AWS EC2 P5 (NVIDIA H100 SXM, on-demand + Capacity Blocks)

per H100 SXM GPU-hour; 8x H100 per p5.48xlarge instance. On-demand us-east-1 $55.04/instance-hr / 8 = $6.88. Capacity Block $41.528/8 = $5.191 per H100 in us-east, $37.76/8 = $4.720 in ap/eu/sa. Fetched 2026-10-03 from an offer file published 2026-09-25; AWS publishes no regional on-demand variation for this SKU (verified identical in us-east-1 and us-west-2) PERISHABLE-FIGURE STAMP (added 2026-10-04, uniform across data/supply/ so it is greppable). PRICE CLASS: PUBLISHED LIST PRICE - an asking rate a new customer is quoted, NOT a realised, discounted or negotiated transaction rate. A real bill is at or below this and typically well below it once commitments, credits and committed-use discounts apply. OBSERVED: 2026-10-03 RE-VERIFY BY: 2027-01-04 - the repo's quarterly re-verification bar. After that date this figure is presumed drifted and must be re-checked against its source before it is quoted again. A price without its observation date is noise; this stamp exists so a reader can tell a fresh figure from a stale one without reading prose. UNIT: per H100 SXM GPU-hour; 8x H100 per p5.48xlarge instance READING RULE: No further perishable flag is published for this figure.

lead_time_weeks is null because the quantity is structurally not applicable: on-demand cloud capacity starts on request, so there is no order-to-delivery lead time. The constraint is the price per GPU-hour and the availability snapshot, not an interval. The one caveat worth keeping: scarce tiers gate capacity behind a reservation or Capacity Block commitment (AWS caps the booking horizon at 8 weeks, source spl-aws-capacity-block-booking-horizon), and that is a commitment window, not a lead time.

EAR 742.6(a)(6)(iii)(A) + EAR 744.23/744.6 (Entity, Unverified, MEU list screening of the end user) + the advanced-computing IaaS obligations of 91 FR 1684 (consignee KYC, and management/limitation of IaaS access to the hardware)

LAYER 1, EXPORT LICENCE: under the Jan 2026 BIS rule 91 FR 1684 (effective 2026-01-15) the license review policy for advanced-computing commodities with TPP < 21,000 AND total DRAM bandwidth < 6,500 GB/s - the NVIDIA H200 and AMD MI325X are the rule's named examples - moved from PRESUMPTION OF DENIAL to CASE-BY-CASE REVIEW, but only for exports FROM THE UNITED STATES to end users located in China or Macau, and only against six exporter certifications filed via SNAP-R before shipment: (1) items below the thresholds with the count of units shipped in the US; (2) sufficient US supply, judged 'taking into account normal lead times'; (3) no diversion of global foundry capacity away from US end users; (4) aggregate China+Macau shipments <= 50% of total US end-use shipments of that product; (5) no end-user or use prohibition; (6) the consignee runs rigorous KYC. Every shipment must then pass a qualified third-party testing lab - US-headquartered, not controlled by a D:5/Macau entity, no ownership stake in any party, qualification revocable by BIS at any time - verifying TPP, total DRAM bandwidth, interconnect bandwidth and copackaged DRAM capacity. Reexports and in-country transfers of the same chips to China/Macau REMAIN PRESUMPTION OF DENIAL. LAYER 2, END-USER AND PARENT SCREENING: per BIS guidance of 2026-05-31 a licence is required where the consignee is HEADQUARTERED in Country Group D:5 (15 CFR part 740 supplement no. 1) or Macau OR whose ULTIMATE PARENT COMPANY is so headquartered - even when the consignee itself sits outside D:5/Macau. The requirement sits at EAR 742.6(a)(6)(iii)(A) for destinations outside the US, with an exception available only under the license exception at 740.2(a)(9)(ii). The destination country alone therefore never answers the question; screen the parent. LAYER 3, REMAINING LIMITS: exports to D:5/Macau-headquartered OR -parented entities stay PRESUMPTION OF DENIAL wherever the buyer sits, and the AI Diffusion Rule that would have set a country-tier structure on who could lawfully buy what was RESCINDED on 2025-05-13 and is not being enforced, so any recorded status rests on the instruments named here rather than on tiering.

THE SCARCITY RECORD FOR THIS SLICE. On-demand p5 capacity is not reliably purchasable: AWS's own price list carries p5.48xlarge with an explicit $0.00/hour rate alongside the real $55.04 (the same sentinel appears for p5.4xlarge, p5en.48xlarge and p4d.24xlarge), which is how that feed encodes 'no capacity'. The workable route is EC2 Capacity Blocks - reservable up to 8 weeks in advance for up to 6 months, 1-64 instances per block (512 GPUs), shareable across accounts. Every figure here is a RESERVATION rate paid up front, not a rate you can walk into. Price basis warning: Capacity Block rates are explicitly dynamic, re-set on supply/demand, and AWS has published a forward schedule effective 2026-10-07 that RAISES P5 from $5.191 to $5.970 per GPU-hour - so that figure is weeks from stale. Linux OS fee is $0.000/h on a p5.48xlarge; RHEL adds $1.8432/instance-hr (~$0.23 per GPU-hour) if you need it. p5.4xlarge gives a single H100 at the same $6.88/GPU-hr but the product page states GPUDirect RDMA is NOT supported on it - unusable for distributed training, fine for single-GPU inference. Egress is billed separately. No contract or sales call is required; a credit card and an AWS account suffice, though enterprise volume needs one. EXPORT CONTROL (2026-10-04, mechanism-level; sources spl-bis-2026-05-d5-guidance, spl-bis-2026-01-advanced-computing-case-by-case): renting capacity does NOT remove the export-control question, it relocates it. Providing remote access to controlled computing capability can constitute a transfer under the EAR, so the provider must screen the end user; and separately, under the 91 FR 1684 licence regime the consignee must run KYC procedures to prevent unauthorized remote access and must manage and limit IaaS access to the hardware - obligations pushed onto the customer, who must be told to implement them. For a customer headquartered or parented in Country Group D:5 or Macau the 742.6(a)(6)(iii)(A) end-user/parent test can bite even when the capacity is consumed in a permitted region. Recorded true because the underlying hardware is controlled and the provider carries the screening duty, not because access to a US region is itself restricted. LEAD TIME: null, and correct as null. For a listed on-demand instance type the provisioning delay is effectively zero - capacity is allocated per request - so a week count would be meaningless; the real gate for scarce shapes is either a quota increase or a capacity reservation, not a lead time. Where a published commitment horizon exists it IS recorded: AWS documents that a Capacity Block may be reserved with a start time up to EIGHT WEEKS in the future (source spl-aws-capacity-block-booking-horizon), which is a floor on how far ahead scarce capacity must be committed, not a wait. On-demand and Spot tiers publish no lead time at all; their constraint is availability, and the repo records that as availability=in-stock or a spot/reality note rather than as a fabricated week figure. Probe log in source spl-negative-no-oem-publishes-lead-time.