The Ukrainian government has simplified the procedure for obtaining permits and conclusions for international transfers of military and dual-use goods under international treaties with Ukraine.
The relevant changes were introduced by Resolution of the Cabinet of Ministers of Ukraine No. 6, dated 7 January 2026, and come into effect immediately from January 2026.
When does the simplified procedure apply?
The simplified procedure applies where an international transfer of goods is carried out on the basis of an international treaty with Ukraine that expressly provides for such a transfer, and specifies:
- the goods to be transferred;
- the exporters, importers, intermediaries and end users of the goods; and
- undertakings regarding the end use of the goods.
What are the benefits of the simplified procedure?
Under the new procedure the core export control examination is conducted at the stage of drafting the given international treaty with Ukraine for the respective goods. In turn, the timeline for obtaining permits or conclusions for specific international goods transfers is limited to 15 days.
How does the simplified procedure work?
Step 1. Approval of draft international treaty
A draft international treaty is subject to prior approval by the State Export Control Service of Ukraine (“SECSU”). Once the given draft is approved, its key provisions, including those relating to the respective goods, exporters, end users, end use or guarantees, may be amended only with the SECSU’s approval.
Step 2. Entry into force of international treaty
Upon review of the given draft international treaty, the SECSU informs the applicable treaty-initiating entity (e.g. the Ukrainian government) whether the document complies with Ukrainian export control requirements. Upon being deemed compliant, the treaty will allow permits or approvals for specific international transfers of goods to be issued through a simplified procedure.
Step 3. Entering into foreign economic contract
Following the entry into force of the respective international treaty, the designated company enters into a foreign economic contract for the execution of said international treaty. A copy of the foreign economic contract must be certified by the treaty-initiating entity.
Step 4. Submission of documents for permits or conclusions
To obtain a permit or conclusion for a specific international transfer under an international treaty, the following documents must be submitted to the SECSU:
- an application for obtaining a permit or conclusion (in statutory form);
- a copy of the foreign economic contract concluded for the execution of the given international treaty, certified by the treaty-initiating entity;
- guarantee documents, if such guarantees are not provided for by the international treaty; and
- a copy of the respective international treaty.
NOTE: The necessary documents must be submitted via the user’s account in the Export Control Information and Communication System available on the official website of the SECSU.
Timeline: 15 calendar days from the date of receipt of the set of documents by SECSU.
The introduction of the simplified procedure does not negate the obligation for companies to undergo state registration as entities authorised to carry out international transfers, in accordance with applicable statutory procedures.
Practical impact
The new framework enables Ukrainian companies to obtain authorising documents for international transfers of military and dual-use goods more quickly and with a reduced administrative burden. The principal export control assessment is now carried out at the stage of the drafting of the respective international treaty rather than during the review of each company’s permit application. The accompanying international treaties are expected to be concluded in the near future.
- Daniel Bilak, Partner, Defence & Security, daniel.bilak@kinstellar.com
- Larysa Gorbunova, Senior Associate, larysa.gorbunova@kinstellar.com
- Varvara Oprysko, Junior Associate, varvara.oprysko@kinstellar.com
For more information on the import/export of military and dual-use goods, please contact Daniel Bilak, Partner, Defence &Security, at daniel.bilak@kinstellar.com.
