UK export licensing shake-up brings new rules and wider market access

12 November 2026

 

UK exporters of military and dual-use goods, software and technology face significant changes to the country's strategic export control framework, with new regulations taking effect on 1 December 2026.

The developments follow an expansion of three open general export licences (OGELs) announced on 14 October 2026, opening additional overseas markets to qualifying exporters while the forthcoming regulations update controls on sensitive technologies and existing export authorisations.

For businesses in aerospace, engineering, advanced manufacturing, electronics and defence, the changes could affect product classifications, existing licensing arrangements and access to international markets.

New export control regulations take effect on 1 December

The Export Control (Amendment) Regulations 2026, made on 29 October and laid before Parliament on 3 November, introduce amendments to two key areas of the UK's strategic export control framework:

  • Schedule 2 of the Export Control Order 2008, covering controlled military goods, software and technology.

  • Annex I of the UK's assimilated Dual-Use Regulation, covering goods, software and technology that may have both civilian and military applications.

The revised controls reflect changes agreed through international export control arrangements, including the Wassenaar Arrangement and Australia Group, alongside measures addressing advanced and emerging technologies.

These include updates affecting certain semiconductor manufacturing equipment, advanced computing technologies and specialised materials, as well as revisions to technical definitions and individual control entries.

For manufacturers and technology exporters, the significance lies in the technical specifications of their products. Goods previously assessed against an existing control entry may need to be reviewed against the revised lists to determine whether their classification or licensing requirements have changed.

Changes to restrictions on Haiti and the Central African Republic

The regulations also amend Schedule 4 of the Export Control Order 2008, which identifies countries subject to stricter export or trade controls.

  • Haiti moves from Part 3 to Part 2, placing it among destinations subject to an arms embargo and military goods transit controls.

  • The Central African Republic moves from Part 2 to Part 3, narrowing the applicable restrictions to military goods transit controls under this Schedule.

These amendments align the export control framework with the scope of the UK's relevant sanctions regimes, broadening the controls applicable to Haiti while narrowing those applying to the Central African Republic.

Existing dual-use export authorisations are being withdrawn

The December regulations also revoke General Export Authorisation No 001 (GEA001) from the UK's assimilated Dual-Use Regulation.

GEA001 has been superseded in Great Britain by the broader Open General Export Licence (export of dual-use items).

Exporters already registered to use GEA001 immediately before 1 December 2026 may continue using it during a transitional period ending on 1 April 2027.

The withdrawal applies to Great Britain only. EU GEA001 will continue to apply to exports from Northern Ireland under the relevant EU dual-use framework.

Separately, the Export Control Joint Unit (ECJU) has announced plans to revoke the existing Open General Export Licence (export of dual-use items to EU member states), which has also been superseded by the broader dual-use OGEL.

Existing users of the EU member states licence may continue using it until 1 April 2027, giving businesses time to review the replacement arrangements and complete the necessary registration.

Further details of these changes and transitional provisions are available in the ECJU's Notice to Exporters 2026/24.

Export licences expanded to additional overseas markets from 14 October

Alongside the forthcoming regulatory changes, the ECJU expanded the geographical coverage of three existing OGELs on 14 October 2026.

These licences allow registered businesses to export specified controlled goods, software and technology to approved destinations without applying for a separate standard individual export licence for every eligible shipment.

Twelve additional destinations for dual-use exports

The expanded dual-use OGEL now includes:

  • Bahrain

  • Botswana

  • Brunei

  • Jordan

  • Kuwait

  • Mauritius

  • Morocco

  • North Macedonia

  • Oman

  • The Philippines

  • Qatar

  • Seychelles

The licence covers qualifying controlled items across sectors including aviation, maritime equipment, information technology, semiconductor technologies and quantum-related applications.

For businesses supplying eligible products to these destinations, the expansion could reduce repeat licence applications and improve export planning.

However, the inclusion of a destination does not automatically authorise all controlled goods or technologies. Eligibility depends on the specific product classification, intended use, end-user and licence conditions.

Exporters can consult the Open General Export Licence for dual-use items for the permitted goods, destinations and applicable requirements.

Military goods licences extended to additional markets

Two OGELs covering military goods, software and technology have also been expanded.

1. Exports to specified government and NATO end-users

The licence now includes:

Brunei, Chile, Jordan, Kuwait, Montenegro, North Macedonia and Oman.

This expansion applies to qualifying military goods, software and technology supplied to eligible government and, where applicable, NATO end-users.

2. Exports to commercial and government/NATO end-users

The broader military goods licence now includes:

Bulgaria, Croatia, Czechia, Estonia, Greece, Hungary, Latvia, Liechtenstein, Lithuania, Luxembourg, Poland, Portugal, Romania, Slovakia, Slovenia, South Korea and Switzerland.

This could benefit businesses supplying eligible defence components, specialist engineering products and technologies used in international aerospace and defence supply chains.

The distinction between the two licences is important, as the permitted goods, eligible end-users and conditions differ.

According to the Government, the October expansions could eliminate the need for more than 800 standard individual export licence applications annually, reducing administrative requirements for qualifying exporters.

The full details of the expanded licensing arrangements are available in Notice to Exporters 2026/23.

 

By Carla Assunção, Chamber International

 

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