Guide

Export Control (Dual-Use Technology)

Export of goods, software, and technology with both civil and military applications requires licensing. Particularly relevant for encryption, advanced computing, AI, and surveillance technologies.

Technology & Digital UK-wide

UK export controls apply to any business exporting goods, software, technology, or providing technical assistance that could have military or weapons-related applications. Controls cover physical exports, electronic transfers (including email and cloud storage), and verbal disclosures to persons outside the UK.

Key principle: If your goods, software, or technology appear on the UK Strategic Export Control Lists, you need a licence before exporting. Even if they are not listed, catch-all controls may apply if you know or suspect the items could be used for weapons of mass destruction or military purposes.

The Export Control Joint Unit (ECJU), part of the Department for Business and Trade, administers licensing. HMRC enforces at the border and prosecutes offences.

What is controlled

The UK Strategic Export Control Lists comprise:

  • UK Military List (Schedule 2 of the Export Control Order 2008) — 22 categories (ML1-ML22) covering military goods, software, and technology
  • UK Dual-Use List (Annex I of the assimilated Dual-Use Regulation) — 10 categories (0-9) covering goods usable for both civil and military purposes, based on the Wassenaar Arrangement
  • UK national controls (Schedule 3) — additional UK-specific controls including on radioactive sources and emerging technologies

The dual-use categories are Nuclear materials (0), Special materials (1), Materials processing (2), Electronics (3), Computers (4), Telecommunications and information security (5), Sensors and lasers (6), Navigation and avionics (7), Marine (8), Aerospace and propulsion (9).

The lists are updated approximately twice per year. From November 2025, new '500 series' entries integrate emerging technology controls (quantum, cryogenic, semiconductor manufacturing) into the main dual-use framework.

Intangible transfers and cloud computing

Export controls apply equally to intangible technology transfers. You need a licence whether you transfer controlled technology by:

  • Electronic means: email, file transfer, remote access to servers
  • Verbal means: telephone calls, video conferences, in-person briefings overseas
  • Visual means: reading a document, viewing a demonstration
  • Cloud storage: making controlled technology available to persons outside the UK via cloud computing services, even if the server is physically in the UK

Important: The UK does not have 'deemed exports'. Transferring controlled technology to a non-UK national solely within the UK is not considered an export. However, sharing that same technology with someone overseas (including by granting remote access) does require a licence.

Types of export licence

There are no fees for export licence applications. Three main licence types are available:

  • Open General Export Licences (OGELs): Pre-published licences for specified items to specified destinations. Register on SPIRE and comply with conditions — no individual application needed. Subject to ECJU compliance audits.
  • Standard Individual Export Licence (SIEL): For a specific shipment of specified items to a named consignee and end-user. Valid for 2 years. Processing target — 70% within 20 working days, 99% within 60 working days.
  • Open Individual Export Licence (OIEL): For repeat exports of specified items. Usually requires an established track record (replacing at least 20 SIELs per year). Valid up to 5 years.

Always check whether an OGEL covers your export first — it is the quickest and simplest route.

End-use controls (catch-all)

Even if your goods are not on the control lists, you need a licence if:

  • The ECJU has informed you (via an 'informing letter') that a licence is required for a particular export
  • You know or suspect the goods may be intended for WMD purposes (chemical, biological, nuclear weapons, or missiles capable of delivering them)
  • The goods could be used for military purposes in connection with a destination subject to a UN or OSCE arms embargo, or listed in Schedule 4 of the Export Control Order 2008

Red flags that should trigger concern include a customer reluctant to provide end-use information, product capability not matching the stated end-use, refusal to provide an end-user certificate, orders inconsistent with the customer's normal business, or unusual shipping routes or payment terms.

Sanctions interaction

Sanctions override export licences. Even if you hold a valid export licence, exports are prohibited if they breach applicable sanctions regulations. Always check the UK Sanctions List before any export.

From 28 January 2026, the UK Sanctions List (maintained by FCDO) is the single source for all UK sanctions designations, replacing the previous OFSI Consolidated List.

Russia sanctions are the most comprehensive, prohibiting export of all dual-use goods, all military goods, and a wide range of industrial goods. HMRC compound settlements for Russia sanctions breaches have exceeded £1.1 million in a single case.

Maximum criminal penalty (on indictment)
Up to 10 years imprisonment and/or unlimited fine
Maximum criminal penalty (summary)
Up to 12 months imprisonment and/or fine
HMRC compound settlements (Jan-Mar 2025)
Close to £3.7 million across multiple cases
Record-keeping requirement
Minimum 4 years (ECJU recommends 6 years)
SIEL processing target
70% within 20 working days, 99% within 60 working days
Licence application fees
No fees charged for any export licence application

ℹ️ Penalties are severe

  1. Check if your goods are controlled

    Use the ECJU Goods Checker tool on SPIRE, or request a classification from ECJU if uncertain. Do not confuse HMRC commodity codes with export control ratings — they serve different purposes.

  2. Check the UK Sanctions List

    Before any export, search the UK Sanctions List to ensure the destination, end-user, and goods are not subject to sanctions.

  3. Check for an applicable OGEL

    Use the OGEL Checker on SPIRE to see if a pre-published open licence covers your export. If so, register and comply with conditions.

  4. Apply for a SIEL or OIEL if no OGEL applies

    Register on LITE (or SPIRE for exceptions) and submit your application with end-user undertaking. Allow 20-60 working days for processing.

  5. Set up an internal compliance programme

    Appoint a responsible person, screen customers against sanctions lists, establish record-keeping, and train staff on red flags. Follow the ECJU compliance code of practice.

  6. Keep export records for at least 6 years

    Record all exports including dates, goods, quantities, destinations, end-users, and licence details. ECJU audits open licence holders.

Apply for export licence (SPIRE)

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