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JV Abroad: How a Ukrainian Defense Company Gets From an MoU to Serial Production

Ukrainian defense companies announced 41 production joint ventures abroad in 2026, yet only six of the 51 known deals are in serial production. What a JV means in practice, what Resolution 875 allows with technology, how to protect the IP and what to model before the MoU.

10 min read
Artur Fedorenko

Author

Artur Fedorenko, Founder & CEO, Wiseboard.

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The memorandum gets signed in one evening at a trade show: photos, handshakes, a press release about a joint venture. Then comes the part the press release leaves out. Where to register the company, who puts in the money and the equipment, which drawings and software may leave Ukraine, what the product will cost Ukraine's Ministry of Defence if it is assembled in Denmark, and who earns from it. Most deals stop on these questions.

The numbers

How many JVs abroad reach serial production

We track Ukrainian defense companies' co-production deals from public announcements. As of 30 September 2026 the tracker holds 51 outbound deals: a Ukrainian design that is made, or is planned to be made, abroad.

51
outbound deals tracked
41
announced in 2026
22
at the MoU or LOI stage
6
in serial production

Source: Wiseboard Defense tracker, public announcements, as of 30.09.2026. Another 20 deals are signed with production not yet started. In 2025, 7 such deals were announced.

Private Ukrainian companies signed 48 of the 51. The most frequent partner countries are Germany (13), the US (9), Finland (6), and Poland and Denmark (5 each). By segment, unmanned ground vehicles and reconnaissance drones lead with 11 deals each, followed by FPV (8) and long-range systems (7).

Independent research shows the same picture. In its “Beyond Aid” report (September 2026), KSE Institute counted at least 180 B2B partnerships between Ukrainian and foreign defense companies, and 22% of them had stalled, most at the MoU stage. Partnerships with private Ukrainian companies are active in 96% of cases, against 62% for state-owned enterprises. The authors recommend bringing in experienced advisers before signing.

The form

What a defense JV means in practice

Press releases use “JV” for very different set-ups. Which one sits behind your deal decides the permits, the tax and the control over the technology.

Joint venture (JV)
In the legal sense, a separate organizational and legal form of joint activity that most jurisdictions regulate tightly. In the defense market, “JV” covers any joint business between a Ukrainian company and a foreign partner: a joint company, licensed production on the partner's line, or a subsidiary with the partner in the capital.
In the legal sense, a joint venture is a special organizational and legal form, regulated to the point of impossibility, so it is global players at the level of Rheinmetall who go into a classic JV. Everyone else sets up joint companies: an OÜ in Estonia, an LLC in Ukraine, a C-Corp or LLC in the US, an LTD in the UK. The cases differ as much as you can imagine, so we build the structure around the specific inputs every time.
Yurii Kornaga · Legal Partner · Axon Partners

Three set-ups come up in practice.

  • A joint company in the partner's country. Both sides become shareholders; the company takes a production licence and sells to the local customer or supplies Ukraine.
  • Assembly on the partner's line. The partner has a production line, and the Ukrainian side hands over the specification, documentation and software. Even with no joint company, technology leaves Ukraine, and that needs a permit.
  • A subsidiary with the partner in the capital. Control stays with the Ukrainian side, and the partner comes in with money, space or access to the customer.

This article follows one outbound deal from the MoU to the first production run. For the reverse direction, a foreign company producing inside Ukraine, see JV or contract manufacturing in Ukraine.

Permits

What Resolution 875 changed for technology transfer

Since 8 July 2026, the procedure approved by Cabinet of Ministers Resolution 875 of 1 July has been in force. It sets the timelines and fees for exporting products, components and technologies, which is everything that moves to a production site abroad.

Resolution 875 for a JV: the key parameters (as of 22.10.2026)
Fee20% on finished products and technologies; 30% on components; 20% on re-export to third countries of products made under Ukrainian technology.
When it is paidWith the application, before the decision.
Minimum contract valueUAH 15 million; the threshold does not apply to components.
Review timeUp to 30 calendar days. The Ministry of Defence signs off within 20 days, or 10 for technologies; with no answer, the transfer counts as approved.
Where toStates on the Ministry of Foreign Affairs list, updated quarterly. Applications for Drone Deal states skip the interagency commission; the rest go through it.
IP rightsThe importing state guarantees the technology is used without alienating the intellectual property rights. Any onward transfer needs prior written permission from the State Service for Export Control.
Selling the technologyThe alienation of exclusive IP rights or a sale of technologies goes to the interagency commission.

The practical conclusion for a JV: the joint company gets a licence to the technology, and the rights stay with the Ukrainian company. A sale of the technology or a transfer of exclusive rights sends the deal straight to the commission.

The Drone Deal circle keeps growing: Norway became the tenth state on 24 August 2026 and Finland the eleventh on 24 September. According to Ukraine's National Security and Defense Council, more than 20 applications to export finished products had been approved under the new procedure by 16 October. The list changes, so check it on the Council's website before filing. The mechanism and the application filters are covered in the export fast-track and Drone Deal explainer.

Putting money into a foreign structure is a separate track. KSE describes a case where a EUR 20 million capital contribution to a company in Denmark needed its own Cabinet resolution and an individual permit from the National Bank of Ukraine. If the Ukrainian side contributes capital as well as technology, that track is planned from day one.

IP

How to protect the IP in a joint company

Resolution 875 settles the question on the importing state's side. Most IP risk arises inside the structure itself: which shareholders have access to technical information, and on what basis.

In most cases the IP is held by the Ukrainian company. When we let outside shareholders in, there has to be a Chinese wall between them and the information about the IP. Otherwise the export-control conditions are breached automatically, through access, even if it is only formal.
Yurii Kornaga · Legal Partner · Axon Partners
  • The rights stay with the Ukrainian company. The joint company takes a licence with defined limits: product, territory, term, the right to modify.
  • Non-resident shareholders' access is limited in the company documents.The charter, the shareholders' agreement and the licence set who sees the technical documentation; an NDA does not replace them.
  • Improvements have an owner. Who owns the improvements made on the foreign line is fixed before the first file is handed over.
  • The exit scenario is written in advance. What happens to the licence and the documentation if the partner leaves or the deal stops.

The legal risk map for a defense-tech company puts export control first, with the trigger defined as uncontrolled transfer of goods, code, data or access.

The economics

What to model before signing the MoU

A JV's economics are usually worked out after the sides have agreed in public, when the terms are hard to change. If the JV will produce for supplies to Ukraine, one number matters most: how much the unit cost rises. Ukraine's Ministry of Defence is a price-sensitive customer, and the uplift from moving production has to be known before the negotiation.

Inputs

  • the country's local-content requirement;
  • space: your own, the partner's, or new;
  • people: already on site, or to be hired and trained;
  • logistics for components from Ukraine and on site;
  • who finances the infrastructure;
  • what the partner brings: money, a line, access to the customer.

What the model shows

  • how much the unit cost rises against production in Ukraine;
  • who contributes what, and the stake each side gets for it;
  • how the Ukrainian side earns: royalties on the licence or dividends;
  • the tax on taking profit out in the jurisdictions you are considering: the EU, the UK, Canada, the US, Saudi Arabia;
  • the Resolution 875 fee, and whether the country is in the Drone Deal;
  • the profitability of each configuration, so countries are compared on the same numbers.

How the model turns into a deal structure, permits and a launch is described on the service page JV abroad: strategy and the numbers.

The sequence

Six stages from the MoU to the first run

  1. 1Product and company diagnostic. Pin down exactly what leaves Ukraine: the product, components, documentation, software, staff training. The permits and the structure follow from it. The readiness diagnostic covers this step.
  2. 2Country and model. Compare two or three countries on the same numbers: unit cost, tax, access to the customer, Drone Deal membership.
  3. 3Partner and money checks.KYC in both directions: where the partner's capital comes from, and where the Ukrainian company's own investors' capital comes from. Money with a poor reputation or ties to public officials can put off a European partner or a ministry.
  4. 4Structure and IP. Where the company is registered, who the shareholders are, how the technology is licensed, how access to the IP is limited, and what happens if one side exits.
  5. 5Permits and the counterpart request.The Resolution 875 application, the Ministry of Defence sign-off and, where needed, a National Bank permit to move capital abroad. In parallel the partner arranges a request from its own defense ministry: a buyer state asking Ukraine's Ministry of Defence about a specific manufacturer carries weight no applicant's document can.
  6. 6Site financing and the first run.Host-country money, European instruments, an order for the first batch. To an investor, a JV counts once it produces cash flow: a signed deal with no production does not raise the company's valuation.
Countries

How to choose the country for a JV

The EU.Companies that see Europe as their main market most often start with an Estonian OÜ that becomes the owner of the Ukrainian company. Registering directly in Denmark, Germany or another more tightly regulated country makes sense once there is a guaranteed partnership with that country's government. How such a structure works is explained in the cross-border holding, explained.

European money for joint procurement comes through the SAFE regulation: up to EUR 150 billion in loans to member states, in force since 28 May 2025, with Ukraine able to take part in joint procurement. The loans go to states, so the financing conversation happens with the partner country's government.

The US. The hardest route. If the company is funded by American investors, a Delaware C-Corp is usually required, and foreign ownership of a defense contractor goes through a foreign ownership, control or influence (FOCI) review. US export control (ITAR, EAR) covers the US only, so Canada or Latin America need a structure of their own.

Canada, the UK, the Gulf.Each country needs its own model. The tax on taking profit out and the local-content requirement change the economics the most, so countries are best compared on a specific product's numbers.

FAQ

Frequent questions

Primary sources

Published: 23 October 2026

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TagsScaleJoint VenturesExport ControlResolution 875Drone DealIP
JV abroad

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