Resolution No. 875: Ukraine’s Streamlined Defence Export Framework (2026 Update)
Global Miltech Legal legal team
Experts in export control and defence law
Коротко
Resolution No. 875 simplifies the export of Ukrainian military goods by capping approval timelines at 30 days for Drone Deal partner nations and introducing a 'silence is consent' mechanism for inter-agency reviews. It allows manufacturers to monetize surplus production capacity while maintaining strict compliance with the State Export Control Service. The framework specifically supports the 'Drone Deal' initiative, facilitating international cooperation in unmanned systems and defence technologies.
As of August 2026, Cabinet of Ministers Resolution No. 875, adopted on July 1, 2026, remains the cornerstone of Ukraine's reformed defence export sector. This regulation provides a structured legal pathway for international transfers of military and dual-use goods, designed to operate throughout the duration of martial law and for six months thereafter.
Key Changes Under Resolution No. 875
- The processing period for export permit applications is strictly capped at 30 calendar days for Drone Deal partner nations.
- Permits are issued by the State Export Control Service (SSECU) with streamlined interagency clearance from the Ministry of Defence, SBU, FIS, and DIU.
- A financial threshold of 15 million UAH applies to contracts for finished products; this threshold does not apply to components or spare parts.
- Implementation of a 'silent consent' principle: if the SBU, FIS, or Ministry of Defence fails to provide an opinion within the mandated timeframe, approval is processed as positive.
- Exporters must ensure foreign counterparties are not sanctioned, nor under the control of the Russian Federation, to maintain eligibility.
Strategic Context and Market Access
The reform addresses a production surplus in the Ukrainian defence industry, particularly in drone and electronic warfare (EW) sectors, where output often exceeds domestic state procurement needs. By aligning with the 'Drone Deal' format, the government aims to foster long-term security partnerships. Current partner states include Lithuania, Latvia, the UAE, Saudi Arabia, Qatar, Azerbaijan, Denmark, the Netherlands, and Estonia, with ongoing negotiations involving approximately 20 additional countries.
Crucial legal detail: The Cabinet of Ministers database contains multiple resolutions numbered 875 (from 2021, 2022, and 2026). Parties must specifically cite Resolution No. 875 of July 1, 2026; clerical errors in documentation remain a primary cause for administrative rejection.
Strategic Recommendations for Manufacturers
While the Resolution creates significant opportunities, it does not waive fundamental compliance requirements, including SSECU registration, product codification, and screening against the quarterly updated 'List of Critical Goods.' Global Miltech Legal assesses your company’s export readiness under the new procedures and provides comprehensive support from initial documentation through to final border crossing. Contact us today for a professional case assessment.
Часті питання
Does Resolution No. 875 apply to all foreign buyers?
No. The accelerated 30-day processing window and simplified procedures are primarily targeted at partner nations associated with the 'Drone Deal' framework. Exports to other countries may still be permitted but often require additional review by the Interagency Commission.
What happens if a security agency misses the response deadline?
Under the 'silent consent' principle, if the SBU, FIS, or Ministry of Defence does not provide a formal response within the mandated timeframe, the permit approval is processed as if a positive opinion was provided.
Do I need to register with the SSECU if I only export components?
Yes. Regardless of the 15 million UAH threshold for finished products, all exporters must maintain proper registration with the State Export Control Service and comply with all dual-use and military trade regulations.
Can I export goods that are on the 'List of Critical Goods'?
As a general rule, the export of goods on the List of Critical Goods is prohibited. However, in exceptional cases, a license may be granted with the specific approval of the Interagency Commission, though the criteria for such exceptions are strictly defined and carry a higher risk of refusal.
Related services
Sources
- РБК-Україна
- ЛІГА:ЗАКОН
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