Export Duties and Fiscal Barriers: Calculating Profitability Under Resolution No. 875 (2026 Update)

The opening of export channels for the Ukrainian defence industry in 2026 marks a milestone; however, the transition to a controlled authorization model carries significant fiscal obligations. For manufacturers entering international markets, it is critical to grasp not only the procedural requirements of Cabinet of Ministers Resolution No. 875 but also the evolving economic components embedded within these new regulatory rules.

The Fiscal Architecture of Exports: What Manufacturers Must Know

The government has established clear levy rates that function effectively as export duties. These proceeds are directed to a special fund to finance internal defence needs. It is essential to understand that the base for these calculations is the value specified in the contract or in an expert assessment. If you are exporting components, a 30% rate may significantly impact your business margin, making financial modeling a mandatory precursor to signing any agreements.

Recent legislative developments in October 2026 (Draft Law No. 15400) further underscore the state's focus on these revenues. The parliament has initiated a process to ensure that 100% of fees collected for processing and issuing export control documents are allocated directly to the Ministry of Defence. This funding is split equally between the procurement/modernization of military equipment and the remuneration of service members, reinforcing the strategic importance of these levies to national security.

Risks and Optimization Strategies

The primary challenge for manufacturers remains the unpredictability of goods valuation. Using domestic defence procurement pricing as a basis for the duty may be disadvantageous if the market price for a foreign customer is significantly higher. We recommend focusing on the following aspects:

The 2026 export model is not merely a sales permit; it is a complex balance between national security and commercial viability, where every percentage point of levies must be accounted for in the business plan at the negotiation stage.

The Global Miltech Legal team specializes in the legal support of defence export operations. We will assist you in conducting a comprehensive financial risk assessment, preparing the document package for the State Export Control Service (SSECU), and ensuring your contract meets the requirements of Resolution No. 875. Contact us for a free initial case assessment to help minimize your tax risks.