Ukraine: Controlled export of weapons from Ukraine - Procedure at the final approval stage

In brief

Since September 2024, discussions intensified on the permitting of weapons exports from Ukraine, which have been effectively prohibited since early 2022. It is anticipated that the National Security and Defense Council of Ukraine (NSDC) will present its concept on both export and joint production with partner countries initially internally in December 2025, and then at the investment forum planned to be held early 2026 in one of the European capitals.

Ukraine is already in the process of establishing two export hubs in Copenhagen and Berlin, respectively, to facilitate the international arms trade. Additional offices are expected to be opened in the US and the countries of the Global South.


Expected launch and timeline

The first export contracts are expected to be made in the second half of 2026. This timeline is reflective of the needs for product testing, certification and foreign partners’ procurement procedures. With over 1,000 defense companies operating in Ukraine, fewer than half are currently ready to engage in arms exports due to the requirements to undergo technical verification and to obtain the necessary permits.

Export products

Ukrainian unmanned systems — air, land and maritime — are expected to be the first products to be offered to the international market. Under the current plan, partners may invest in weapons production within Ukraine or establish joint manufacturing facilities in their own jurisdictions.

Financial outlook

According to the NSDC estimates, in 2025 Ukraine’s defense industry could have produced defense products worth up to USD 35 billion, while public finances enable the procurement of no more than half of this volume. In 2026, the sector’s output may potentially reach USD 60 billion. With the view to ensuring the optimal utilization of production capacity and given the limitations posed by finite public finances, a portion of extra capacity may be taken up by permitting the controlled exports to friendly nations. This approach may help facilitate a greater rate of utilization of production capacities, preserve jobs and attract foreign currency revenue into the defense sector.

Permitted export destinations

The NSDC is responsible for determining the list of countries eligible to procure Ukrainian weapons. This list will include states with which Ukraine has concluded security agreements. As of November 2025, Ukraine has signed 28 bilateral security agreements with partner countries and the European Union, including the United Kingdom, Germany, France, Denmark, Canada, Italy, the Netherlands, Finland, Latvia, Spain, Belgium, Portugal, Sweden, Iceland, Norway, Japan, the United States, Estonia, Lithuania, Poland, Luxembourg, Romania, the Czech Republic, Slovenia, Ireland, Greece and Albania. Post-export controls will be implemented to prevent unauthorized resale without Ukraine’s consent.

Eligibility of exporting companies

According to the NSDC's concept, the procedure for granting export rights to companies is intended to be straightforward and transparent. Any company that meets the established eligibility criteria and possesses surplus production capacity not required by the Ukrainian security and defense forces may apply for an export permit by the State Export Control Service (SECS).

Export procedure

The SECS will verify all submitted data and issue the relevant permit within 90 days. In determining surplus production capacity, the SECS will conduct an interdepartmental inquiry, including with the Ministry of Defense consolidating the needs of the armed forces. Decisions and recommendations will then be made by the Interdepartmental Commission on Military-Technical Cooperation and Export Control Policy, with the involvement of all security and defense agencies. Once approved by the commission, the export permit will be issued, ensuring a two-stage process — technical and security review.

Private manufacturers may export weapons via state or private special exporters, or directly once the necessary authorization are procured. For residents of the Defence City, a special virtual zone offering a set of tax and legal benefits, there will be a “fast track” procedure permitting the procuring of the requires authorization within seven (7) to twelve (12) days under a “one-stop shop” principle to minimize the bureaucratic barriers.

While no immediate action is required, it is recommended that businesses monitor legislative developments and the potential impact of the planned export launch. If you have any questions or would like to discuss how this proposal may affect your investment planning, please contact us.

Ukrainian version

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​Mariia Tashchi, Associate, has contributed to this legal update.


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