Ukraine · Defence & Dual-Use
Ukraine’s Resolution No. 875: A New Framework for Controlled Defence Exports
Ukraine’s Resolution No. 875 introduces a controlled export framework for Ukrainian military and dual-use goods. We examine what changed, who can use the new procedure, and what manufacturers should verify before exporting defence-related products.
Reviewed by Oleksandr Sobovyi, Founder & CEO of CORVUS AI — editorial responsibility statement below.
Complex law. Clear action.
What changes for producers of military and dual-use goods after 1 July 2026
On 1 July 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 875 "On Certain Issues of International Transfers of Goods for the Period of the Legal Regime of Martial Law in Ukraine," approving a new Procedure for international transfers of military and dual-use goods for the duration of martial law. The instrument was published on the Government Portal, entered into force on 8 July 2026 — the date of publication — and remains in effect for the duration of martial law and six months following its termination or cancellation.
For CORVUS AI's practice, this is not a technical adjustment to the export control regime. It is a structural change to how Ukrainian producers gain access to foreign markets.
What the resolution changes in substance
A controlled, not liberalised, export model. The resolution does not open unrestricted export of military products. It establishes a controlled export regime for specific categories of military goods, dual-use goods, and technologies — the licensing procedure of the State Service for Export Control (Derzhexportcontrol) remains mandatory.
One barrier removed, not all of them. Producers that are executors of state defence contracts, or are included in the relevant register, are now permitted to export goods and technologies without separately obtaining Cabinet of Ministers authorisation under Resolution No. 838. A licence from Derzhexportcontrol is still required.
The Drone Deal mechanism. A separate regime is introduced for agreements and memoranda with foreign states concerning unmanned systems, defence technologies, and joint development or production. For states party to such arrangements, export is possible without review by the Interagency Commission, subject to specified exceptions.
Control over technology and IP, not only goods. The Procedure extends to technology transfer, including control over further assignment, re-export, third-party production based on Ukrainian technology, and a mandatory obligation to provide Ukraine with information on modifications. The export contract must set out the IP architecture: who owns the technology, precisely what is being transferred, whether modifications are permitted, who owns resulting improvements, and how further use is controlled.
Relationship to the existing framework. The Procedures for state control over international transfers of military goods (Resolution No. 1807 of 20 November 2003) and dual-use goods (Resolution No. 86 of 28 January 2004) continue to apply insofar as they do not conflict with the new Procedure. Resolution No. 875 does not replace the baseline regime — it operates as a specialised wartime layer on top of it.
Where state control is retained
The resolution's underlying logic is not deregulation for its own sake, but a managed corridor that preserves the priority of Ukraine's defence needs.
A licence may be refused where the Ministry of Defence or another state customer intends to procure the relevant goods for defence needs.
An already-issued licence may be suspended — but for no more than 30 calendar days.
A producer may submit written guarantees to secure Ukraine's defence needs as grounds for lifting a refusal.
Where refusal is based on an intended state purchase, the relevant customer must take steps to conclude a state contract within 30 calendar days; if no contract is concluded, the producer may reapply for a licence without the same ground for refusal being invoked again.
A default-approval mechanism applies: if the competent authorities fail to respond within the statutory deadline, the transfer is deemed approved.
The fee model: what to build into pricing
Alongside Resolution No. 875, amendments to the list of paid administrative services provided by Derzhexportcontrol (Resolution No. 746) introduced licensing fees:
Type of licence | Fee |
|---|---|
Export of finished (complete) military or dual-use goods | 20% of the value of the goods |
Export of components and constituent parts | 30% of the value of the goods |
Export of military or dual-use technologies | 20% of value |
Re-export to third countries of goods manufactured under transferred technologies | 20% of the value of the goods |
A separate value threshold applies: export of the relevant goods must be carried out for a sum of not less than UAH 15 million, though this restriction does not apply to components and constituent parts. How the threshold is to be calculated for framework, batch, or mixed contracts has not yet been clarified — this is the first practical question exporters will face when structuring a transaction.
The practical signal for the market
The resolution changes the underlying operating model for producers: from "we work exclusively under state order" to "we hold a validated product with the potential for international contracts." For UAVs, control systems, components, software, electronic warfare solutions, and other dual-use technologies, export becomes a tool for scaling and attracting investment — but only for those prepared for full export compliance, including end-use chain traceability.
Drone Deal, in this context, is not a mechanism for one-off export of finished products. It is a framework for joint production, localisation, and technology exchange with the circle of states with which defence-technology cooperation is deemed strategically acceptable.
What remains unresolved
At the time of writing, a number of implementing acts required for the Procedure to function fully have not yet been adopted, and several practical questions remain open — in particular, the methodology for calculating the UAH 15 million threshold on mixed contracts, and how the licence fee applies where a licence is suspended. The regime's effectiveness will be determined by the enforcement practice of Derzhexportcontrol and the Interagency Commission, not by the text of the resolution alone.
CORVUS AI recommendations
For producers of military and dual-use goods intending to use the new regime, we recommend at this stage:
Audit eligibility status — confirm the grounds for exemption from Cabinet of Ministers authorisation under Resolution No. 838 (status as executor of a state defence contract, or inclusion in the relevant register).
Price in the licence fee (20–30% of value) at the contract structuring stage, not after the fact.
Structure the IP architecture of the export contract before filing the application — allocation of technology rights, the modification regime, and re-export control must be documented in advance.
Assess the applicability of the Drone Deal mechanism as an alternative to the standard procedure when working with partner states.
Factor in the risk of a 30-day licence suspension when planning delivery schedules and contract logistics.
CORVUS AI advises on compliance assessment under Resolution No. 875, structuring of export contracts, and engagement with Derzhexportcontrol for Ukrainian producers of UAVs, electronic warfare systems, and other dual-use technologies.
What matters. What’s next.
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.
Sources
Resolution of the Cabinet of Ministers of Ukraine of 01.07.2026 No. 875 "On Certain Issues of International Transfers of Goods for the Period of the Legal Regime of Martial Law in Ukraine" — zakon.rada.gov.ua
Povelko, A. "Controlled Export for Defence Tech: What Resolution No. 875 Actually Changes" — column for AIN.UA, 15.07.2026 — ain.ua
"Licence for Export of Finished Military or Dual-Use Goods to Cost 20% of Their Value" — LexInform, 08.07.2026 — lexinform.com.ua
"Ukraine Opens Controlled Export of Defence Products: What Resolution No. 875 Changes" — PRAVO.UA — pravo.ua
"Export Control in Ukraine Will Operate Under New Rules" — ANTIRAID, citing "Yurydychna Gazeta" — antiraid.com.ua
Editorial note: the baseline procedures for state control over international transfers of military goods (Resolution No. 1807 of 20.11.2003) and dual-use goods (Resolution No. 86 of 28.01.2004) remain in force insofar as they do not conflict with Resolution No. 875, and are referenced here as the existing backdrop to the new regime.
