July 2026
On 8 July 2026, new Cabinet of Ministers Resolution No. 875 ‘On Certain Matters of International Transfers of Goods for the Duration of Martial Law in Ukraine’ (adopted on 1 July 2026) (Resolution No. 875) entered into force. It applies to goods for military purposes and dual-use goods.
Resolution No. 875 was adopted to put into practice the so-called Drone Deal format – a concept of long-term security partnership between Ukraine and partner states, based on agreements on joint production, supply, or technology exchange in the field of unmanned systems and other defence technologies.
With the adoption of Resolution No. 875, a special export control regime for Ukrainian military products has been introduced, enabling representatives of Ukraine’s defence industry to export the military products and technologies they manufacture and develop.
Resolution No. 875 does not repeal the general export control procedure for military and dual-use goods established by Cabinet of Ministers Resolutions No. 1807 as of 20 November 2003 and No. 86 as of 28 January 2004. During martial law in Ukraine, and for six months after it ends or is lifted, those resolutions will apply only to the extent they do not conflict with Resolution No. 875, and will also apply to export operations of military and dual-use goods carried out outside the Drone Deal format.
Export controls introduced by Resolution No. 875 provides the following.
EXPORT IS BASICALLY POSSIBLE FOR GOODS / TECHNOLOGIES SPECIFIED IN RESOLUTION NO. 875
These include:
Military goods included in the list of military goods that have been put into service or codified as items for supply to Ukraine’s defence forces;
Dual-use goods included in the unified list of dual-use goods that may be used to develop, manufacture, or use the above military goods;
Goods not included in either list, where such goods have been put into service or codified as items for supply to Ukraine’s defence forces (subject to certain conditions);
Military technologies and technologies included in the Unified List of Dual-Use Goods.
A LICENCE AS THE BASIS FOR EXPORT OPERATIONS
Export of goods and technologies is carried out on the basis of a licence issued by the State Service for Export Control (SSEC) under the procedure set out in Resolution No. 875.
Contractors performing state contracts, and entities included in the register of participants in the selection and performance of state contracts, are exempt from the obligation to obtain the authorisations for international transfers of goods that would otherwise be required under the general export procedure.
* This does not, however, remove the need to register with the SSEC, to undergo a preliminary examination of the goods, or to comply with other requirements.
VALUE THRESHOLD
For exports of finished products, the value of the relevant shipment must be at least UAH 15 million (approximately EUR 295,000) to qualify for a licence.
For exports of components and spare parts, this value threshold does not apply.
PROCEDURE AND CONDITIONS FOR ISSUING A LICENCE FOR EXPORT OPERATIONS UNDER RESOLUTION NO. 875
A licence is issued on the basis of an application submitted by the exporter, together with the supporting documents listed in Resolution No. 875.
The overall period for reviewing the application and deciding whether to issue a licence may not exceed 30 calendar days.
The SSEC issues the licence subject to approval by the Ministry of Defence, as well as interagency clearance from the Security Service of Ukraine, the Foreign Intelligence Service, and the Defence Intelligence Directorate of the Ministry of Defence (DIU).
! This interagency clearance must be completed within the 30-day period set for reviewing the licence application. Approval by the Interagency Commission on Military-Technical Cooperation and Export Control Policy (Interagency Commission) may be required only in certain cases.
CONDITIONS FOR EXPORT OPERATIONS UNDER RESOLUTION NO. 875
a/ Requirements for foreign counterparties
Foreign counterparties – importers, end users, intermediaries (including their owners and officers), etc. – must not:
be sanctioned entities or included in the list of persons connected with terrorist activity;
be under the direct or indirect control of russia or entities connected with it;
directly or indirectly hold corporate rights in legal entities established under russian law.
b/ Restrictions on importing countries and critical products
As a general rule, exports are permitted only to states that are Ukraine’s partners under the Drone Deal format. The list of such states is approved by the Ministry of Foreign Affairs (in agreement with the Interagency Commission) and updated quarterly (the List of Partner States).
The List of Partner States is still being drawn up. However, publicly available information indicates that Ukraine has signed Drone Deal agreements with nine states: Lithuania, Latvia, the UAE, Saudi Arabia, Qatar, Azerbaijan, Denmark, the Netherlands, and Estonia. Negotiations on Drone Deal agreements are also under way with around 20 further countries, including Germany, Norway, and Italy.
The Ministry of Defence (in agreement with the Interagency Commission) approves the list of goods and technologies whose export could threaten Ukraine’s defence capability and national security (the List of Critical Goods). The List of Critical Goods is likewise updated quarterly. As a general rule, export of goods on this list is not permitted. The List of Critical Goods is currently still being drawn up.
Notwithstanding the above, exporters may obtain a licence for exports that do not fully meet the basic requirements of Resolution No. 875, namely:
exports of goods and/or technologies to countries outside the List of Partner States;
exports subject to a partial export embargo;
exports of goods and/or technologies included in the List of Critical Goods;
exports subject to restrictions arising from Ukraine’s international obligations;
and cases where the relevant authorities raise objections during interagency clearance.
In such cases, however, a licence may be issued only with the approval of the Interagency Commission.
c/ Priority for equipping Ukraine’s defence forces with military products
A licence may be refused if, in particular, the Ministry of Defence or another Ukrainian state defence procurer plans to purchase the relevant products for Ukraine’s defence needs (provided that the Ministry of Defence or other state procurer enters into a procurement contract with the exporter for the relevant products within 30 calendar days of such refusal).
A licence may nonetheless be granted if the exporter provides written assurances that the export will not prevent performance of the state contract.
d/ Protection of Ukrainian technologies and related intellectual property rights. Control over end use of goods
The SSEC may issue a licence to transfer goods and technologies only if the foreign importing state provides an assurance document on protecting rights to the Ukrainian technologies, including their use for the purpose specified in the contract. Resolution No. 875 sets out extensive requirements for the content of such assurances.
FEE FOR ISSUING A LICENCE FOR EXPORT OPERATIONS
Issuance of a licence is subject to a fee. The fee is:
20% of the value of the goods / technologies – for a licence to:
export goods that are finished products,
transfer technologies, or
re-export by a foreign counterparty to third countries of goods it manufactured using the transferred technology;
30% of the value of the goods – for exports of components (spare parts).
SUSPENSION AND REVOCATION OF A LICENCE
An issued licence may be suspended, in particular, if there is information about non-performance of a state contract, non-payment of the licence fee, or a state procurement need.
A licence may also be revoked, in particular, in the event of:
inaccurate information provided in the application or supporting documents;
sanctions being imposed on any party to the export operation (exporter, importer, end user, intermediary, etc.);
information being received about a breach of the licence conditions;
a breach of assurances by the importing state or supplier;
the goods or technologies being intended for use in unfriendly countries;
information being received about circumstances indicating a risk that the goods will be used other than for their stated end use, unauthorisedly re-exported, transferred to third parties, or used contrary to Ukraine’s national security interests or international obligations.
