What conditions apply to the simplified procedure, which authorities process the documents, how much the permit costs, and what to pay attention to before signing a contract with a foreign buyer.

On 1 July 2026, the Cabinet of Ministers adopted Resolution No. 875. It approved a separate procedure for international transfers of military and dual-use goods during martial law. The resolution entered into force on 8 July 2026. Its purpose is to accelerate exports, but at the same time it introduced a substantial fee for the permit. Let us examine how the procedure works and where companies most often face risks.

Conditions for the simplified procedure

The new procedure applies if the following conditions are met simultaneously:

• the goods have been accepted into service or codified by the Ministry of Defense as a supply item;

• the value of exports of finished products is not less than UAH 15 million (there is no such threshold for components);

• the buyer’s country has an agreement with Ukraine in the field of unmanned systems or other defense products (the “Drone Deal” agreement) and is included in the list approved by the Ministry of Foreign Affairs;

• the goods are not included in the list of critical goods approved by the Ministry of Defense.

For Ukrainian manufacturers, there is another change: Resolution No. 838 exempts from a separate authorization to export those who perform state defense contracts or are included in the register of selection participants. Registration with the State Export Control Service and a permit for a specific transfer remain mandatory.

Authorities and time limits

The application is submitted to the State Export Control Service together with a package of documents and proof of payment of the fee. The State Export Control Service makes a decision within 30 calendar days. During this period, the documents are approved by:

• the Ministry of Defense: 20 days (10 days for technologies);

• the Security Service of Ukraine, the Foreign Intelligence Service, and the intelligence body of the Ministry of Defense: 15 days each;

• state defense procurement authorities, upon request of the Ministry of Defense: 15 days.

If an authority does not respond within the prescribed period, the transfer is deemed approved by default. The Interagency Commission considers the application only in cases expressly provided for by the procedure, in particular where there is no “Drone Deal” agreement with the buyer’s state or the goods are included in the list of critical goods.

Risk of refusal and guarantees for the state

Among the grounds for refusal is the intention of the Ministry of Defense or another state customer to purchase the same goods for the needs of Ukraine. This ground may be removed by providing written guarantees of supply for the defense needs of Ukraine. If the refusal was issued due to such a purchase, the state customer has 30 days to conclude a contract. If the contract is not concluded, the company may submit the application again.

In addition, refusal may be issued for inaccurate information, sanctions against participants in the transfer, absence of a document on the guarantee of the importing state, or the company’s failure to perform state contracts.

If the permit has already been issued, the intention to purchase may become grounds for suspending it for up to 30 days.

How much the permit costs

The fee is calculated based on the value of the goods:

• finished military or dual-use products: 20%;

• components: 30%;

• technologies: 20%;

• re-export of goods manufactured using transferred technologies: 20%.

The fee is paid before submitting the application, that is, before the decision is made. Resolution No. 875 does not provide for a refund of the fee in the event of refusal, and Resolution No. 746 expressly states that the fee for unused documents is non-refundable. Therefore, this amount should be taken into account in the contract price and in the conditions for its entry into force.

What to check before submission

• whether the company is registered with the State Export Control Service;

• whether the goods are included in the Ministry of Defense list and whether the export reaches UAH 15 million;

• whether the buyer is included in the list of states and whether the “Drone Deal” agreement has been concluded;

• whether the goods are not included in the list of critical goods;

• whether the document on the guarantee of the importing state is ready;

• whether the buyer has been checked for sanctions and ties to the aggressor state;

• whether the 20% or 30% fee has been included in the contract price;

• whether the contract enters into force only after the permit is obtained.

Legal support

Digilaw supports defense companies from assessing the export procedure to submitting the application, structuring the contract, and obtaining guarantees for the state. If your company has found a foreign buyer, start with a legal assessment: it will show which route the application will take and how much it will cost.

Contacts:

Email: hello@digilaw.pro

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