UKR: Your guide to 2026 Ukrainian weapon exports

Presented by FTI Consulting

BLUF: Big changes are in store for Ukraine’s defence industry with the relaunch of exports—but first, the government has to set a new export tax, compile a list of countries eligible to procure weapons, and determine how to protect Ukrainian IP abroad.

Export of defence products in Ukraine is overseen by the State Service for Export Control. The decision-making process involves interagency consultations, with input from the Ministry of Defence and coordination within the Interagency Commission on Military-Technical Cooperation Policy and Export Control. 

The first representative offices are planned to open in Copenhagen, the capital of Denmark, and Berlin, the capital of Germany.

If this email was forwarded to you, you can subscribe here to get our emails.

This year will bring changes for Ukrainian weapons manufacturers as the country transitions to the controlled export of surplus military products.

The first export representative offices will also open in Berlin and Copenhagen. 

Oleksandr Kamyshin, chairman of the Ukrainian Council of Defence Industry, a non-governmental defence industry association, will oversee the European offices, while similar offices will later be established in the Middle East and the U.S.

The framework for this will be based on existing regulations, though some updates are already in place. 

In December 2025, President Zelenskyy appointed Yevhenii Ostrianskyi, First Deputy Secretary of the National Security and Defence Council of Ukraine, as chairman of the Interagency Commission on Military-Technical Cooperation Policy and Export Control, replacing the previous leadership. 

Under the new structure, the chairman is responsible for proposing the commission’s membership, with the final composition subject to presidential approval.

Ukrainian manufacturers will have three pathways to export products:

This refers to state-owned enterprises that have the authority to carry out international transfers of military goods, including the transfer of goods not of their own production, as well as the provision of intermediary and brokerage services.

If a manufacturer goes through a specialized exporter, there are seven to choose from in Ukraine:

Companies with export authorization can export independently, meaning they can ship their products directly once they are manufactured.

There are some nuances to take into consideration, however. The last time the Cabinet of Ministers granted such export authorization was in December 2024, Oleg Tsilvik, acting head of the State Service for Export Control (SSEC), told The Arsenal.

To obtain direct authorization, a company has to apply with the SSEC, which must then process the application within 60 days to verify documents and the manufacturer's capabilities. Then, a draft resolution for the Cabinet of Ministers has to be prepared, after which it will be reviewed by the Interagency Commission.

"We have a large backlog of applications currently pending the next commission meeting. We've also re-agreed on some ready-to-go drafts [export permit decisions] after the government change," he said.

In early January, the Defence City was officially launched, opening the way for defence companies to apply for resident status. To obtain it, a company must submit an application and supporting documents to the Ministry of Defence, which reviews the submission and, if the criteria are met, enters the company into the Defence City register. Once granted, this status allows residents to export defence products without requiring special authorization from the Cabinet of Ministers.

Through Defence City, companies that don't have export authorization and don't want to work with specialized exporters can still export— but they must have an internal export control system in place. 

This system is also required for manufacturers who opt to use independent export. The internal corporate export control system is a set of rules within the company to prevent the uncontrolled export of goods and technologies. There is no legislative requirement for companies that choose to work with a specialized exporter, as it acts as a qualified agent and operates under its own internal system. And all three export routes require registration with the State Service for Export Control. 

The application procedure for exports won't change regardless of which of the three export pathways is chosen, Tsilvik said. 

Each option involves the following process:

The recipient country provides guarantees in the form of an end-user certificate, which records the parties to the international transfer, prohibition on re-export, and procedures for post-delivery verification of end use of the exported goods.

The Ukrainian company must have a Ukrainian legal entity with a transparent ownership structure, licenses, a serial production line, and no tax issues. 

It's also important to have verified product results, combat application, and military feedback, Ihor Fedirko, CEO of the Ukrainian Council of Defence Industry, told The Arsenal.

The risk assessment of the entire international transfer chain doesn’t follow a single, universal process, Tsilvik said. Each application must be checked separately, because it’s essential to make sure Ukrainian tech does not fall into the hands of Russians. 

A variety of factors are considered: 

"Whether international intermediaries are involved, whether you're shipping through a free economic zone [where trade is subject to simplified customs controls], because that's an even greater risk. Whether there's a direct contract with the MoD of a European country that supports us in sanctions policy," Tsilvik added.

Intellectual property protection is a separate challenge, he said. If a patent was created in Ukraine, its protection must be guaranteed abroad as well. Manufacturers will need to ensure that their technologies can’t be copied abroad.

The SSEC reviews the application and consults with the Ministry of Defence, the Security Service, intelligence agencies, and other relevant authorities to assess two main points:

Then comes interagency coordination:

The commission brings together representatives of key government agencies in security, defence, foreign policy, economics, export control, and the defence industry. 

The role of the MoD and General Staff includes determining how much weaponry the army needs and what stockpiles should be created within the country.

Then, these needs are compared with enterprises' actual production capabilities. If a factory can consistently produce more than the state can purchase, this is considered surplus production.

According to Fedirko, Ukraine's weapons production potential in 2025 is estimated at $35 billion, but realistically, the state can only purchase about $13 billion worth.

During the next year, the first two export offices will open—in Berlin and Copenhagen.

Berlin was chosen as one of the primary decision-making centers, as Germany is a key European defence partner. 

Copenhagen was chosen because Denmark is a center for maritime security and is responsible for the Danish model, a mechanism for the direct funding of Ukraine’s defence industry. 

The main tasks of the representative offices, according to Fedirko, are:

Export contracts will be executed in different formats, Fedirko said. These could be between private entities, or within intergovernmental agreements. The latter is more likely for large deals or politically sensitive projects, Fedirko said.

It's important to note that the Ministry of Finance, together with other government bodies, is currently working on developing a separate tax for defence product exports. The Ukrainian Council of Defence Industry supports the decision to tax exports.

The collected funds could go towards purchasing Ukrainian weapons for Ukrainian military personnel.

The first products designated for export are maritime, ground, and aerial drones, as well as anti-tank guided missiles. According to Tsilvik and the Ukrainian Council of Defence Industry, the first export contracts are expected to be signed in the second half of 2026.

Currently, Ukrainian manufacturers are participating in exhibitions and conducting negotiations with international partners to prepare for exports. However, they still face the challenge of eliminating Chinese components from their products.

In the U.S., it won't be possible to export at all without first doing this, since there's a ban on such imports from the American side.

In addition, companies should already be preparing to meet European standards and address a range of other challenges:

Read about these challenges in our deep dive on how the defence sector will help Ukraine in its reconstruction.

We'd like to thank our friend and the former head of the State Export Control Service of Ukraine, Oleksandr Pavlichenko, for helping guide us through this complex process.