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The New Defence-Tech Export: Fast-Track, Drone Deal & the 3 Filters That Decide It

On 1 July 2026 a fast-track appeared for exporting defence and dual-use goods. Here it is without the myths: what actually changed, who clears the three filters (WHO · WHERE · WHAT), what it costs (20%/30%), why applications are refused — and what to do now so you don’t lose the contract.

15 min read

Produced in partnership with Juscutum.

Petro Bilyk, Partner, AI & Technology practice.

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On 1 July 2026 Ukraine’s Cabinet adopted a new procedure for exporting defence and dual-use goods — the so-called fast-track (Resolution No. 875, in force from 8 July). The market split into two camps at once: “exports are finally open” and “nobody understands anything”. Both are wrong. Here is what actually changed, who clears the new filters — and what to do today so a real business opening doesn’t break on the preparatory steps.

Key parameters of the new procedure
InstrumentCabinet of Ministers Resolution No. 875 of 1 July 2026 (fast-track)
In force from8 July 2026 (adopted 1 July)
Application reviewup to 30 calendar days
Fee20% goods · 30% components · 20% technology to third countries
Minimum contract valuefrom UAH 15M (≈ €293K); doesn’t apply to components
Country list (Drone Deal)9 signed + ~20 in progress; updated quarterly
Regime durationmartial law + 6 months after it ends
Market read

What actually changed — and what didn’t

First, the context that dissolves half the panic. Ukraine didn’t invent arms-export procedure in 2026, and it wasn’t dreamt up during the war — it has existed since independence. Before the full-scale invasion Ukraine was one of the world’s top-12 exporters of defence-purpose products. For the duration of the war a political decision simply held: almost everything produced goes to the defence forces.

What actually happened on 1 July: the state simplified specific steps of getting a permit and tried to close a few problem spots. But the control regime itself did not disappear. So the most common assumptions are worth checking against reality up front.

What everyone assumesHow it actually is
“Exports are open”Control stayed — new filters were added
“The process was simplified”Only specific steps; the law over them didn’t change
“You can go to market quickly”Not without registration and a certified export-control unit
“Critical goods can’t be exported”They can — via the interagency commission, with refusal risk
“Only a few countries are allowed”The number of countries isn’t capped; Drone Deal only simplifies the procedure

Based on the Juscutum webinar · “Myth vs reality” slide

The numbers

How many permits are actually issued

The best answer to “does this even work?” is the data. The interagency commission was blocked and only resumed work in February 2026. In under half a year — before the new procedure — it managed the following (NSDC figures):

0
commission sittings
0
subjects granted authority
0
permits issued · 92%
0
refusals · 8%

Source: NSDC, results of the interagency commission since February 2026. Permits: goods 214 · services 122 · technology 6.

Two conclusions. First: permits are in fact issued — and not only for goods, but for services (development, modification, engineering) and technology. If you transfer technical data to a foreign party or provide an engineering service, you need an export permit too — and it’s granted. Second: 8% of applications were refused. The door is open, but selectively — and on Juscutum’s read, a large part of the market risks failing the new filters without preparation.

The filter system

The three filters every application passes through

This is the core of the new procedure. Any application to export military-purpose goods runs through three mandatory filters. Clear all three on the simplified terms and you take the short path. Trip on even one and the application goes to the interagency commission.

Filter 1
WHO

Who exports

A manufacturer of the product, or a state-contract performer, or a member of the relevant registry.

Filter 2
WHERE

Where to

Designated partner states (Drone Deal) — or interagency-commission clearance for other countries.

Filter 3
WHAT

What you export

The product must not be on the critical-goods list — otherwise commission clearance is required again.

Filter 1 — WHO: and why it’s fast-track’s biggest advantage

The longest step used to be obtaining Cabinet of Ministers authorization. In practice it took three to six months, sometimes longer. The new procedure carves out an exemption. If you’re a manufacturer of the product and at the same time a performer of a state defense contract (or included on the registry of selection participants and state-contract performers), you don’t need Cabinet authorization. You apply for the permit directly.

Filter 2 · WHERE

Drone Deal: where you can export

Drone Deal
It’s not about drones, and the name isn’t a list of countries. Drone Deal refers to the general international security-and-cooperation agreements between states. If the importing country is on that list, you drop one step of the process — interagency-commission clearance.

Publicly announced: 9 signed agreements, with around 20 more states in the pipeline (NSDC data). The list of partner states is compiled by the Ministry of Foreign Affairs — with input from the Ministry of Defence, the SBU, foreign intelligence and defence intelligence — and updated quarterly.

  • Gulf: Qatar, UAE, Saudi Arabia, Azerbaijan
  • Europe: Latvia, Lithuania, Estonia, the Netherlands, Denmark
  • + around 20 states in the process of signing

Important: the number of countries is not capped. Want to export to Canada or Latin America? You can — but then the application goes to the interagency commission. The export-control service separately publishes a list of countries to which export is allowed in general (it includes even offshore Panama, but not China). As of the date of this piece (17 July 2026) the specific Drone Deal list had not yet been published — it was expected within 14 days of the rules taking effect, roughly by the end of July. So before a deal, check the current list on the MFA and export-control service sites.

Filter 3 — WHAT: the critical-goods list

Critical goods
Goods whose export could threaten defence capability and national security. The list is compiled by the Ministry of Defence (with input from the interior ministry, SBU, foreign intelligence, the General Staff and defence intelligence) and updated quarterly.
  • Product not critical → standard procedure, no interagency commission.
  • Product critical → export is still possible, but via the commission and with a high refusal risk.
The financial model

What it costs: the 20% / 30% fee and the “pay upfront” trap

The number to build into the financial model before you even talk to a buyer. The fee is calculated off the prices paid by state defence customers. If there were no comparable procurements in the past 6 months, you need a court-expert opinion or a property-valuation report (valid for 6 months). And not every valuer is cleared to work with military goods — sort that out early.

20%
goods manufacturers
30%
components manufacturers
20%
technology to third countries

The biggest trap is when you pay. Proof of the fee is filed together with the application: without it, the service won’t accept your documents for review. So on a UAH 15M contract you pay ≈UAH 3M upfront, whether or not you get the permit. Either you agree with the foreign partner to cover that part, or you split the risk in some proportion — but it has to be priced in before signing. Work out your fee:

Fee calculator
Fee payable
3,000,000UAH
58,594

Estimate. Proof of payment is filed with the application — before the export-control service decides.

Timeline

How long it takes: “up to 30 days” with a big “if”

Yes, fast-track cuts application review from the previous 45–90 days to 30 calendar days. But that clock runs only from the moment you file — and to file, you already have to be registered with the export-control service and hold a certified internal unit. Here’s the full timeline.

1

Register with the service

now

As a subject of international transfers. Done before you file.

2

Certify the internal unit

now

Build and formally certify your export-control service.

3

Preliminary review

up to 30 days

Product identification; can be extended.

4

Cabinet authorization

up to 40 days

Only if needed. Manufacturer + state contract = exempt.

5

Export permit

up to 30 days

The new procedure. Plus “silent approval”.

Adapted from the “Timeline” slide. In practice the preparatory steps add another 1 to 3+ months.

Silent approval
Your documents go through clearance by the security services (SBU, foreign intelligence, defence intelligence). If an agency doesn’t respond within the set period, it counts as approval by default and you move on.

Hence the speaker’s main advice: start the preparatory steps now, in parallel with negotiations — not after. The classic mistake is to agree an export deal with a foreign counterparty and then get stuck for half a year on registration and certification. The deal simply falls apart in the meantime.

Case · how it should work

A drone manufacturer that is a state-contract performer wants to sign a UAH 25M export contract. The importing country is on the Drone Deal list, the product isn’t on the critical list, and the company is already registered with the service and holds a certified internal unit.

  • Cabinet authorization — not needed (exempt)
  • Interagency commission — not needed (Drone Deal + non-critical product)
  • Review time — up to 30 days
Counterparty & guarantees

Importer guarantees and counterparty requirements

Before filing you have to vet the counterparty and obtain guarantees from the importing state. This isn’t a formality: a counterparty mismatch is independent grounds for refusal, and false information will be caught by the security services during clearance. The adversary tries to reach technology even through foreign companies and funds — so run compliance at the first step, not after signing.

The foreign importer must NOT

  • be under sanctions (the Sanctions Act) — including among founders, beneficiaries or directors;
  • be linked to terrorism or fall under anti-money-laundering law;
  • be under the direct or indirect control of the aggressor state, or have its citizens among owners or directors;
  • hold corporate rights in a legal entity registered in the aggressor or occupier state (even a subsidiary there is a risk).

What the importer’s guarantee must confirm

  1. 1The right to use the technology without transferring IP rights or reselling to third parties.
  2. 2Mandatory prior written permission from the service for any re-export, sale or temporary removal.
  3. 3Production strictly within the volumes agreed in the contract.
  4. 4An obligation to pass Ukraine information about any modifications or improvements to the goods.
Risks

Why applications are refused — and suspension vs revocation

The six most common grounds for refusal:

  • inaccurate or incomplete information, errors in the application, an incomplete document set;
  • a mismatch of the foreign party (sanctions, ties to the aggressor state);
  • sanctions on any participant in the transfer — and that’s broader than just a Russia link;
  • a missing guarantee document from the importing state;
  • a state-customer intent to buy the product — the state has the priority right;
  • a critical product, or the subject’s failure to meet obligations under defence contracts.

After a permit is issued it can still be suspended or revoked — and the difference matters. Suspension (up to 30 days) is for failure to perform state contracts, non-payment or a state-customer intent; once the cause is removed, the permit can be reinstated. Revocation is for inaccurate information, sanctions, breach of supply guarantees for the Armed Forces or unsanctioned re-export; that’s a loss of the ability to export. Both are worth minimizing through contract terms up front.

6 typical mistakes that cost the contract

  • transferring a product or technology without assessing it against the military / dual-use list;
  • not checking whether the product is critical before signing;
  • not building the rules into the contract (guarantees, re-export limits, payments);
  • not counting the 20%/30% — and the contract turns loss-making after signing;
  • not accounting for state needs — no written supply guarantees for the Armed Forces;
  • not vetting the buyer — sanctions status and Russia ties stay unknown until the deal is signed.
Self-check

Are you ready to export: the 10-step algorithm

A practical way to check yourself in two minutes. This is the same readiness algorithm from the Juscutum slide: every item you can’t tick is a “STOP” before you file. Check what’s already done — and you’ll see your real readiness and the next steps.

Interactive checklist
Are you ready to export?
0/10
ready
Check the boxes you've already cleared — and see what's left before you file.

Clear the filters on the first try.

Alternatives

Fast-track isn’t the only path

The new procedure doesn’t cancel the others. The manufacturer chooses the path — by country, product, value and timing. There are three alternatives.

  • The general regime — the standard procedure for those who don’t qualify for the simplification (with Cabinet authorization and the interagency commission). It isn’t repealed and is always available.
  • Defense City — residents don’t need Cabinet authorization, plus the regime’s tax benefits.
  • Resolution No. 6 (of 7 January 2026) — a separate procedure for performing international treaties (for example, in the Build with Ukraine logic), with its own simplifications.
Action plan

What to do right now

While the market waits for the official country and critical-goods lists (roughly by the end of July), there are five steps that don’t depend on the date of your first export — and that will decide whether you make the opening or not.

  1. 1Identify the product. Classify the good / technology by nomenclature: military or dual-use.
  2. 2Register with the export-control service as a subject of international transfers — no application is accepted without it.
  3. 3Build and certify the internal export-control unit — regardless of when you plan to export.
  4. 4Protect the technology — register copyright or a patent, put the IP on the company before negotiations start.
  5. 5Vet partners — sanctions lists, ties to the aggressor state, ownership structure — before signing anything.

The new fast-track isn’t “exports are open” — it’s a new, harder window of opportunity with higher liability. The ones who win are those who prepare the documents, the structure and the contract in advance, in parallel with negotiations. That preparatory layer is exactly what Wiseboard Defense builds for Ukrainian defence-tech companies: from product identification to the permit, with the structure and certificates the buyer and the investor will later want to see.

FAQ

Frequent questions

Sources & disclaimer

Produced in partnership with Juscutum. Petro Bilyk, Partner, AI & Technology practice. This article is informational and not legal advice. The regulatory lists (Drone Deal countries, critical goods) update quarterly — verify against the primary sources from SSECU, the MFA and the Ministry of Defence, and get individual advice before signing contracts.

Published: 17 July 2026

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TagsExport controlFast-trackDrone DealSSECUDefence goodsDefense City
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