On 11 December 2025, the UK formally acceded to the Agreement on Defence Export Controls, joining France, Germany and Spain in a framework designed to simplify export licensing for joint defence programmes. This marks a significant step in aligning UK defence trade processes with key European partners.
Key takeaways
- UK joins Defence Export Controls Agreement with France, Germany and Spain.
- Streamlines licensing for joint defence programmes—applies both ways (exports and imports).
- Covers military goods, dual-use items, technical assistance and data.
- UK regime remains under Export Control Act 2002 and Strategic Export Licensing Criteria.
- ECJU will issue guidance and an OGEL to support implementation.
- Does not grant access to EU funding schemes like SAFE/ReArm, but signals closer alignment.
Background & Official Statement
The Agreement was first signed in Paris in September 2021 by France and Germany, later joined by Spain, to address delays and complexity in multinational defence programmes.
The Secretary of State, Luke Pollard, commented:
“The UK’s accession to the Agreement will reduce the administrative burden of granting export licences between our nations, open opportunities for UK businesses and help boost economic growth across the country”
What’s Covered: Products & Legal Framework
The Agreement applies to defence items already controlled under UK law, including:
- Military goods, software and technology designed or modified for military use.
- Dual-use items (civilian goods with military applications), such as electronics, sensors, navigation systems, and advanced materials.
- Technical assistance and data, including designs, blueprints, and training related to controlled goods.
- Catch-all controls for items intended for military end-use.
These controls sit within the UK’s statutory regime under the Export Control Act 2002, supported by the Export Control Order 2008. All licence applications remain subject to the Strategic Export Licensing Criteria, and violations can lead to criminal penalties.
Why This Matters
The Agreement simplifies licensing for defence items moving between signatory countries in collaborative programmes. For UK businesses, this means:
- Faster licensing for joint projects.
- Greater certainty in multinational supply chains.
- Reinforced UK positioning as Europe’s leading defence exporter.
Who Should Pay Attention?
- UK exporters and importers trading defence components with France, Germany and Spain.
- European partners supplying into UK-led programmes.
- Systems integrators, technology suppliers, brokers, compliance teams, financiers.
The Agreement is bidirectional—applies to defence items moving both ways between signatories. Imports from non-signatory countries (e.g., US, Italy) remain under existing UK rules.
Could This Help the UK Join EU Defence Funding Schemes (SAFE/ReArm)?
Not directly. The Agreement focuses on licensing, not funding. It does not grant access to EU initiatives like SAFE or ReArm (€150 bn in loans and procurement support). However, it signals closer alignment and could strengthen the UK’s case in future negotiations.
Next Steps for Businesses
- Monitor ECJU guidance and upcoming OGEL.
- Engage early in Franco-German-Spanish collaborative ventures.
- Stay alert to developments in UK–EU defence finance talks.
How We Can Help
Bird & Bird has extensive expertise in helping clients navigate export controls and customs rules across Europe. Our team advises on:
- Compliance strategies and risk assessments
- Licensing applications under UK and EU regimes
- Managing complex regulatory frameworks for cross-border defence projects
For further information, please contact:
Goran Danilovic, Bird & Bird
goran.danilovic@twobirds.com
