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Reviewed by Oleksandr Sobovyi, Founder & CEO of CORVUS AI — editorial responsibility statement below.

Defence Codification in Ukraine: 1,530 Ukrainian-Made Systems in 2026

From 1 January to 25 September 2026, the Ministry of Defence of Ukraine codified and authorised for operation 1,678 items of weapons and military equipment. Of these, 1,530 — 91.2% — were produced by Ukrainian enterprises. In 2022, the corresponding number of Ukrainian-made items was 60. The 25.5-fold increase is not only an indicator of the growing maturity of Ukraine’s defence-industrial base. It also signals that codification has become a key regulatory gateway to the Ukrainian defence market — and that European partners should build their market-entry strategy around that gateway rather than around attempts to bypass it.

1. 2022–2026: three trends behind one number

Source: Ministry of Defence of Ukraine, 2 October 2026 · 2026 data as at 25 September.

Over five years, 5,727 items have been codified, including 4,363 Ukrainian-made items. The official statistics support three observations that are not expressly stated in the Ministry’s release.

First, 2026 has not yet reached its full-year level. In less than nine months, 1,678 items were codified. A simple extrapolation of the current pace — without adjusting for possible seasonality — would put the full-year figure at approximately 2,250–2,300 items, above the 2025 level. The number of Ukrainian-made items has already exceeded the total for the whole of 2025: 1,530 compared with 1,427.

Second, the 91.2% share reflects not only growth in Ukrainian production but also a sharp fall in the number of foreign-made items entering the codification statistics. In 2025, 623 foreign-made items were codified; in 2026, the figure is 148. The Ministry does not explain the reasons. Possible explanations include a change in the structure of supplies, greater procurement under already codified positions, or different admission routes for foreign systems.

Third, the trend has not been linear. In 2025, the share of Ukrainian-made items fell from 74.6% to 69.6%. The Ministry’s statement that the share increased by 67.3% is arithmetically correct when expressed as relative growth (91.2 / 54.5), but the increase is 36.7 percentage points. For a professional audience, that distinction matters.

2. What “codification” means legally

Ukrainian defence practice distinguishes between several procedures that are often conflated in public discussion:

1.         Adoption into service — the full development and state-testing cycle based on the state customer’s technical requirements.

2.         Authorisation for operation — an accelerated route used during the special period and martial law, under which a decision may be based on declared tactical and technical characteristics, test results and the technical documentation required by the applicable procedure.

3.         Codification — assignment of a nomenclature identifier to an item of supply and its entry into the supply system under the rules applicable to the relevant category of defence product.

Practical implication: for most new defence products, codification is a key stage in bringing the product into the supply system and enabling subsequent procurement with public funds where an operational requirement exists. For a manufacturer, this is not an administrative formality but a critical element of access to the state defence customer. The applicable framework nevertheless contains specific exceptions, including for certain categories of unmanned systems that may, subject to defined conditions, be procured without prior codification.

The sharp increase in codification figures is linked, among other factors, to simplified procedures introduced during martial law. The current version of Cabinet of Ministers Resolution No. 345 provides different supply and admission routes depending on the origin of the product, its development stage and the procurement circumstances. For certain wartime routes, codification follows assessment of declared tactical and technical characteristics, test results and technical specifications. The exact documentation package depends on the applicable route and product category.

The international layer is equally important. Ukraine participates in the NATO Codification System, and items of supply may be assigned NATO Stock Numbers (NSNs) in accordance with the applicable NCS rules. For a European partner, this primarily means standardised identification of the item within an interoperable logistics environment — not automatic recognition for procurement or operational use in another country.

3. What the figures do not show

Codification statistics measure access to the supply system, not the size of the market. Four limitations should be considered when assessing a partnership or investment.

4.         Item ≠ contract. Codification may enable procurement, but it does not guarantee an order. Public data do not show what proportion of the 1,530 Ukrainian-made items actually received contracts or in what volumes.

5.         The structure is only partially disclosed. According to the Ministry, 650 unmanned aerial systems had been codified by 22 September — around 39% of the 1,678 items reported in the statistics as at 25 September. An “item” does not necessarily mean an entirely new product: the statistics may include new and upgraded solutions and platform modifications. The Ministry’s release does not provide a complete comparable breakdown across all categories.

6.         “Ukrainian production” is not the same as localisation. The statistics refer to items produced by Ukrainian enterprises. They do not disclose the origin of components, engines, optics, electronics or software. This is precisely where export-control, supply-chain and dual-use risks arise for European component suppliers.

7.         Speed has a compliance cost. Accelerated wartime procedures increase the importance of robust testing and technical documentation. Manufacturers should assume that evidence, technical files and test results may require additional scrutiny if the applicable admission regime changes or if the product enters other markets.

The legal framework has been checked against the current version of Cabinet of Ministers Resolution No. 345 and official communications of the Ministry of Defence of Ukraine. Specific departmental procedures and requirements may vary by product category and admission route; the requirements applicable to a particular product should therefore be verified before submission.

4. What this means for European partners

The shift to 91.2% Ukrainian-made items points to a change in the structure of entry into Ukraine’s defence market. For European suppliers, the opportunity may increasingly lie not only in exporting a finished system to Ukraine, but in becoming part of a Ukrainian-produced system — through components, software, licensing, joint production or industrial partnerships. Three practical consequences follow.

8.         Consortia and joint ventures. For projects under European instruments supporting Ukraine’s defence industry, a codified Ukrainian partner can be an important indicator of an established route into the supply system. Codification status, NSN where assigned, type of authorisation and actual procurement track record should be included in due diligence alongside financial, corporate and sanctions checks.

9.         Rights in technical documentation. Admission and codification procedures may require a substantial body of technical and testing documentation. Where a product incorporates European components, software or third-party technology, rights to use, disclose, modify and transfer the relevant documentation should be contractually settled before the procedure begins.

10.    Export control and dual-use. Supplies of European components for Ukrainian defence products require prior export-control classification. Depending on the characteristics of the item, end user, end use and jurisdiction, Regulation (EU) 2021/821, national military-goods controls, sanctions restrictions and related licensing requirements may apply. Codification of the end product may support end-use documentation, but it does not replace export classification or any required licence.

One jurisdictional point is essential. Ukrainian codification is a national process integrated with the NATO Codification System. It does not automatically authorise procurement or operational use by the armed forces of another state and does not replace applicable national assessment, admission, certification or procurement procedures. NSN ≠ certification ≠ procurement eligibility ≠ mutual recognition.

5. What to do now

For Ukrainian manufacturers:

·       Build testing and technical documentation for future scrutiny, not merely to meet the minimum threshold of an accelerated wartime procedure.

·       Audit rights in design documentation and software, particularly where foreign components, licensors or subcontractors are involved.

·       For products incorporating AI or autonomous functions, prepare documentation in advance for the due-diligence requirements of European partners and funding instruments. A military-use exclusion from parts of the EU AI Act does not eliminate investor, contractual or procurement due diligence.

For European companies and investors:

·       Include codification status — NSN where assigned, date, type of authorisation and procurement track record — in the standard legal due-diligence checklist for a Ukrainian partner.

·       At term-sheet stage, determine who owns the technical documentation and software, who may disclose them to the state customer, and on what terms they may be used, modified or transferred in the EU and Ukraine.

·       Carry out export-control classification of supplied components in advance and verify the applicable military, dual-use and sanctions regimes so that licensing does not become the bottleneck in the production cycle.

CORVUS AI advises on EU–Ukraine defence and dual-use projects, including consortium structuring, partner due diligence, export controls and access to European funding. Contact: contact@corvusai.eu.

Oleksandr Sobovyi — Founder & CEO of CORVUS AI, PhD in International Law, Honoured Lawyer of Ukraine; former Director of the Legal Department of the Ministry of Defence of Ukraine.

Disclaimer

This article has been prepared by CORVUS AI for general informational and educational purposes only. It is intended to make complex legal and regulatory developments easier to understand.

It does not constitute legal advice and does not create a professional adviser–client relationship. The information should not be relied upon as a substitute for advice based on the specific facts, circumstances and applicable law relevant to your organisation or project.

The article reflects our understanding of the law and regulatory framework as of the date of publication. Legislation, case law, regulatory guidance and administrative practice may subsequently change. While reasonable care has been taken in preparing this article, CORVUS AI does not warrant that the information is complete or remains current after the date of publication. We do not undertake to update this content.

To the fullest extent permitted by applicable law, CORVUS AI excludes liability for loss arising from reliance on this article. Nothing in this article constitutes an offer or solicitation to provide regulated legal services in any jurisdiction where doing so would be unlawful.

AI-assisted preparation: This article was prepared with the assistance of AI tools. Its legal analysis, conclusions and final text were subject to human review and editorial control and were reviewed and approved prior to publication by Oleksandr Sobovyi, Founder & CEO of CORVUS AI. CORVUS AI retains editorial responsibility for the published content.

For advice tailored to your organisation, project or specific circumstances, please contact CORVUS AI.

Primary Sources

·       Ministry of Defence of Ukraine — codification statistics, 2 October 2026: https://mod.gov.ua/news/minoborony-kodyfikuvalo-ponad-1-500-vitchyznianykh-zrazkiv-zbroi-ta-tekhniky-z-pochatku-roku

·       Cabinet of Ministers of Ukraine — Resolution No. 345, current text: https://zakon.rada.gov.ua/laws/show/345-2015-%D0%BF

·       Ministry of Defence of Ukraine — 650 UAS codified, 22 September 2026: https://mod.gov.ua/news/minoborony-kodyfikuvalo-maizhe-650-novykh-bpak-dlia-syl-oborony-z-pochatku-roku

·       EUR-Lex — Regulation (EU) 2021/821 on dual-use export controls: https://eur-lex.europa.eu/eli/reg/2021/821/oj