ECJU · Update · July 15, 2026 · #84

UK Publishes 2025 Strategic Export Controls Annual Report

ECJU published its Strategic Export Controls Annual Report 2025 on 15 July 2026, covering licensing activity, compliance, and enforcement under the Export Control Act 2002 for the 2025 calendar year. Key highlights of the report: 1. Licensing volumes: 14,849 SIEL applications received in 2025; 10,414 issued, 501 refused/rejected, 4 revoked. Refusal rate fell to 3.6% (from 4.6% in 2024). 2. Refusal grounds: Criterion 7 (diversion risk) remained the leading basis (437 cases), followed by MEUC catch-all controls (194) and Criterion 5/national security (113). 3. Performance: Neither the 20-working-day (70%) nor 60-working-day (99%) processing targets were met, attributed to the LITE/SPIRE dual-system transition (87% of SIELs now processed via LITE) and rising case complexity linked to Russia sanctions, Gaza, and dual-use/emerging-tech reviews. 4. Israel/Gaza: ECJU continued refusing licences carrying risk of use in Gaza operations; F-35 component exclusion (except direct-to-Israel parts, still suspended) upheld by High Court and Court of Appeal. 5. Russia/Ukraine: £4.5bn in UK military support to Ukraine in 2025 (incl. £1.5bn via the ERA loan); continued use of the Common High Priority List to flag circumvention risk in third countries. 6. Other geopolitical actions: Armenia/Azerbaijan arms embargo lifted (13 Oct 2025); Rwanda licences revoked/restricted following DRC advances; Iran snapback sanctions triggered (28 Aug 2025, with UK/Germany/France). 7. Enforcement: 4 HMRC compound settlements totaling £4,294,409.64; 212 warning letters from voluntary disclosures; 10 ongoing criminal investigations, 4 awaiting trial.

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ECJU
Action Type
Update

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