UK Government United Kingdom Strategic Export Controls Annual Report 2025 HC 557 UK Government United Kingdom Strategic Export Controls Annual Report 2025 Presented to Parliament pursuant to Section 10 of the Export Control Act 2002 Ordered by the House of Commons to be printed on 15 July 2026 HC 557 © Crown copyright 2026 This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned. This publication is available at www.gov.uk/official-documents Any enquiries regarding this publication should be sent to us at [email protected] ISBN 978-1-5286-6401-1 E03585820 07/26 Printed on paper containing 40% recycled fibre content minimum Printed in the UK by HH Associates Ltd. on behalf of the Controller of His Majesty’s Stationery Office Contents Foreword 1 Section 1: Export licensing process and basics 3 Section 2: Export licensing data 9 Section 3: Modernising ECJU 24 Section 4: Updates on legislation 26 Section 5: External engagement 28 Section 6: HM Government support to Allies and Partners 32 Section 7: International Issues 36 Section 8: UK and International Policy developments 40 Section 9: Compliance and enforcement 44 Annex A: The Strategic Export Licensing Criteria 50 Annex B: Licence type definitions 55 Annex C: A summary of key changes affecting OGELs in 2025 60 Annex D: OGELs and other general licences in force in 2025 62 Foreword This Annual Report sets out the United Kingdom’s strategic export controls activity in 2025. Strategic exports are an important part of the UK economy, supporting jobs and industries at home - as well as supporting our national security and foreign policy overseas. But it is vital that those exports do not fall into the wrong hands - and can never be used to commit acts which violate basic human rights, or which breach international humanitarian law. That is what the UK’s system of export controls seeks to do, and this report gives important transparency to Parliament on how it operates. The report reflects a year in which the export control system operated in a particularly demanding international and operational environment. Rightly there is strong parliamentary and public interest in ensuring there are strong export controls connected to Gaza - including for example the suspension we put in place in September 2024 to stop all exports to the IDF (Israel Defense Forces) which might be used in a breach of international humanitarian law. In relation to Russia and Ukraine, the report shows how sanctions, heightened diversion risks and the need to support Ukraine’s defence have continued to shape licensing activity and place new demands on operational and policy teams. In both contexts, the report underlines the need for the export control system to remain agile, evidence-based and capable of responding quickly to changing circumstances while maintaining rigorous scrutiny. The report demonstrates how the control regime continues to adapt to evolving risks and points to the increasing prominence of emerging and dual-use technologies in the export control landscape. As technological change accelerates, HM Government must ensure that the UK’s strategic export controls remain effective, proportionate and responsive. The reviews and policy work described in this report, including work on emerging technologies, are therefore an important part of ensuring that the UK’s strategic export controls remain effective, proportionate and fit for purpose in a changing global environment. The report also sets out candidly the pressures on operational performance during 2025. Although performance against published targets remained below the standard we ideally seek to attain for the year as a whole, the report shows the practical action being taken to improve timeliness, strengthen case handling and build a resilient service, all of which resulted in improved operational performance in the latter half of 2025. A central theme of this year’s report is the transition from SPIRE to LITE, the new digital licensing platform. This is a major modernisation programme, designed to replace legacy infrastructure, improve security and accessibility, and support a more efficient and user-centred licensing service over time. This transition has brought short-term operational challenges, but it also represents an important investment in the future capability, resilience and transparency of the export control system and has been actively supported by industry. Strategic export controls are an essential part of responsible government: they protect our security, support our international partnerships, and help ensure that UK exports are consistent with our values and obligations. This report provides Parliament and the public with a clear account of how those responsibilities were discharged in 2025, and of the steps being taken to strengthen the system for the years ahead. The Rt Hon Peter Kyle MP Secretary of State for Business & Trade and President of the Board of Trade The Rt Hon Yvette Cooper MP Secretary of State for Foreign, Commonwealth & Development Affairs The Rt Hon Dan Jarvis MP Secretary of State for Defence Section 1: Export licensing process and basics 1.1 The need for export licensing Export controls protect global security by restricting who has access to sensitive technologies and capabilities, ensuring UK exports do not contribute to Weapon of Mass Destruction (WMD) proliferation, a destabilising accumulation of conventional weapons, or are used to commit or facilitate internal repression or to commit or facilitate a serious violation of International Humanitarian Law. They are a means by which a range of international obligations and commitments, including the Arms Trade Treaty (ATT), are implemented. The Export Control Act 2002 and the Export Control Order 2008 provide the legal framework for the UK’s export controls. A body of assimilated legislation and current EU legislation are also relevant. Through this legislative framework, HM Government controls the export of a range of military and “dual-use” items. (Dual-use items are goods, software, technology, documents and diagrams which can be used for both civil and military applications. They can range from raw materials to components and complete systems, such as aluminium alloys, bearings, or lasers. They could also be items used in the production or development of military goods, such as machine tools, chemical manufacturing equipment and computers.) Under the terms of the Windsor Framework, certain EU legislation continues to apply to the movement of controlled goods in Northern Ireland. Section 4 sets out the changes to applicable legislation that occurred in 2025. A product needs an export licence if it is included in: • the UK Military List or national control list • lists of controlled dual-use items covered by assimilated Council Regulation (EC) No 428/2009. (For exports from Northern Ireland, the relevant regulation is Regulation (EU) 2021/821). These dual-use items are derived from the international export control regimes (set out in more detail in section 8), which are: • The Nuclear Suppliers Group • The Missile Technology Control Regime • The Australia Group • The Wassenaar Arrangement • The Zangger Committee • the list of goods covered by assimilated Regulation (EU) 2019/125 concerning trade in certain goods which could be used for capital punishment, torture or other cruel, inhuman, or degrading treatment or punishment (the Torture Regulation), for exports from Northern Ireland, the relevant regulation is Regulation (EU) 2019/125 • the list of items covered by assimilated Regulation (EU) No 258/2012, which establishes export, import and transit measures for firearms, their parts and components and ammunition. For exports from Northern Ireland, the relevant regulation is Regulation (EU) 258/2012), although a new regulation (EU) 2025/41 is in force, it does not apply to exports of firearms until 12 February 2029 • the list of goods covered by the Export of Radioactive Sources (Control) Order 2006 Even if an item does not appear on one of these lists, it may still require an export licence under Article 4 of assimilated Council Regulation (EC) No 428/ 2009 (Article 4 of Regulation (EU) 2021/ 821 for Northern Ireland), if there are concerns about its end-use. “End-use” or “catch-all” controls aim to prevent the proliferation of WMD and their delivery systems, or the supply of items intended for a military end-use in an embargoed destination. Articles 6, 10, 11 and 12 of the Export Control Order 2008 extend the scope of the WMD controls to include: where a person suspects that dual-use goods, software or technology are or may be intended for a WMD purpose; transfers of software or technology for a WMD purpose within the UK; transfers of software or technology for a WMD purpose by a UK person from outside the UK; and transfers of software or technology for a WMD purpose by non-electronic means to destination outside the UK. Article 12a of the Export Control Order 2008 enhances the Military End-Use Control (MEUC), by extending the scope of this control to use by a broader range of relevant entities. 1.2 The Export Control Joint Unit (ECJU) ECJU manages HM Government’s system of export controls and brings together policy and operational expertise from DBT, the Foreign, Commonwealth & Development Office (FCDO) and the Ministry of Defence (MOD). The individual departments within ECJU have distinct roles. Departments involved in export control The licensing process, and all the departments involved in licensing and/or enforcing the implementation of export controls, are set out below. Department for Business and Trade (DBT) DBT has overall responsibility for the export licensing process. The Secretary of State for Business and Trade is responsible for: • the statutory and regulatory framework of the controls (i.e. what items and activities are controlled) • the decision to grant or refuse an export licence in any individual case; and where necessary, the decision to suspend or revoke extant licences in accordance with the relevant legislation and policy Advisory departments The principal advisory departments are the FCDO and MOD. Together, they provide DBT with advice and analysis on foreign policy, defence and development matters relevant to licensing. They do this by assessing all applications on a case-by-case basis against the Strategic Export Licensing Criteria. Foreign, Commonwealth & Development Office (FCDO) The FCDO team considers, among other issues, whether an export: • will be consistent with the UK’s international obligations and commitments and sanctions regimes • might be used to commit or facilitate internal repression or to commit or facilitate a serious violation of International Humanitarian Law • would contribute to or undermine peace and security • could be used to commit or facilitate an act constituting an offence under international conventions or protocols to which the UK is a Party, relating to terrorism or transnational organised crime • could be diverted to an undesirable user or for an undesirable end-use • is compatible with the technical and economic capacity of the recipient country, if the country is on the World Bank’s International Development Association list The FCDO also provides advice to the MOD for relevant F680s, a security procedure assessing the release of UK classified material. FCDO assesses whether the release of information would be consistent with the UK’s international obligations and commitments and sanctions regimes. In making its assessment, the FCDO takes account of the proposed end use of the items, the situation in the destination, and the end user. The FCDO ECJU team seeks detailed political, sanctions, human rights advice as necessary from the FCDO’s policy desks, posts overseas and other sources, including Non-Governmental Organisations (NGOs), or credible media reporting. Ministry of Defence (MOD) The MOD considers the military, operational, technical and security aspects of proposals to release classified material or export-controlled goods to foreign end-users. The MOD advises on the risk of any export being used against the UK Armed Forces and those of our Allies, and any potential threat to the security of the UK or Allies. The MOD jointly leads with the FCDO on assessing the risk of diversion or re-export of goods to end-users of concern. The MOD’s advice on export licence applications is given on a case-by-case basis and assesses the views of those responsible for protecting the capability of the UK’s Armed Forces, as well as security and intelligence specialists. The MOD operates the MOD Form 680 (F680) approval process which enables HM Government to control the release of classified equipment or information to foreign entities without compromising the UK’s national security. The MOD is responsible for processing gifting applications on behalf of HMG (further details can be found in section 6). National Cyber Security Centre (NCSC) The NCSC is HM Government’s national technical authority for information security and advises on applications for goods involving sensitive communications or computer technology. Department for Energy Security and Net Zero (DESNZ) DESNZ plays a key role in HM Government’s chemical and nuclear non-proliferation policy. DESNZ ensures HM Government continues to meet its obligations under the Chemical Weapons Convention (CWC) and Nuclear Suppliers Group (NSG). For the CWC, DESNZ ensures CWC Schedule 1 chemical exports are appropriately licensed by the UK National Authority, that the restrictions on certain chemical exports are highlighted and, where appropriate, documentation approved by other governments is acquired prior to making recommendations to DBT. For the NSG, DESNZ ensures that any additional documentation required from other governments is secured in advance of providing a recommendation to DBT. HM Revenue and Customs (HMRC) HMRC does not provide direct advice on export licence applications but has a key role to play in the licensing system. It is responsible for enforcing UK export controls and trade sanctions which fall within its customs remit, and for certain trade sanctions outside its customs remit that it will enforce under criminal law on referral from the Office of Trade Sanctions Implementation (OTSI) which became operational in October 2024. HMRC works with Border Force to prevent, detect and investigate breaches. A decision whether to commence a prosecution arising from an HMRC criminal investigation is made by the relevant prosecuting authority, who will also undertake the conduct of any subsequent prosecution. This is the Crown Prosecution Service for England and Wales, the Crown Office and Procurator Fiscal Service in Scotland and the Public Prosecution Service for Northern Ireland. Standard Individual Export Licence (SIEL) process: - Licence application submitted - DBT triage application - Licensing Intelligence Team conducts additional checks - Technical Assessment Unit checks goods ratings - Licensing Unit reviews before consulting Advisory Departments (FCDO, MOD, DESNZ, NCSC) - If refusal recommended: Meeting between DBT and advisory departments - If required: Request for more information from Applicant - Outcomes: Licence Refused OR Licence Issued - If issued: DBT issues digital copy of licence -> EXPORT PERMITTED - If refused: Appeal submitted by Applicant -> Outcome: Appeal Rejected / Original decision upheld OR Appeal Upheld 1.3 Overview of export licence types Applications for export, trade (‘brokering’), or transhipment licences for controlled goods are submitted to ECJU either through its legacy digital system known as SPIRE (Shared Primary Information Resource Environment), or through its new digital system LITE (Licensing for International Trade and Export), which is being gradually introduced. Further detail is available in section 3.2. Applications must include details about who will use the goods and what they intend to do with them. This information is considered as part of the overall assessment process. Applications must include technical specifications, sufficient to allow experts in ECJU to determine whether the goods are specified by the control lists and therefore need an export licence. A list of licence types, including a description of each, is set out in Annex B. Table 1.1 Summary of applications and registrations - Standard Individual Export Licences (SIELs): 14,849 (1,496 SIEL applications on SPIRE legacy system, 13,353 on LITE) - Open Individual Export Licences (OIELs): 444 (428 OIEL applications on SPIRE legacy system, 16 on LITE) - Open General Export Licences (OGELs)*: 1,192 - Assimilated General Export Authorisations (GEAs)*: 270 - Union General Export Authorisations (GEAs)*: 43 - Standard Individual Trade Control Licences (SITCLs): 229 - Open Individual Trade Control Licences (OITCLs): 49 - Open General Trade Control Licences (OGTCLs)*: 48 - Standard Individual Transhipment Licences (SITLs): 5 - Open General Transhipment Licences (OGTLs)*: 6 - General Trade Licences*: 29 - Other types of General licences*: 1 *Registrations are based on finalised records available on gov.uk Section 2: Export licensing data 2.1 Transparency Transparency is one of the key priorities for the ECJU, with the unit looking to publish what it can, whilst being mindful of the very real commercial sensitivities of the data entrusted to us by UK exporters. HM Government publishes quarterly strategic export controls licensing decisions statistics providing data about decisions made on licence applications, including those issued, refused, rejected, or revoked. In addition, an online searchable database (Strategic Export Controls: Reports and Statistics website) is provided to allow users to produce bespoke reports drawing on this data. HM Government remains committed to openness and transparency of strategic export licensing to enable Parliament and the public to hold it to account. Given the exceptional circumstances, and the significant Parliamentary and public interest in the conflict in Gaza, HM Government has also published a series of ad hoc management information releases since May 2024 to provide more current information about Israel export licensing. Completeness of published data The official statistics have progressively expanded their coverage of licensing decisions processed through LITE. A significant milestone was reached with the publication of Q2 2025 data in November 2025, when, for the first time, the statistics incorporated the full set of licensing decisions across both SPIRE and LITE systems. Data Quality Between Q1 2023 and Q1 2025, published statistics were affected by limitations in extracting complete and accurate data from LITE, which have been clearly caveated alongside the impacted figures in the licensing decision statistics. In December 2024, ECJU Official Statistics were reclassified as ‘Official Statistics in Development’ due to changes affecting data quality. This status has continued through 2025 and will remain until there is full confidence in new data extraction processes and data quality. Timeliness of the ECJU quarterly statistics To generate the quarterly statistics, data is extracted across SPIRE and LITE, which is then merged and quality assured, before final publication data tables are produced. The timeliness of publishing ECJU licensing outcomes was significantly affected during 2024 and 2025 due to the added complexity of operating both LITE and SPIRE systems in parallel. Additional time was required to extract and prepare data of varying quality across the two platforms. Over the course of 2025, the timeliness of publications improved, with the lag between the reporting period and publication reduced to around 4.5 months. Work is ongoing to further enhance timeliness, with the aim of returning to a publication timeline of approximately 3.5 to 4 months after the reporting period, in line with performance prior to the introduction of LITE as soon as reasonably possible. Ad hoc Management Information publications Given the exceptional circumstances, and the significant Parliamentary and public interest in the conflict in Gaza, DBT has published a series of ad hoc management information releases since May 2024, to provide more current information about Israel export licensing. These ad hoc management information releases have provided data at the date of each update on Israel export licence applications in progress, Israel export licences that remained extant and Israel export licensing decisions made between each update. These ad hoc releases included both SPIRE and LITE data and are therefore representative of all licensing activity for Israel in the periods to which they relate. One such release was published in 2025 (on 28 August), covering the period 7 December 2024 to 31 July 2025. The remainder of relevant licensing decisions in 2025 were covered in the 20 April 2026 release, which covered the period 1 August 2025 to 28 February 2026. Information on actual licence usage It has been a long-held ambition of ECJU to collate, utilise and make public information on actual licence usage data. Whilst some such data is transmitted to DBT systems, this has not historically been done in a manner that makes aggregated data accessible, suitable for publication. ECJU is therefore actively exploring with HMRC a new system to rectify these issues, with a view to being able to provide more information on the usage of export licences. Progress is being made, although more work remains to be done on data assurance, completeness, and the level of detail that could eventually be published. 2.2 Data for each licence type Table 2.1 Summary of application outcomes in 2025 Outcome | SIELs | SITLs | OIELs | SITCLs | OITCLs Issued | 10,414 | 2 | 247 | 121 | 11 Refused / Rejected | 501 | 0 | 44 | 7 | 4 No Licence Required | 2,865 | 0 | 4 | 23 | 1 Withdrawn, Stopped or Unsuitable | 1,226 | 4 | 101 | 67 | 29 Revoked | 4 | 0 | 0 | 0 | 0 Total licensing decisions | 15,010 | 6 | 396 | 218 | 45 Chart 2.1 Application outcome of Standard Individual Export Licences (SIELs) in 2025: Issued: 10,414; No Licence Required: 2,865; Withdrawn/Stopped: 1,226; Refused: 501; Revoked: 4. Chart 2.2 Application outcome of Standard Individual Transhipment Licences (SITLs) in 2025: Issued: 2; Withdrawn/Stopped: 4; No Licence Required: 0; Refused: 0; Revoked: 0. Chart 2.3 Application outcome for Open Individual Export Licences (OIELs) in 2025: Issued: 247; Withdrawn, Stopped or Unsuitable: 101; Rejected: 44; No Licence Required: 4; Revoked: 0. Chart 2.4 Application outcome of Standard Individual Trade Control Licences (SITCLs) in 2025: Issued: 121; Withdrawn, Stopped or Unsuitable: 67; No Trade Licence Required: 23; Refused: 7; Revoked: 0. Chart 2.5 Application outcome for Open Individual Trade Control Licences (OITCLs) in 2025: Issued: 11; Withdrawn, Stopped or Unsuitable: 29; Rejected: 4; No Trade Licence Required: 1; Revoked: 0. 2.3 Performance against targets On receipt of a Standard Individual Export Licence (SIEL) application, ECJU’s target is to complete 70% of cases within 20 working days (primary target) and 99% within 60 working days (secondary target). Performance against these targets during 2025 remained challenging, with neither the primary nor secondary target met. Recent performance against the secondary target reflects the longstanding difficulty ECJU has faced in achieving this target. It has only been met twice since it was introduced in 2013 – in 2014 and 2016. Table 2.2 SPIRE SIEL processing performance (Annual) - Number of applications completed in 20 working days: 2025: 1,002 | 2024: 6,539 | 2023: 7,746 - % of applications completed in 20 working days: 2025: 51% | 2024: 60% | 2023: 52% - Number of applications completed in 60 working days: 2025: 1,403 | 2024: 9,179 | 2023: 13,049 - % of applications completed in 60 working days: 2025: 72% | 2024: 84% | 2023: 87% - Median processing time in days: 2025: 20 | 2024: 16 | 2023: 20 Table 2.3 LITE SIEL processing performance (Annual) - Number of applications completed in 20 working days: 2025: 6,968 | 2024: 2,127 | 2023: 489 - % of applications completed in 20 working days: 2025: 53% | 2024: 47% | 2023: 38% - Number of applications completed in 60 working days: 2025: 11,867 | 2024: 4,172 | 2023: 1,174 - % of applications completed in 60 working days: 2025: 91% | 2024: 93% | 2023: 92% - Median processing time in days: 2025: 19 | 2024: 22 | 2023: 25 Quarterly SIEL performance (Charts 2.6 & 2.7): Primary 20 working-day target (70%): - Q4 2024: SPIRE 58%, LITE 51% - Q1 2025: SPIRE 48%, LITE 41% - Q2 2025: SPIRE 53%, LITE 50% - Q3 2025: SPIRE 52%, LITE 59% - Q4 2025: SPIRE 58%, LITE 63% Secondary 60 working-day target (99%): - Q4 2024: SPIRE 76%, LITE 93% - Q1 2025: SPIRE 70%, LITE 93% - Q2 2025: SPIRE 69%, LITE 92% - Q3 2025: SPIRE 77%, LITE 91% - Q4 2025: SPIRE 77%, LITE 88% 2.4 Refusals There were 508 Standard Individual Licences (SIELs, SITLs or SITCLs) refused in 2025, compared with 611 in 2024. Refusal rate decreased from 4.6% in 2024 to 3.6% in 2025. Table 2.4 Reasons for refusals of SIEL and SITCL applications (2025 / 2024 / 2023): - Criterion 1 (Non-proliferation Treaties/WMD/ballistic missiles): 0 / 5 / 6 - Criterion 1 (UN, OSCE, UK arms embargoes): 74 / 53 / 39 - Criterion 1 (Announced national measures or restrictions): 5 / 10 / 8 - Criterion 1 (Certain Conventional Weapons / Oslo / Ottawa / Land Mines Act): 0 / 0 / 0 - Criterion 2 (Internal repression / IHL): 35 / 39 / 22 - Criterion 3 (Internal peace and security): 1 / 3 / 1 - Criterion 4 (Preservation of peace and security): 45 / 6 / 3 - Criterion 5 (National security of UK, allies): 113 / 180 / 175 - Criterion 6 (Behaviour of buyer country): 1 / 0 / 0 - Criterion 7 (Risk of diversion): 437 / 486 / 321 - Criterion 8 (Economic capacity): 0 / 0 / 0 - Catch-all controls for non-listed items - WMD: 34 / 33 / 77 - Catch-all controls for non-listed items - Military End-Use: 194 / 296 / 447 2.5 Revocations There were four revocations of SIELs and SITCLs in 2025 (all 4 under Criterion 4 - Preservation of peace and security). No suspensions of SIELs and SITCLs occurred in 2025, though two open individual licences to Israel were suspended in 2025. 2.6 Appeals Table 2.6 Appeals outcome and performance (2025 / 2024 / 2023): - Number of Appeals received: 91 / 50 / 95 - Number of Appeals finalised: 91 / 72 / 50 - Median processing time for finalised Appeals (days): 36 / 106 / 80 - Number of Appeals where refusal was upheld: 87 / 68 / 46 - Number of Appeals where refusal was overturned: 4 / 5 / 4 2.7 Data on other types of licence Table 2.7 Other licence type decisions made in 2025 (Issued / Refused / Revoked): - Technical Assistance Licences (WMD): 0 / 0 / 0 - Technical Assistance Licences (Sanctions): 0 / 0 / 0 - Technical Assistance Licences (Energy related items under Russia Sanctions): 0 / 0 / 0 - Technical Assistance Licences (Russia Sanctions - Other): 4 / 0 / 0 - Individual Financial Services Licences: 53 / 0 / 0 - Individual Brokering Services Licences: 1 / 0 / 0 - Licences for multiple services - Financial Services and Brokering Services: 1 / 0 / 0 - Individual Licences for export-related activities: 3 / 0 / 0 - Syrian Humanitarian Licences: 0 / 0 / 0 - Licence under multiple sanctions regimes: 0 / 0 / 0 - Professional and Business Services Licences: 10 / 1 / 0 - Licences for drugs used in execution by lethal injection: 0 / 0 / 0 - Global Project Licences: 0 / 0 / 0 2.8 OGELs and Assimilated and Union General Export Authorisations In 2025, there were 72 OGELs and general licences in force, one of which was revoked and one extended. 21 OGELs were amended in 2025. Section 3: Modernising ECJU 3.1 Improving the way ECJU works In 2025, the ECJU established a continuous improvement programme aimed at enhancing service delivery to UK exporters by identifying opportunities to improve operational performance and quality. A dedicated continuous improvement team was recruited, tasked with conducting systematic reviews of existing processes and identifying ways to make these more efficient, with service to exporters in mind. A commitment to continuous improvement has been embedded across all operational areas, with regular monitoring and evaluation mechanisms established to track progress and identify further opportunities for refinement. A significant milestone in this improvement journey has been the comprehensive review of operational processes undertaken in parallel with the design and development of LITE. As part of this modernisation programme, ECJU is introducing new standardised operating procedures across all teams responsible for processing SIELs. These procedures have been designed to ensure consistency in decision-making across different case officers and government departments, maintain consistency of information throughout the licensing process, and establish clear quality assurance frameworks. Throughout 2026, further development of standard operating procedures will cover the Open Individual Export Licence (OIELs) process as well as processes for other licence types. In 2025 ECJU has also concentrated on improving support and guidance to exporters. The ECJU helpdesk introduced new technology that allowed more efficient management of queries, providing a better service to those requiring support. Increased communications have taken place, through targeted webinars when new technology was released as well as a review of the content available to exporters via the internet. A key objective for 2026 is to complete a review of the published communications and content to make it easier for exporters and users of the service to find out information about export controls. 3.2 Modernising the new online digital system for export licensing Development of the new online digital service for export licensing, LITE, made significant progress during 2025 as ECJU continued to transition away from the legacy SPIRE platform. LITE provides exporters with a modern GOV.UK compliant route for submitting applications and is a central component of ECJU’s digital modernisation programme. Following its move from small, invitation-only test environment to a wider trial run in September 2024, LITE saw strong adoption throughout 2025. By the end of 2025, the majority of export licence applications were processed through LITE, with 87% of SIEL applications submitted via the system. In 2025, the service also expanded beyond SIELs with the introduction of the F680 application route on LITE. The rollout of F680s marked an important step in reducing reliance on SPIRE, and work continues into 2026 to increase the proportion of F680 applications handled through the online system. The LITE programme maintained strong engagement with exporters and internal users throughout the year, including targeted user research, online events, and close collaboration with licensing officers across government. Exporters continue to be supported by a dedicated helpdesk, with service enhancements informed by ongoing feedback. Monitoring and evaluation of the LITE programme is in place. The initial survey and interviews with SPIRE users have been completed, with further research concentrated on LITE now in progress. We intend to publish the full evaluation findings in due course once the research is complete. Looking ahead to 2026, ECJU will continue to develop additional licence types and further improve existing services on LITE. This work will be phased and prioritised around high volume and operationally critical needs, supporting the wider programme to modernise ECJU’s digital and operational capabilities while ensuring continuity of service as migration from SPIRE continues. Further development is planned in 2026 to enable LITE to produce new management information data, which is critical to supporting ECJU to make operational improvements and reduce processing times. Section 4: Updates on legislation 4.1 Changes in UK and EU legislation in force relating to export licensing Table 4.1 Amendments to export control legislation in 2025: 1. Title: The Export Control (Amendment) Regulations 2025 Reference: 2025 No. 532 Description: These Regulations amend the Export Control Order 2008 and assimilated Council Regulation (EC) No 428/2009 of 5 May 2009 setting up a community regime for the control of exports, transfer, brokering, and transit of dual-use items (Recast) (EUR 2009/428). 2. Title: The Export Control (Amendment) (No. 2) Regulations 2025 Reference: 2025 No. 1197 Description: These Regulations amend the Export Control Order 2008, assimilated Council Regulation (EC) No 428/2009 of 5 May 2009 setting up a Community regime for the control of exports, transfer, brokering and transit of dual-use items (Recast) (EUR 2009/428), and assimilated Regulation (EU) 2019/125 of the European Parliament and of the Council of 16 January 2019 concerning trade in certain goods which could be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment (codification). 3. Title: Commission Delegated Regulation (EU) 2025/2003 of 8 September 2025 amending Regulation (EU) 2021/821 of the European Parliament and of the Council as regards the list of dual-use items Reference: Commission Delegated Regulation (EU) 2025/2003 Description: Updates Annex I of Regulation (EU) 2021/821 for dual-use items subject to control when they are exported from or in transit through Northern Ireland. 4. Title: Regulation (EU) 2025/41 of the European Parliament and of the Council of 19 December 2024 on import, export and transit measures for firearms, essential components and ammunition, implementing Article 10 of the United Nations Protocol against the illicit manufacturing of and trafficking in firearms, their parts and components and ammunition, supplementing the United Nations Convention against Transnational Organised Crime (UN Firearms Protocol) (recast) Reference: Regulation (EU) 2025/41 Description: Recasts the previous Firearms regulation (EU) No 258/2012, for import, export, and transit measures for firearms. Does not come into force for the export of firearms essential components and ammunition until 12 February 2029. 5. Title: Commission Delegated Regulation (EU) 2025/928 of 21 May 2025 amending Regulation (EU) 2019/125 of the European Parliament and of the Council concerning trade in certain goods which could be used for capital punishment, torture or other cruel, inhuman, or degrading treatment or punishment Reference: Commission Delegated Regulation (EU) 2025/928 Description: Updates Annex II and Annex III of Regulation (EU) 2019/125 for trade in goods from Northern Ireland which could be used for capital punishment, torture or other cruel, inhuman, or degrading treatment or punishment. Section 5: External engagement 5.1 Parliamentary engagement Parliamentary oversight of export controls was provided through Business and Trade Committee (BTC), and the Business and Trade Sub-Committee on Economic Security, Arms and Export Controls. In March 2025, ECJU hosted members from the BTC at the Department for Business and Trade offices for an in-person briefing on export control and sanctions policy developments and the ongoing delivery of the LITE system. In July 2025, the Minister of State for Trade Policy and Economic Security, Rt Hon Douglas Alexander MP, and the Chancellor of the Duchy of Lancaster, Rt Hon Pat McFadden MP, gave oral evidence to the BTC Sub-Committee on Economic Security, Arms and Export Controls on UK Economic Security. They were accompanied by the DBT’s Director of Geopolitics and Economic Security Philippa Makepeace and the Deputy National Security Advisor (Economics) Jonathan Black. In September 2025, the Minister of State for Trade Policy, Sir Chris Bryant MP, the Minister of State for Defence Readiness and Industry, Luke Pollard MP, and the Minister of State for the Middle East, North Africa, Afghanistan and Pakistan, Hamish Falconer MP gave oral evidence to the BTC on UK arms exports to Israel. They were accompanied by DBT’s Director of Export Controls and Sanctions Dr Rosemary Pratt, the MOD’s Director – Fixed Wing, Defence, Equipment and Support Keith Bethell CBE, and the FCDO’s Head of the International Humanitarian Law Cell, Ciaran Morrisey. Since then, ECJU has continued to engage with the Committee by providing detailed responses to queries regarding arms export controls. Such engagements have helped ECJU to ensure its processes are robust, and to prioritise improvements, particularly in data and transparency, to ensure adequate scrutiny can take place. 5.2 Raising awareness of export licensing with industry and academia During 2025, ECJU completed a programme of engagement with industry and academia to raise awareness of export controls and changes to legislation, to improve compliance and to facilitate responsible exports. Notices to Exporters in 2025: During 2025, the ECJU published 34 Notices to Exporters providing updates and guidance to exporters on changes to export control legislation, licensing procedures, sanctions implementation, and compliance expectations. Subjects included: • Legislative and Regulatory Updates • Open General Export Licences (OGELs) and General Trade Licences • Sanctions and Russia Related Measures • Compliance, Enforcement and Compound Settlements • Country Specific and Policy Changes Events: ECJU participated in several trade, academia, defence and security events, including: • Security and Policing 2026 event • DSEI 2025 (Defence & Security Equipment International) • Higher Education Export Control Association (HEECA) annual conference • SAE Media Group’s ‘Defence Exports Conference’ • 2025 Defence Procurement Research Technology and Exportability (DPRTE) event • UK Defence and Security Exports (UK DSE) Small to Medium Enterprises (SME) surgeries • Annual Export Controls and Sanctions Symposium in London (15 October 2025, over 300 participants) Online and Helplines: Recorded webinars viewed over 25,000 times. In 2025 the Export Control Helpline received over 2,600 calls and 27,500 emails. The LITE platform support service received over 12,600 enquiries. 5.3 International Outreach • February: Attended the 31st Asian Export Control Seminar in Tokyo. • May: Senior officials visited Beijing for the Export Control Working Group with MOFCOM. • June: Bilateral working group with Indian government officials on export controls. • November: Annual meeting of the ‘Letters of Intent’ group (Germany, France, Italy, Sweden, Spain). • December: UK's accession to the Agreement on Defence Export Controls with Spain, France and Germany. • December: Panel discussion at the EU Export Control Forum in Brussels. 5.4 The End-User Advisory Service During 2025 ECJU finalised 9,827 enquiries (compared to 10,029 in 2024). 1,085 WMD and MEUC ‘Concerns’ letters were sent in 2025 (compared to 905 in 2024 and 1,358 in 2023). Section 6: HM Government support to Allies and Partners 6.1 Gifting The term ’gifting’ is applied to the donation of any export-controlled equipment by HM Government to a foreign government in support of its wider security and foreign policy aims. In 2025, 8 applications to gift equipment (to countries other than Ukraine) were approved. Four were funded via the Integrated Security Fund (ISF) (Senegal, Ghana, Gambia, Sierra Leone) and two via the Defence Assistance Fund (DAF) (Morocco, Kenya). Table 6.1 Gifted controlled equipment in 2025: - Nigeria | Nigerian Army HQ | Counter-Improvised Explosive Device equipment | MOD | £46,000 - Germany | RAF Bruggen Museum | 1 x Jaguar GR1 XX969 with engines and seat; 1 X Tornado GR4 ZD711 with engines and seats | MOD | £40,000 - Morocco | Direction Generale de la Surete Nationale (DGSN) EOD Training Centre | Counter-Improvised Explosive Device equipment | MOD | £54,000 - Kenya | The Humanitarian Peace Support School in Nairobi | Counter-Improvised Explosive Device equipment | MOD | £45,000 - Senegal | Senegal Armed Forces in Dakar | 2 X Furuno Radar FAR2238S-NXT BB | MOD | £95,000 - Ghana | Armed Forces of Ghana | 1 x Halmatic Pacific 22 Rigid Hull Inflatable Boat (RIB) and spares plus 1 x trailer | MOD | £71,000 - Gambia | Armed Forces of Gambia | 2 x Halmatic Pacific 22 Rigid Hull Inflatable Boat (RIB) and spares plus 2 x trailer | MOD | £142,000 - Sierra Leone | Armed Forces of Sierra Leone | 2 x Halmatic Pacific 22 Rigid Hull Inflatable Boat (RIB) and spares plus 2 x trailer | MOD | £142,000 6.2 Government to Government Exports Table 6.2 Government-to-government exports: - Turkey | Typhoon Aircraft & Services | Quantity: 20 Table 6.3 Resales to foreign governments: - Turkey | C130J Aircraft | Quantity: 12 - Brazil | Albion Class Ship | Quantity: 1 - Singapore | Apache Helicopter Inventory | Inventory – multiple lines 6.3 Government to Government Projects Longstanding programme with Saudi Arabia (Typhoon, Tornado, Hawk aircraft, mine countermeasure vessels, munitions, logistics, and manpower support packages). Section 7: International Issues 7.1 Ukraine/Russia In 2025, the UK provided an unprecedented £4.5 billion in military support to Ukraine, including £1.5 billion through the Extraordinary Revenue Acceleration (ERA) loan backed by immobilised Russian sovereign assets. HMG issued 440 licences for Ukraine in 2025, including 44 related to gifting. Gifted controlled equipment to Ukraine in 2025 included: • approximately 1,000 short range surface-to-air and air defence missiles including Storm Shadow and Lightweight Multirole Missiles, as well as several air defence systems • dozens of artillery systems, and more than 150,000 artillery rounds • more than 300 armoured vehicles, protected mobility and logistic support vehicles • hundreds of units of communication, SATCOMS, radar, electronic warfare, GPS systems and surveillance and targeting equipment • dozens of infrastructure and engineering items including generators, maintenance and bridging capabilities • circa 35,000 uncrewed systems • thousands of spares, vehicle spares, ancillaries, parts, tools, support kits, medical items and PPE • hundreds of weapons systems • over 5 million rounds of ammunition including ammunition and anti-armour weapons • dozens of maritime equipment including boats, spares and lifesaving items Sanctions against Russia continued to be enforced under The Russia (Sanctions) (EU Exit) Regulations 2019, utilizing the Common High Priority List (CHPL) to mitigate diversion. 7.2 Israel Throughout 2025 HM Government’s assessment remained that Israel was not committed to upholding International Humanitarian Law in Gaza; licences were refused where there was a risk exports might be used in Gaza military operations. Licences for non-military/humanitarian purposes (PPE for journalists/NGOs, laboratory chemicals, etc.) continued to be approved. UK components for the global F-35 pool were excluded from suspension (challenged in court, but government decision was upheld by High Court and Court of Appeal). A 'Change in Circumstances' review in June 2025 confirmed no relevant licences might be used in Israeli actions in Lebanon or Iran. 7.3 Sudan Over 3,000 old and extant licences were reviewed for risk of diversion to Sudan (e.g. from UAE). No evidence of UK weapons/ammunition being used in Sudan was found. 7.4 Armenia/Azerbaijan On 13 October 2025, the UK lifted its arms embargo on Armenia and Azerbaijan following progress on a peace agreement and upgraded bilateral relations to Strategic Partnerships. 7.5 Thailand/Cambodia Reviewed in light of border clashes (May–July 2025 and Dec 2025). Following the 27 December 2025 ceasefire, licensing resumed with caution. 7.6 Rwanda Following Rwandan advances into eastern DRC in January 2025, HMG revoked 4 SIELs and removed Rwanda as a permitted destination from 2 OIELs and 4 OGELs. 7.7 Madagascar, Nepal and Tanzania Reviews concluded no licences in scope needed suspension, revocation, or amendment. 7.8 Iran On 28 August 2025, snapback sanctions mechanism was triggered under the 2015 nuclear agreement; arms embargo and missile restrictions maintained. 7.9 China Exporters notified of diversion risks to Russia via China/Hong Kong/Macau. Trade approach aligned with the June 2025 China audit. Section 8: UK and International Policy developments 8.1 Military End-Use Control (MEUC) and Emerging Technologies Reviews Reviews concluded in summer 2025 by the National Security Council affirmed the export control system's agility, recommended closer cross-government engagement, greater international coordination, and enhanced guidance for exporters. 8.2 Arms Trade Treaty (ATT) 118 State Parties as of 31 December 2025. In August 2025 (CSP11), the UK promoted agreement for a first 5-year strategy. 8.3 Small Arms and Light Weapons (SALW) and Conventional Ammunition Participation in the Global Framework for Through Life Conventional Ammunition Management; support provided to Nigeria, Somalia, Kazakhstan, and Moldova. 8.4 Nuclear Suppliers Group (NSG) 48 participating governments as of March 2026. Plenary held in Cape Town (21–25 July 2025). 8.5 Zangger Committee 39 member states; UK acts as secretariat. Trigger list reviewed regularly. 8.6 Australia Group (AG) 42 participating states + EU. 40th anniversary Plenary in Sydney in July 2025. 8.7 Missile Technology Control Regime (MTCR) 35 participating states. RPOC meeting held 13–14 May 2025 in France. 8.8 Wassenaar Arrangement (WA) Plenary in December 2025; 40 technical recommendations achieved consensus. 8.9 The Hague Code of Conduct (HCoC) 145 signatories. 8.10 Academic Technology Approval Scheme (ATAS) In 2025, approved 28,370 applications (23,999 students, 4,371 researchers); denied clearance on 1,343 occasions (997 students, 346 researchers). Section 9: Compliance and enforcement 9.1 Compliance ECJU Compliance Inspectorate conducted 383 compliance checks in 2025 (up 41% from 270 in 2024; 244 in 2023). Issued 66 warning letters and 2 licence suspensions in 2025. Compliance check outcomes (2025): - First-time checks (80 total): 33% Compliant (26), 22% Generally compliant (17), 21% Not fully compliant (16), 24% Non-compliant (19) - Routine checks (224 total): 37% Compliant (82), 27% Generally compliant (60), 19% Not fully compliant (42), 18% Non-compliant (40) - Revisits (60 total): 63% Compliant (38), 15% Generally compliant (9), 13% Not fully compliant (8), 8% Non-compliant (5) 9.2 & 9.3 Enforcement - 172 seizures of strategic goods in 2025 (compared to 233 in 2024, 266 in 2023, 177 in 2022, 202 in 2021) - 77 end-use cases where non-listed items were stopped - 4 compound settlements totalling £4,294,409.64 for unlicensed exports - 212 warning letters issued via voluntary disclosures (out of 267 disclosures received) - 95 No Further Action (NFA) letters issued - 10 criminal investigations ongoing in 2025, 4 awaiting trial - 2 positive charging decisions achieved - Convictions in Table 9.8: None in 2025, 2023, 2021. In 2024: EDM Limited (Qatar, £80,000 penalty + £9,359.80 costs). In 2022: VWR International Ltd (Pakistan, £660 fine + £2,650.50 costs). Annex A: The Strategic Export Licensing Criteria (Guidance given under section 9 of the Export Control Act 2002): Criterion One: Respect for the UK’s international obligations and relevant commitments (UN/OSCE sanctions, ATT, NPT/BWC/CWC, CCW/Oslo/Ottawa conventions, AG/MTCR/Zangger/NSG/WA, OSCE principles). Criterion Two: Respect for human rights and fundamental freedoms in destination country and respect for international humanitarian law (risk of internal repression, caution for serious violations, risk of IHL breaches, gender-based violence). Criterion Three: Preservation of internal peace and security. Criterion Four: Preservation of peace and security (armed conflict likelihood, territorial claims, regional instability). Criterion Five: National security of the UK, territories, and friendly/allied countries. Criterion Six: Behaviour of buyer country towards international community (terrorism, transnational crime, international law, non-proliferation). Criterion Seven: Risk of diversion to an undesirable end-user or end-use. Criterion Eight: Compatibility with technical and economic capacity of recipient country. Other Factors: Exceptional circumstances impacting international relations. Annex B: Licence type definitions - Standard Individual Export Licences (SIELs): Specific items to specific consignee/end-user up to specified quantity. Generally valid 2 years (permanent) or 1 year (temporary). - Open Individual Export Licences (OIELs): Multiple shipments of specified items to specified destinations/consignees. Generally valid 5 years (3 years for military to EU or dealer-to-dealer). - Open General Export Licences (OGELs): Pre-published licences for specific items to specific destinations following online registration. - Assimilated General Export Authorisations (GEAs): 6 dual-use GEAs + 1 Torture Regulation GEA in Great Britain. - Union General Export Authorisations (GEAs): 8 dual-use GEAs + 1 Torture Regulation GEA applicable in Northern Ireland. - Standard Individual Trade Control Licences (SITCLs): Trading/brokering specific goods between overseas countries. Valid 2 years. - Open Individual Trade Control Licences (OITCLs): Multiple trading activities between overseas countries. Valid 5 years. - Open General Trade Control Licences (OGTCLs): Pre-published licences for supply of goods outside UK (4 available). - Standard Individual Transhipment Licences (SITLs): Transit/transhipment through UK. Valid 2 years. - Open General Transhipment Licences (OGTLs): Pre-published licences for transit (4 available). - General Trade Licences (GTLs): Pre-published open general licences covering export and trade measures, typically under sanctions. - Technical Assistance Licences: Covers provision of technical assistance (e.g. WMD, sanctions exemptions). - Financial and Brokering Services Licences: Authorisations under sanctions regimes. - Syria Humanitarian Licences: For humanitarian activities in Syria. - Professional and Business Services Licences: Relating to restricted services under Russia sanctions. - Individual Licences for Export-Related Activities / Energy-related goods under Russia sanctions. - Licences for drugs used in execution by lethal injection (Barbiturate anaesthetics: Amobarbital, Secobarbital, Pentobarbital, Thiopental, etc.). - Global Project Licences (GPLs): OIEL form for Framework Agreement Partners (France, Germany, Italy, Spain, Sweden, UK). Annex C: A summary of key changes affecting OGELs in 2025 - February: OGEL (F-35) updated to include Greece. 4 OGELs updated to remove Rwanda (military goods: demonstration; repair/replacement under warranty; PCBs and components; software and source code). - March: Open General Licence (AUKUS Nations) revised to align with US excluded technologies list. - April: OGEL oil and gas exploration updated for continental shelves; General Trade Licence for Syria Sanctions (earthquake relief) revoked. - May: 8 OGELs revised to exclude nuclear power generating and naval nuclear propulsion equipment under ML17g and ML9; 5 OGELs revised to exclude naval nuclear propulsion under ML9. - July: General Trade Licence (Russia Sanctions – Sectoral Software and Technology) first published. - October: Open General Licence (AUKUS Nations) updated text on Authorised User Community and F680 requirements; General trade licence Russia sanctions (sectoral software and technology) reissued with extended validity. Annex D: OGELs and other general licences in force in 2025 Lists all active licences in 2025 including: - Military and dual-use goods open general licences (Diplomatic missions, UK Forces deployed in embargoed/non-embargoed destinations, GCAP, AUKUS) - Dual-use OGELs (Chemicals, Cryptographic Development, India, Exhibition, Repair/Replacement, EU Member States, Information Security, Low Value, Oil and Gas, Technology, PCBs) - Military Goods OGELs (Software/Tech Individual Use, Certified Companies, Exhibition, Repair/Replacement, F-35, Turkish Aerospace TF-X, UK Govt Defence Contracts, US-UK Treaty, Historic Military Goods/Vehicles, Military Components, Collaborative Project Typhoon, A400M, NATO End Use, India, Surplus Vehicles, etc.) - Other types of General Licences (Iraq, Radioactive sources, Russia Sanctions GTLs, Syria Sanctions GTL) - Open General Transhipment Licences (Sporting Guns, Postal Packets, Transhipment Licence) - Open General Trade Control Licences (Category C Goods, Insurance/Re-Insurance, Maritime Anti-Piracy, Small Arms and Light Weapons) - Assimilated General Export Authorisations (GEA001 to GEA006, GEA 2019/125) - Union General Export Authorisations (EU001 to EU008, EU GEA 2019/125)