Ukraine simplifies the procedure for obtaining export permits from the SSECU
Ukraine simplifies the procedure for obtaining export permits from the SSECU
16 July 2026
On 1 July 2026, the Cabinet of Ministers of Ukraine (the "CMU") adopted Resolution No. 875 approving the Procedure for International Transfers of Military and Dual-Use Goods for the Period of Martial Law in Ukraine (the "Procedure"). The Procedure came into force on 8 July 2026.
The Procedure introduces several novelties that simplify the existing procedure for obtaining an export permit issued by the State Service of Export Control of Ukraine (the "SSECU") for the export of military and dual-use goods.
In particular, the Procedure sets a shortened, 30-day period for reviewing an application for the SSECU permit for the export of certain military and dual-use goods to the "Drone Deal"[1] partner states. The Procedure also allows export permit applications to be reviewed without the prior approval (save for certain cases) of the Interagency Commission on Military-Technical Cooperation and Export Control Policy (the "Interagency Commission") under the National Security and Defence Council of Ukraine. It was this prior approval requirement that significantly extended the time needed to obtain the SSECU permit.
[1]"Drone Deal" is a general name for the international agreements under which Ukraine and a partner state have agreed on 10-year cooperation in the production, supply, joint development, technology exchange, or use of unmanned systems, as well as other defence technologies or defence goods. The Ministry of Foreign Affairs (the "MFA") will approve, on a quarterly basis, the official list of states to which controlled goods may be transferred under the simplified procedure ("List").
As of 16 July 2026, the MFA has not yet approved the List; however, public sources indicate that Ukraine has already concluded a "Drone Deal" with 9 countries, including the Netherlands, Denmark, Estonia, Qatar, the United Arab Emirates, Saudi Arabia, Azerbaijan, Lithuania, and Latvia.
Public sources also indicate that Ukraine has signed a letter of intent to conclude a "Drone Deal" with the European Union and continues negotiations on concluding it with a number of NATO countries.
The simplified permitting procedure envisaged by the Procedure is available for the duration of martial law in Ukraine and for six months after its termination. The general export control procedures (CMU Resolutions No. 1807 and No. 86) continue to apply to the extent they do not conflict with the Procedure.
Goods covered by the simplified procedure
The simplified procedure for obtaining the SSECU export permit covers:
- military goods (as per the list approved by CMU Resolution No. 1807 dated 20 November 2003);
- dual-use goods that can be used for the development, production, or use of military goods (as per the list approved by CMU Resolution No. 86 dated 28 January 2004);
- goods not included in the lists of military or dual-use goods but may be used in the end-user states at any stage (from development to storage or dissemination) of weapons of mass destruction or their means of delivery; and
- military or dual-use technologies.
Key condition: the goods must have been accepted for service or codified by the Ministry of Defence (the "MOD") as a supply item.
Financial threshold for the simplified procedure
The simplified procedure for obtaining the SSECU export permit is available if the value of the goods is at least UAH 15 million (approx. EUR 300,000).
The UAH 15 million threshold only determines which procedure applies: if the value of the goods exceeds UAH 15 million, the simplified permitting procedure applies; if it is lower, the general procedure with a 90-day document review period applies. In either case, registration with the SSECU as an entity carrying out international transfers of goods and obtaining an export permit remain mandatory regardless of the value of the goods.
That said, the financial threshold does not apply to components and parts (the SSECU permit may be obtained under the simplified procedure).
Safeguard protecting Ukrainian manufacturers
Alongside simplifying the export procedure for certain goods, the Procedure provides a mechanism for Ukrainian manufacturers to retain intellectual property rights to technologies (favouring licensing rather than assignment of rights) and to control the further transfer, re-export, or disposal of goods manufactured using such technologies.
In particular, to obtain a permit, the exporter must submit to the SSECU a guarantee document (for example, an international import certificate obtained by the importer) under which the "Drone Deal" partner state guarantees:
- a ban on the assignment of intellectual property rights to the technologies and on the sale of the technologies;
- that any further transfer, re-export, sale, or temporary export of goods manufactured using the technologies, as well as any transfer of the technologies, documentation, or related services to third parties, will take place only with the prior written consent of the SSECU;
- that goods will be manufactured using the transferred technologies only in the quantities and on the terms set out in the relevant licence agreement;
- that Ukraine will be informed of any further modifications to the goods manufactured using the transferred technologies; and
- that, in the event of re-export of goods manufactured using the transferred technologies, 20% of the value of such goods will be paid to Ukraine.
Permit fee
A fee is charged for the issuance of the SSECU permit: 20% of the value of the goods – for a permit to export self-contained (finished) goods or technologies, 30% – for a permit to export components and parts, and 20% – for a permit to re-export to third countries goods manufactured using the transferred technologies.
The fee must be paid before the application is filed with the SSECU, as the application must be accompanied by a supporting payment document (for example, a payment instruction, receipt, or payment order). The Procedure does not provide a dedicated mechanism for refunding the fee if the SSECU refuses to issue a permit. Given the negative feedback from industry on this requirement, the rule is likely to be revisited or clarified.
Specific grounds for refusal to issue the SSECU permit
If the MOD or another state customer in the defence sector (for example, the Security Service of Ukraine, the Foreign Intelligence Service, or the Defence Intelligence of Ukraine) intends to purchase the exporter's goods for the needs of the defence forces, the SSECU will have the right to refuse to issue an export permit.
However, if the exporter undertakes to supply the goods for defence needs in the volumes and within the timeframes set by the MOD or another state customer, the SSECU will not be able to rely on this ground for refusal.
In addition, the SSECU will be able to refuse a permit if the goods or technology have been included in the list of "critical"[2] items. The MOD will approve this list on a quarterly basis, and the SSECU will be required to take it into account when reviewing export permit applications. The criteria for inclusion in the list and the procedure for removal from it have not yet been detailed, which is worth factoring in when planning long-term projects.
[2]Goods and technologies whose export may pose a threat to Ukraine’s defence capability and national security.
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Conclusions
The Procedure is designed to make it easier for manufacturers of military and dual-use goods to access the markets of the "Drone Deal" partner states by shortening the permit application review period from 90 to 30 days and removing the need to clear exports of controlled goods with the Interagency Commission.
Manufacturers of controlled goods planning to enter these markets should prepare in advance: identify the goods, check them against the control lists, register with the SSECU as an entity carrying out international transfers of goods, verify compliance with the general requirements that remain in force (including, where applicable, obtaining the CMU authorisation to export military goods and certification of the in-house export control system (internal compliance programme)), and file an export permit application under the general or the simplified procedure.
Source: Resolution of the Cabinet of Ministers of Ukraine No. 875 dated 1 July 2026 "Certain Issues of International Transfers of Goods for the Period of the Legal Regime of Martial Law in Ukraine".
Our experts: Yevheniy Deyneko, Vladyslav Shulkin.
How we can help:
- assisting with the preliminary identification of goods against the control lists;
- specific product (technology);
- assisting with registration with the SSECU as an entity carrying out international transfers of goods;
- preparing and filing the documents to obtain the CMU authorisation to export military goods;
- drafting and supporting the negotiation of an export contract with a foreign counterparty;
- advising on intellectual property matters related to the export of goods and technologies;
- preparing and filing an application for the SSECU export permit under the simplified or the general procedure; and
- supporting interactions with the SSECU during the review of the export permit application.
