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On 8 July, Ukraine loosened its defense-technology export controls through Cabinet of Ministers Resolution No. 875, reopening a channel that had been effectively frozen since early 2022. The headline is the permit fee: 20% of a finished system's value to export it, 30% on components.
Since the Ukrainian government sets the valuation of the technology the fee is charged on, using the price the Ukrainian military pays, an exporter often can't price the fee before signing.
That combination of a steep charge on a state-controlled price drives the economics of every deal and signals the premium that Kyiv puts on combat-proven technology.
Why now
For 3 years Ukraine ran a closed war economy: push as much kit as possible to its own front, and ship almost nothing to foreign buyers not at war themselves. Resolution No. 875 arrives as supply and demand move together.
Ukraine's defense output is heading for $50 billion or more this year, while the state can buy only about $13 billion of it. That surplus has to go somewhere, and demand for combat-proven systems is climbing abroad, pushed by conflict in the Middle East and a US drive to scale up drone forces. Buyers want a proven record, and no other supplier's is as current or as deep as Ukraine's.
Opening exports brings in hard currency. It also keeps factory lines running at full volume, which domestic orders alone couldn't support once the front is stocked. And because every sale runs through a government-to-government deal, it lets Kyiv trade access to its systems for what it wants from partner governments.
Classification
Ukraine now runs two permit tracks. The standing regime carries a flat fee near $75 (UAH 3,400) and covers routine dual-use trade.
No. 875 is the wartime track, and it engages when the exported item can feed a military product already codified into service by the Ministry of Defence. The trigger sits with the end use and the customer, so the same component can fall under either regime depending on destination.
Classification, the call on what the goods are under Ukraine's control lists and which of the two regimes they trigger, is therefore the first decision in any transaction and the costliest to misjudge. It separates a $75 permit from a fee worth a fifth to a third of contract value, and it turns on the end use, a fact about the buyer that the seller may not control.
Anyone who knows US export control will find this familiar. It's the same threshold question as ITAR versus EAR: whether an item sits on the US Munitions List or the Commerce Control List decides which rule applies, and how heavy the burden is. Ukraine's two tracks pose the same kind of call, and it's just as costly to get wrong.
Mechanics
The fee. 20% on finished goods and technologies, 30% on components, filed with the application and non-refundable on denial.
A finished good is a complete, deployable system, like a whole drone or an electronic-warfare unit. Technologies are the designs and know-how to build or run one. Components are the parts inside: flight controllers, motors, seekers, antennas.
The higher rate on parts is deliberate. It keeps Ukraine's components at home and pushes finished systems out the door.
Ukraine sets the value. The 20 to 30% is charged on a value the Ukrainian government sets, the price its own military pays for similar gear, which can differ from your own contract price. You usually can't see that number when you sign, so you won't know your real fee until Kyiv tells you.
The timeline. The permit decision is meant to come within 30 days, and that's the figure you'll hear. But it doesn't start until the goods are classified, a step the new rule kept that can run up to 60 days on its own. So the real wait is closer to 90 days, before the buyer's government signs off.
Eligibility. To buy, a country's government needs a cooperation deal with Ukraine, and it has to promise, at state level, that the goods will be used as agreed and won't be resold. When that deal is one of Ukraine's "Drone Deal" frameworks, the buyer skips a step: no case-by-case clearance from Ukraine's defense and security agencies, so approval comes faster. Eligibility is a government-to-government question before it's a commercial one.
IP retention and onward royalty. Transferred technology stays Ukrainian-owned under a use-and-build license, with written consent required for any downstream transfer. A further 20% falls due where goods built abroad on Ukrainian technology reach a third country. Partners can co-produce, but ownership stays in Kyiv.
The recall. A permit yields to domestic priority. Where the front needs the goods, the state can refuse or freeze the export, and the exporter's only route through is a first-supply guarantee to Ukraine. So a signed permit doesn't guarantee supply: Ukraine can still hold the goods back for its own use.
Beyond Ukraine
The mechanics are the easy part. The harder question, for a portfolio or a mandate, is how much of this holds up outside Ukraine.
Ukraine-specific
The pricing power rests on a data monopoly. Ukrainian systems are the only inventory validated continuously against a peer adversary over 3-plus years. No other exporter can charge a proof premium, because no other exporter holds the proof.
No. 875 is a martial-law measure, and the recall right depends on there being an active front. Both go away once the war ends.
The specific rates and the Drone Deal structure reflect Ukraine's current position and alliances, and both will change.
Transferable
The pricing principle. Ukraine has put a real number on combat validation: 20 to 30% of value, plus a cut of any resale. That gives you a reference point for pricing anything whose worth comes from a proven combat record. And a government sitting on the best battlefield data just wrote that premium into law, which cuts against how most Western buyers still value these systems.
Export policy as a foreign-policy tool. Ukraine gates access behind government guarantees and waves treaty partners through faster. That's a playbook other exporters can copy, and one their customers will feel: to get in, your government has to sign on. Watch for others to run it.
Cross-border control mismatch. Every export has an importer on the other end, and that country runs its own controls, which rarely line up with Ukraine's. Ukraine still classifies goods against international lists from 2017 to 2019, the EU uses a newer set (Regulation 2021/821) that updates often, and any US parts inside a system pull in US re-export rules on top.
So a deal Kyiv would approve and a buyer would accept can still stall, because the two sides disagree on what the item even is or what it takes to clear it. The lesson carries to any cross-border defense deal: the real bottleneck is usually the gap between the two countries' control systems, and it bites even when each side's rules would clear the deal alone.
Assessment
Start with the biggest change: Ukraine is open for business. For 3-plus years there was no legal path to buy its frontline technology. Now there's a front door, with a set price and a clear process, built by the state on purpose.
Anyone who wanted the world's most combat-proven systems and couldn't get near them can now do a deal.
For a capital allocator, that opening cuts both ways. On the plus side, a deal here can finally be underwritten and compared like any other. On the minus side, Ukraine can recall the goods and sets the valuation itself, so a supply contract carries real risk, and any lender or buyer will price that in.
Open and orderly now, and still not clean.
The fee also works as a filter. A 20 to 30% charge, plus a cut of any resale, is only worth paying on high-value, combat-proven systems, where the margin can absorb it. Cheap commodity parts can't carry a fee that size, so they drop out.
Whatever does move abroad then shows what buyers actually want from Ukraine. The tax does the sorting.
And the take is earmarked. The 20 to 30% flows to a special state fund for the Ministry of Defence, so every export deal feeds Ukraine's war effort directly.
Signposts
Recall refusals. How often Ukraine blocks or freezes an export to keep the goods for its own front. If that happens a lot, a signed contract doesn't mean much. If it's rare, buyers can count on delivery.
Quiet discounts. Whether the 20 to 30% fee gets waived or cut for favored buyers. If the price bends for the countries Ukraine wants to court, the headline rate means less than it looks.
Systems or parts. Whether cleared permits are for whole systems or just components. Mostly whole systems would confirm the fee is filtering out the cheap stuff, as we expect.
List changes. How often Ukraine updates its two lists, who can buy and what counts as controlled. Frequent changes mean more of the outcome rides on official discretion than on fixed rules.
Catching up to the EU. Whether Ukraine updates its control lists to match the EU's newer ones. If it does, the cross-border mismatch that stalls deals gets smaller.
Gaps
The rule has been in force about 6 weeks. A handful of permits have issued, though refusals are still common. There's no public record of volumes yet.
So it's too soon to tell whether No. 875 runs as a genuine open channel or a gate Kyiv opens at its own discretion. That stays an assessed judgment until more decisions land.
The valuation sits with Ukraine and isn't shown up front, so the real fee on a given deal can't be modeled from outside. The eligible-country list still isn't public. The signposts above are how these questions resolve.
Structure and figures documented against the enacted text of Resolution No. 875 (adopted 1 July 2026, in force 8 July 2026), Ukraine's State Export Control Service procedure, and independent legal analyses, as of 20 August 2026.