user. A named legal entity with a verifiable registration, ownership and line of business.
2. Installation address. Tests the end user: does this entity have the right to place hardware at this site, shown by a colocation contract or a letter of intent for capacity, and will the operator attest to it? The BIS guidance of 13 May 2025 adds that data centers able to operate more than 10 megawatts of servers "merit additional scrutiny". That is a reason for closer review, not a disqualification.
3. Intended use. Tests the address and the quantity: a stated workload has to fit the configuration ordered and the power and cooling the site can deliver.
4. Exporter and supplier requirements. The exporter maps the combination to the rules: the classification of the items, the destination, the parties and the end use. The outcome is that no licence is required, that a licence is required, or that the request can't be supported. The applicable export requirements are determined by the exporter or supplier, not by the buyer or a reseller.

For step 4, the reference points are public. Advanced computing items are controlled under ECCNs 3A090 and 4A090, as cited in the BIS rules published in the Federal Register on 15 January 2026 and 14 July 2026 (checked 19 September 2026). Country groups are defined in Supplement No. 1 to Part 740 of the EAR. End-use and end-user controls sit in Part 744. The classification of a specific part number is looked up, not assumed, and destination rules for these items have changed several times, including at least twice in 2026. Country-level detail is kept in export controls and dual-use IT hardware.

Consistency is the real test. The statement is read against the company registration, the data-center agreement and, later, the commercial and shipping documents. The same end user, the same address and the same configuration have to appear in each. A contradiction between them is not a formality to be fixed at the end. It stops the review.

What if the buyer is not the end user?

Integrator or reseller buying for a client. The end user is the client, and the statement comes from the client. A request "for a client to be identified later" can't be assessed, because there is nothing yet to review.

Hardware hosted in a third-party data center. The end user is the company that owns and operates the hardware. The data-center operator is a separate party that confirms the end user's right to be there and the site's capacity.

GPU cloud or GPU-as-a-Service. The question extends from who holds the hardware to who uses the compute. The BIS guidance of 13 May 2025 treats as a red flag an Infrastructure-as-a-Service provider that "does not or cannot affirm" that its users are not headquartered in China. For exports to China and Macau reviewed case by case under the rule of 15 January 2026, the ultimate consignee must run "rigorous Know Your Customer (KYC) procedures" to prevent unauthorised remote access. Outside those specific rules, suppliers commonly ask a compute provider about customer KYC, access controls and a ban on passing compute to restricted users. They also look at its ultimate parent. These projects are possible but harder to clear; the ladder of project types is in which projects clear most easily.

Financed or leased hardware. A lessor or lender may hold title, but the end user is still the operator. Both may appear in the documents, and the statement describes the operator's use and site.

What disqualifies a request?

Some findings end a request. Others stop it until they are resolved.

End the request:

• an end user or party on a restricted list, such as the BIS Entity List;
• a military, intelligence or weapons-related end use;
• an end user, destination or use that is not the real one;
• documents that contradict each other on the end user, the address or the configuration.

Stop the request until resolved:

• an end user that isn't named yet;
• ownership or an ultimate parent that isn't disclosed;
• an intended use too vague to assess;
• a site with no agreement, or without the power and cooling for the configuration;
• a quantity the use and the site don't explain.

The procedural stop list that applies before a request goes to a supplier is published in what stops a request. For advanced computing chips, the BIS guidance of 13 May 2025 lists further red flags, and it is the most direct public statement of what reviewers look for.

What happens if something changes after the statement is signed?

The statement describes one deployment. If the end user, the installation address, the intended use, the configuration or the quantity changes, the statement no longer describes the order, and the request is reviewed again. The same applies when a compute provider starts serving a new category of customer, or when hardware is moved to another site or country after delivery.

The commitments in the statement stay with the hardware. Re-export or transfer to another party or destination requires authorisation where the rules require it. A change made quietly after delivery is exactly what the statement exists to prevent.

What can a buyer check alone, and what not?

What a buyer can check:

• the classification of a part number, on NVIDIA's export regulations page. NVIDIA states that this information is "for informational purposes only and should not be construed as a representation or warranty of any kind" (checked 19 September 2026), so it is a classification lookup, not evidence that a shipment will be approved;
• the country group of a destination, using the BIS interactive country groups tool, with the group definitions in Supplement No. 1 to Part 740;
• its own parties against the Consolidated Screening List, which includes the Entity List.

What a buyer can't check: the vendor's commercial compliance, which is not published, and whether a specific order will be approved. A claim that a request is "pre-cleared", or that no end-user statement is needed for current-generation data-center GPUs, can't be verified by the buyer and doesn't match how legitimate supply is reviewed.

Frequently asked questions

Does NVIDIA issue the end-user certificate?

No. The end user signs it, and it is normally requested by the supplier, OEM or distributor that sells or exports the hardware. NVIDIA's export regulations page publishes ECCN and HS classifications by part number and does not provide an end-user form (checked 19 September 2026). NVIDIA may take part in an end-user review depending on the product, volume, destination and supply route, but not in every order.

Is the end-user statement the same as Form BIS-711?

Not usually. Form BIS-711, the Statement by Ultimate Consignee and Purchaser in 15 CFR §748.11, is mandatory for licence applications that include 600 Series Major Defense Equipment, and BIS may require it case by case for others (eCFR current as of 16 September 2026). The end-user statement a GPU buyer signs is normally the supplier's own due-diligence document.

Is an end-user statement needed for GPUs bought from stock?

Yes. End-user and destination screening is not specific to allocation; see what is needed before the supplier or OEM channel.

Does a signed end-user certificate guarantee allocation?

No. It is one input to the review. Final allocation and hardware availability remain subject to manufacturer, OEM and supplier approval, applicable compliance requirements and supply availability.

Can the end-user details be kept confidential?

If a buyer does not want to disclose sensitive information at the first stage, a non-disclosure agreement comes first. It changes who sees the information, not what the review needs.

Can the end user or site be changed after the statement is signed?

Only by making a new request. The statement describes one deployment; a different end user, address, use, configuration or quantity is reviewed again.

How Haink takes a request from the end-user package to executable supply and a purchase order: GPU procurement process →