On 1 July 2026, Ukraine officially opened the door to arms exports. The government adopted the long-awaited Resolution No. 875, approving a new procedure for the international transfer of military and dual-use goods during martial law. The new framework is intended to strike a balance between two priorities: reducing bureaucratic barriers for exporters while ensuring that the needs of the Armed Forces of Ukraine remain paramount.
In a blog for Censor.NET, NAKO examines the new export rules and their implications. What has changed?
1. The end of “negotiation permits”
Previously, companies needed prior authorization from the State Export Control Service simply to begin negotiations with a foreign customer or prepare an export contract. Obtaining this approval could take up to a year. Under the new rules, developers and manufacturers registered with the Ministry of Defence can negotiate contracts and apply for export licences without first obtaining a separate negotiation permit.
2. Clearer division of responsibilities
The new procedure clearly defines the roles of the relevant government institutions:
- The State Export Control Service registers exporters, issues and revokes export licences, monitors end-use compliance, and maintains the national export registry.
- The Ministry of Defence compiles and updates a quarterly list of critical military goods that may not be exported, assesses the Armed Forces’ needs, and approves export licence applications.
- The Ministry of Foreign Affairs maintains a quarterly “white list” of countries eligible to receive Ukrainian defence exports.
- An interagency commission under the National Security and Defence Council (NSDC) approves both the list of eligible countries and the list of restricted military goods, while also reviewing exceptional or particularly sensitive export cases.
3. Faster procedures and the principle of “silent consent”
Export licence applications previously took more than three months to process. Under the new rules, the entire procedure is capped at 30 days, with agencies reviewing applications in parallel.
The reform also introduces the principle of silent consent: if the Security Service of Ukraine (SBU), the Foreign Intelligence Service, or Defence Intelligence fail to issue an opinion within 15 calendar days, the transaction is automatically deemed approved.
4. Simplified procedures for allied countries
Exports to countries that have signed defence cooperation agreements with Ukraine—including those participating in initiatives such as the Drone Deal—will follow a significantly simplified procedure. Such transactions will no longer require review by the NSDC interagency commission unless they involve sensitive technologies, re-exports, or concerns raised by Ukraine’s intelligence services.
5. Clear grounds for refusing exports
Previously, export applications could be rejected on the vague grounds that they were “contrary to national security interests.” The new rules require authorities to provide specific and justified reasons for refusal, such as sanctions against the buyer, links to hostile actors, or a manufacturer’s failure to fulfil government contracts.
Importantly, if the Ministry of Defence blocks an export because the weapons are needed by the Armed Forces, the state must sign a procurement contract with the manufacturer within 30 days. If no contract is concluded within that period, the government can no longer rely on that justification to prevent the export.