# GitHub Copilot: Export Restrictions and Troubleshooting > How to distinguish an export restriction from a payment decline and an authentication error in VS Code. GitHub’s official policy and the limits of the appeal process. Source: https://ailoot.ai/blog/en/github-copilot-export-controls/ Canonical: https://ailoot.ai/blog/en/github-copilot-export-controls/ Language: en Publisher: Ailoot (https://ailoot.ai/) Translation: guide-098 Revision: sha256-965dbac5b51f86b836755c0cab0ae2e0c264b3f3811f9754a695a1698bbbf49c If you already have a GitHub account but Copilot is unavailable in VS Code, or a rejection occurs when you try to pay, first record the stage at which the problem arises. This article covers the service policy and signing back in to VS Code. [Practical information on working with Ailoot is in the documentation](https://ailoot.ai/docs/).
Warning This article is for reference and is not legal advice. Official GitHub documents are cited below; the English quotations are followed by a translation.
## How does GitHub separate regional cloud access from export restrictions? The “GitHub and Trade Controls” page has a separate section on Copilot:

GitHub Copilot is a commercial, mass-market product and has been assigned the Export Control Classification Number (ECCN) of 5D992.c and may be exported to most destinations with no license required (NLR).

— GitHub, trade controls policy, https://docs.github.com/en/site-policy/other-site-policies/github-and-trade-controls.md
Translation: Copilot is a commercial, mass-market product with the export classification number ECCN 5D992.c. It can be exported to most destinations without a license. The next paragraph limits this permission:

GitHub Copilot may not be sold, exported, or re-exported to any embargoed destination or a country listed in Country Group E:1 in Supplement No. 1 to part 740 of the EAR without authorization. These destinations currently include Cuba, Iran, North Korea, Russia, Belarus, and the following regions of Ukraine: Crimea/Sevastopol and the separatist areas of Donetsk and Luhansk. This list is subject to change.

— GitHub, trade controls policy, https://docs.github.com/en/site-policy/other-site-policies/github-and-trade-controls.md
Translation: Copilot cannot be sold, exported or re-exported without authorization to embargoed destinations or countries in Group E:1 of Supplement No. 1 to part 740 of the U.S. Export Administration Regulations (EAR). These destinations currently include Cuba, Iran, North Korea, Russia, Belarus, Crimea/Sevastopol and the separatist areas of Donetsk and Luhansk. The list may change. The wording gives two grounds: an embargo or inclusion in Group E:1. The list that follows applies to both. The terms for GitHub.com are described separately. For cloud services in Iran, GitHub cites a license from the U.S. Office of Foreign Assets Control (OFAC); for Cuba, it states that free and paid cloud services are generally available. This does not override the separate Copilot provision quoted above. ## What is known about sanctions screening of accounts Further down the page is a sanctions FAQ. Its list names Crimea, certain areas of Donetsk and Luhansk, Cuba, Iran and North Korea. The following rules on identifying accounts and on travel belong to that section.

If GitHub determines that a user or customer is located in a region that is subject to U.S. trade control restrictions for which GitHub does not yet have a license from the U.S. government, or a user is otherwise restricted under U.S. economic sanctions, then the affiliated account will be restricted to comply with those legal requirements. The determination of user and customer location to implement these legal restrictions are derived from a number of sources, including IP addresses and payment history. Nationality and ethnicity are not used to flag users for sanctions restrictions.

— GitHub, trade controls policy, https://docs.github.com/en/site-policy/other-site-policies/github-and-trade-controls.md
Translation: if GitHub determines that a user is located in a region subject to U.S. trade restrictions for which GitHub does not yet have a U.S. government license, or is otherwise subject to U.S. economic sanctions, the affiliated account is restricted. Location is determined using several sources, including IP addresses and payment history. Nationality and ethnicity are not used to flag an account for sanctions. This is a general rule from the sanctions section. The same section includes a condition for organizations:

If an organization is based out of, or the key individuals or membership of an organization shows sufficient ties to, a sanctioned territory or country for which GitHub does not yet have a license from the U.S. government, or if the organization otherwise appears to be subject to U.S. economic sanctions, then the organization account and the affiliated owner account will be restricted.

— GitHub, trade controls policy, https://docs.github.com/en/site-policy/other-site-policies/github-and-trade-controls.md
Translation: if an organization is based in a sanctioned country or territory for which GitHub does not yet have a U.S. government license, or its key individuals or members have sufficient ties to it, the organization account and affiliated owner account are restricted. The same applies if the organization is otherwise subject to U.S. economic sanctions. The travel warning applies to the regions in this FAQ section:

Travel in these regions may impact your account status, but availability may be reinstated once you are outside of the sanctioned region.

— GitHub, trade controls policy, https://docs.github.com/en/site-policy/other-site-policies/github-and-trade-controls.md
Translation: travel to these regions may affect your account status, but availability may be restored once you are outside the sanctioned region again. ## How this differs from a card being declined during payment If a rejection message appears when you try to pay, save its exact wording for a support request. Such a rejection does not by itself prove that the export rule was applied. Pricing and the free plan are covered separately: [what is free in GitHub Copilot](https://ailoot.ai/blog/en/github-copilot-free-plan/). The cited sources cannot establish the cause of a particular payment rejection or support a promise that another card will restore access. Do not treat the absence of a sign-in problem as evidence of a sanctions flag. ## How this differs from an authentication problem in VS Code If you have already signed in to GitHub but Copilot is unavailable in VS Code, the documentation says there may be an authentication problem:

If you are signed in to GitHub but Copilot is unavailable in Visual Studio Code, it may be due to an authentication problem.

— GitHub, troubleshooting Copilot, https://docs.github.com/en/copilot/how-tos/troubleshoot-copilot/troubleshoot-common-issues.md
Translation: if you have signed in to GitHub but Copilot is unavailable in Visual Studio Code, the cause may be an authentication problem. GitHub suggests the following steps: 1. In the bottom-left corner of the VS Code window, click the **Accounts** icon, hover over your GitHub username and click **Sign out**. 2. Press **F1** to open the command palette and select **Developer: Reload Window**. 3. After the reload, sign back in to your GitHub account. Check whether Copilot is available after signing back in. If it is not, the cause has not yet been established: the same document also describes, for example, an outdated extension, the lack of a plan, or an error connecting to the GitHub API. It also links to the trade controls policy. Signing back in is not a way to remove an export prohibition. ## If you believe your account was flagged in error The general appeal process on the GitHub page is intended for accounts affected in error. It is not presented as a separate procedure for Copilot:

In the rare instance that an account is affected unintentionally or in error, we have an appeal process to address such instances. If an individual user or organization owner believes that they have been flagged in error, then that user has the opportunity to appeal the flag by providing verification information to GitHub. If GitHub receives sufficient information to verify that the user or organization is not affiliated with a U.S.-sanctioned jurisdiction for which we do not have a license or otherwise restricted by U.S. economic sanctions, then the flag will be removed.

— GitHub, trade controls policy, https://docs.github.com/en/site-policy/other-site-policies/github-and-trade-controls.md
Translation: if an account is affected unintentionally or in error, the user or organization owner can appeal the flag by providing verification information to GitHub. The flag is removed if there is enough information to verify that there is no affiliation with a U.S.-sanctioned jurisdiction for which GitHub has no license and no other restrictions under U.S. economic sanctions. The source directs readers to GitHub Support for help. If you believe the flag is an error, describe the situation to GitHub Support at support.github.com/request. Do not present your assumption about the cause of the failure as a confirmed flag. The cited process does not specify a review timeframe. ## Quick checklist 1. Record where the rejection occurs and the exact wording of the message. A payment rejection does not by itself confirm an export restriction. 2. If you have signed in to GitHub but Copilot is unavailable in VS Code, sign back in as described above and check the result. 3. If signing back in did not help, that still does not mean there is a sanctions flag. Open the official Copilot troubleshooting documentation; it describes other causes too. 4. If you suspect an erroneous sanctions flag, contact GitHub Support. 5. Check the current list of destinations on GitHub's export policy page: the source warns that it changes. Another Copilot question is covered in [“6 models being removed from Copilot on 19 October”](https://ailoot.ai/blog/en/github-copilot-model-deprecation-2026/).
### Sources - [GitHub: trade controls policy](https://docs.github.com/en/site-policy/other-site-policies/github-and-trade-controls.md) — the separate export rule for Copilot and general questions about sanctions restrictions. - [GitHub: troubleshooting Copilot](https://docs.github.com/en/copilot/how-tos/troubleshoot-copilot/troubleshoot-common-issues.md) — reasons for unavailability and signing back in to VS Code.
[Go to Ailoot](https://ailoot.ai/). ## Questions about GitHub Copilot: Export Restrictions and Troubleshooting ### Does a declined Copilot payment prove an export restriction? No. Record the exact message and the stage where it appears. A payment decline, a VS Code authentication failure, and an export restriction require different checks; the decline alone does not establish a sanctions flag. ### What should I do if Copilot is unavailable after signing in to VS Code? Sign out through Accounts, reload the window with Developer: Reload Window, and sign in again. Check the result; if it still fails, use the official troubleshooting page or support because the cause is still unproven. ## Ailoot · The company and its project portfolio Ailoot combines established operating experience, a large client base, stable service and ongoing KPI control. The company and its project portfolio: millions of customers; monthly sales in the billions. Ailoot brings that operating experience to API access for AI features in customer products, agents, applications and automations.