Ukraine Export Permit for Military and Dual-Use Goods (2026)
Updated 2 October 2026. Author: Peter Bilyk, Head of Technology and Investment and AI, Juscutum.
This guide is for general information and is not legal advice. Rules in this area change frequently, so confirm current requirements before acting.
An export permit for military and dual-use goods from Ukraine is issued by the State Export Control Service of Ukraine (SSECU). In 2026 there are two review tracks: a standard track of up to 90 calendar days and a simplified Fast Track of up to 30 calendar days. Fast Track applies to supplies to countries that have signed Drone Deal agreements with Ukraine and only to goods that are not on the list of critical goods. Producers and technology rights holders that perform state defence contracts, or are included in the register of selection participants and executors of state contracts, can apply. Separate special authority to export is not required. Transferring technology, source code or access to it to a foreign person is also an export.
What counts as an export
Many companies assume that export means physically shipping a product. Under export control rules it also covers:
- transfer of products and components;
- transfer of software;
- transfer of technical documentation;
- access to technology, such as source code, drawings and know-how.
For a technology company, any transfer of technology to a foreign person can be an export. Risks therefore arise before logistics, during negotiations and demonstrations.
Do your goods need a permit?
Scenario 1: the product is on a control list. If it appears on the list of military goods or the list of dual-use goods, export is possible only with a permit.
Scenario 2: the catch-all principle. A product that is not on any list can still be controlled if there is potential military use, a sensitive destination or a specific end user. Being absent from a list does not mean that a permit is not needed.
Who can export and what can be exported
According to the official export portal of the Ministry of Defence and SSECU, exporters are companies that are manufacturers of goods or owners of technology rights and that perform state defence contracts and/or are included in the register of selection participants and executors of state contracts.
Exportable items:
- finished products: weapons, equipment, unmanned systems, electronic warfare and other codified products or products accepted for service;
- dual-use goods;
- components, with no minimum contract value;
- technologies and documentation for producing defence products.
Step-by-step: how to obtain a permit
- Register with SSECU. Without registration, export is not legally possible.
- Find a foreign buyer. Contracts are concluded directly with foreign buyers. The contract should identify the end user, restrictions on re-export and the intended use.
- Classify the product and prepare documents. Decide what is being transferred (goods, technology or intellectual property) and whether it is controlled. A classification mistake carries into every later step.
- File the application with SSECU. If you want the simplified track, state this in the application.
- Receive the permit and ship. After the permit, SSECU continues to monitor international transfers and end use.
Under the general regime, certain types of permit (such as general and open permits) also require the company to run an internal export-control system: product classification, counterparty screening, access control to technology and documentation of transfers.
Two review tracks
How Fast Track works. The producer files the standard package with SSECU and asks for Fast Track review. SSECU checks completeness within up to 3 working days. The package then goes to inter-agency approval: up to 20 days for the Ministry of Defence and up to 15 days for other bodies. SSECU issues the final decision and the permit. The whole procedure takes up to 30 days.
Practice. As of mid-September 2026, trade bodies reported that the list of critical goods, which the Ministry of Defence must approve, had not yet been published. In late August the head of the Ukrainian Council of Arms Manufacturers said that no permits had been issued under the simplified mechanism in its first month. Plan for the standard timeline until practice confirms faster decisions.
How much a permit costs
According to the official portal, the cost of an export permit is set as a percentage:
Conditions and obligations
- Needs of the Defence Forces come first. Export is allowed on condition that the needs of the Defence Forces are met. A producer may give a guarantee that it will fulfil both the state defence order and the contracted export volume. In that case, demand from state customers is not a ground for refusal.
- Obligations to state customers. Failure to meet them is a ground for suspension or cancellation of a permit.
- Intellectual property. Under the Cabinet procedure, products are transferred without alienation of intellectual property rights.
- Re-export requires separate approval and payment at the rate above.
- Refusal. If a permit is refused and no state contract is concluded within 30 calendar days, the applicant may reapply, and the same ground cannot be applied twice.
Common mistakes
- Wrong classification. The company thinks it is selling a product, but the regulator sees a transfer of technology, and the deal stalls.
- Sharing technology before assessing risk. Typical cases are access to a code repository, drawings and technical demos. These can already be exports.
- A contract without key clauses. If the end user, re-export limits and intended use are not defined, a permit may not be issued.
- A conflicting structure. IP in one jurisdiction, R&D in Ukraine and the contract through another company can create conflicts between tax, rights and export control.
- Wrong order of steps. Negotiating first and trying to "legalise" later often ends the deal.
Liability
Article 333 of the Criminal Code of Ukraine provides liability for violating the procedure for international transfers of goods subject to state export control, including personal criminal liability for company management.
Defence City and export
The Defence City regime offers residents additional opportunities in export procedures. Specific terms depend on the company's status and the type of transfer, so check them against the rules for residents and the export portal. Registration and permit requirements remain.
Frequently asked questions
How long does an export permit take in Ukraine?
Up to 90 calendar days under the standard procedure and up to 30 calendar days under Fast Track.
Who can apply for an export permit?
Producers and technology rights holders that perform state defence contracts and/or are included in the register of selection participants and executors of state contracts. Separate special authority to export is not required.
What is Fast Track?
A simplified review for supplies to countries with Drone Deal agreements and goods not on the list of critical goods, with a decision in up to 30 days.
Do I need a permit to share source code with a foreign contractor?
Yes. Transferring software, repository access or technical documentation counts as an international transfer and falls under export control.
How much does a permit cost?
According to the official portal: 20% for finished products, 30% for component parts, 20% for technologies and 20% for re-export.
Are intellectual property rights transferred with the goods?
No. Under the Cabinet procedure, products are transferred without alienation of IP rights.
What are the penalties for violations?
Article 333 of the Criminal Code of Ukraine provides criminal liability, including for management.
Sources and related reading
- Defence exports portal of the Ministry of Defence and SSECU
- National Security and Defence Council: how to obtain a permit under Fast Track (23 July 2026)
- LexInform: 30 days for reviewing export applications
- Ukraine Defence Tech: Legal Guide for Investors
- Експортний контроль військових технологій (Ukrainian, detailed)
Contact
To discuss an export permit, a classification question or an export contract, contact the Juscutum Technology and Investment team through the contact page.
