AWS EC2 Spot Instances (interruptible GPU capacity, general)

NO price_usd recorded, deliberately. AWS advertises a discount of 'up to 90% off compared to On-Demand' and states prices 'adjust gradually based on long-term trends in supply and demand', but the concrete per-SKU spot table renders client-side from describe-spot-price-history and spot-price.s3.amazonaws.com/spotprice.js returned HTTP 403 when fetched 2026-10-03. A derived or remembered spot rate would be invented.

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.

A structural record rather than a price record. Spot is the cheapest credible route to AWS Hopper and Blackwell capacity by a wide margin when it works - independent neocloud evidence elsewhere in this slice puts H100 spot at roughly 40% of the on-demand rate - and it is the real answer to the p5 allocation problem. The catch is interruption: AWS reclaims Spot instances on a two-minute warning, and the p5 SKUs are exactly those with the deepest demand pools and therefore the worst interruption profile. Practical guidance: Spot for fault-tolerant training with checkpoint resume, never for an interactive inference endpoint; Capacity Blocks when the pool must still be there tomorrow. 'Up to 90% off' is a ceiling across all EC2 SKUs, not the H100 discount specifically. Note the same mutual-exclusion logic as on Google Cloud, where the pricing page states explicitly that Spot VMs and preemptible VMs cannot receive CUDs or SUDs: never model a Spot instance as if it were also earning a commitment discount. 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.