Private Defense Regulation by Country

Jurisdictions Side By Side

Country Comparison

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Compare how selected jurisdictions regulate private military, private security, defense-service and defense-industrial companies across fourteen categories. Select two to four jurisdictions; each cell carries a status, confidence level, last-verified date and linked primary source, and expands for further legal detail. Where the dataset holds no researched entry, the cell reads “Insufficient verified information.”

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Choose between 2 and 4 jurisdictions (4 selected).

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Full Regulatory Matrix

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Comparison matrix

Jurisdictions × regulatory tools. Cells summarize each mechanism to highlight elements Ukraine could adapt.

Jurisdiction	Export control	FDI screening	Defense procurement	Licensing	Armed contractors / PSC	Dual-use technology	Classified contracts	Tech-transfer restrictions	Sanctions / end-use monitoring	Verification
United StatesUS	ITAR (State/DDTC) for defense articles; EAR (Commerce/BIS) for dual-use.	CFIUS review under FIRRMA for foreign investment in sensitive defense/tech firms.	FAR/DFARS federal procurement rules; DoD contracting oversight; competition and bid protest system.	Registration and licensing with DDTC for defense manufacturers/exporters; state-level PSC licensing.	No single PMC statute: control is layered through contract clauses (FAR 52.225-26, DFARS 252.225-7039), DoD policy (DoDI 3020.50 / 32 C.F.R. pt. 159) and criminal jurisdiction abroad under MEJA and UCMJ art. 2(a)(10). Military training and advice to foreign forces is separately licensed as a “defense service” under ITAR § 120.32.	EAR Commerce Control List; end-use/end-user restrictions; emerging tech controls.	NISPOM industrial security; facility clearances (FCL) and personnel clearances.	ITAR technical data controls; deemed-export rules for foreign nationals.	OFAC sanctions; Blue Lantern (State) and Sentinel (Commerce) end-use monitoring programs.	Partially Verified
United KingdomUK	Strategic export licensing via ECJU; Consolidated EU/UK Strategic Export Control Lists.	NSI Act 2021 mandatory notification regime across 17 sensitive sectors including defense.	MOD Defence and Security Public Contracts Regulations; single-source contract regulation.	SIA licensing for domestic private security; self-regulation for overseas PSCs (SCEG/ICoCA).	No dedicated extraterritorial PMC statute; reliance on self-regulation and Montreux/ICoC.	UK dual-use export control list aligned with Wassenaar; end-use catch-all controls.	List X facility security clearances; Government Security Classifications policy.	Controls on transfer of technology and technical assistance under Export Control Order 2008.	OFSI sanctions enforcement; end-use undertakings in licenses.	Partially Verified
FranceFR	War materiel exports authorized by CIEEMG under Prime Minister; defense articles licensed by DGA.	IEF regime under Ministry of Economy for foreign investment in sensitive activities including defense.	DGA-led procurement; French defense procurement code; preference for domestic and European industrial base.	CNAPS licensing for private security; specific licensing for war materiel manufacturers.	Criminal prohibition on mercenary activity (Loi 2003-340); private maritime security narrowly authorized.	EU Dual-Use Regulation 2021/821 implementation via SBDU (Service des biens à double usage).	Habilitation défense clearances; IGI 1300 protection of national defense secrets.	Intangible technology transfer controls; controls on foreign nationals in sensitive facilities.	EU sanctions implementation; end-use certificates required for war materiel exports.	Partially Verified
European UnionEU	EU Dual-Use Regulation with harmonized control list; member states retain arms-export authority under Common Position.	Regulation 2019/452 cooperation mechanism; member-state screening regimes for defense/dual-use.	Directive 2009/81/EC for defense and security procurement; EDF and EDIP industrial support instruments.	Member-state licensing; Intra-EU Transfers Directive 2009/43/EC simplifies transfers between member states.	No unified EU PMC regime; member-state law governs; EU supports Montreux/ICoC.	Regulation 2021/821 introduces cyber-surveillance controls and human-rights criteria.	Council Decision 2013/488/EU on protection of EU classified information; national security clearances mutually recognized.	Technical assistance and brokering controls under dual-use regulation.	EU restrictive measures regime; end-user statements required under national implementations.	Partially Verified
IsraelIL	DECA (Defense Export Control Agency) under MoD licenses defense marketing and exports.	Advisory committee for national-security review of foreign investment in sensitive sectors.	MoD procurement with strong domestic preference; MAFAT R&D coordination; IDF requirements-driven.	Marketing and export licenses under DECA; separate licensing for private security firms.	Restrictions on Israeli nationals providing military services abroad without permit.	Dual-use controls administered jointly by MoD and Ministry of Economy.	Malmab (Directorate of Security of the Defense Establishment) governs classified industrial security.	Strict controls on transfer of cyber and defense know-how; extraterritorial reach for Israeli persons.	End-use undertakings; export destinations screened; recent tightening of cyber-surveillance exports.	Partially Verified
TürkiyeTR	Defense export licensing under SSB (Presidency of Defense Industries) and Ministry of National Defense.	Sector-specific approvals for defense; general FDI liberal but defense requires MoD/SSB consent.	SSB-led centralized procurement; strong domestic-content and offset requirements.	Production permits from MoD; facility security clearances; PSC licensing under Law 5188.	Domestic PSCs regulated under Law 5188; overseas armed contractor activity restricted.	Dual-use controls aligned with Wassenaar; Ministry of Trade coordination.	Facility Security Clearance regime under MoD; personnel security investigations.	Offset and technology-transfer clauses mandated in major procurement contracts.	End-user certificates; case-by-case export approvals; independent sanctions posture.	Partially Verified
DenmarkDK	War materiel export licenses issued by Ministry of Justice; dual-use by Danish Business Authority.	Investment Screening Act 2021 mandatory pre-approval for defense and other sensitive sectors.	EU Directive 2009/81 implementation; centralized procurement via Danish Defence Acquisition and Logistics Organisation.	Manufacturing licenses for war materiel; private security licensing under national law.	No dedicated PMC statute; general criminal law and Montreux Document support.	EU Regulation 2021/821 implementation; catch-all controls.	PET/FE clearance procedures; NATO-aligned classification handling.	Technology transfer controls under dual-use regime; end-use verification.	EU sanctions implementation; end-use certificates.	Partially Verified
SwitzerlandCH	War materiel and dual-use exports licensed under the War Material Act and Goods Control Act by SECO and the Federal Council for sensitive destinations.	No general defence FDI screening at the time of the report; control operates through export and service authorisations rather than ownership review.	armasuisse procurement under federal procurement law; neutrality policy constrains onward transfer and re-export of Swiss materiel.	PSSA requires companies domiciled in Switzerland to declare private security services provided abroad to the competent federal authority before performing them, and to accede to the International Code of Conduct.	PSSA prohibits direct participation in hostilities and services that would support serious human-rights violations; the authority may open a review and prohibit a declared activity in whole or in part, or attach conditions.	Goods Control Act implements Wassenaar-aligned dual-use controls; catch-all clause for end-uses of concern.	Federal information-security and industrial-security procedures; clearances required for classified defence work.	Technical assistance and brokering controls under the War Material and Goods Control Acts.	Embargo Act implementation of UN/EU measures; non-re-export declarations and end-use undertakings.	Unverified
UkraineUA	SSECU licenses transfers of military and dual-use goods, technologies and services under Law No. 549-IV, including intangible transfers of technology and technical assistance.	No comprehensive FDI screening regime; strategic assets are controlled ad hoc, with no dedicated review of foreign ownership of PMC or defence-service providers.	Law No. 808-IX and the Defence Procurement Agency govern state purchasing; Brave1 supports defence-tech developers. Procurement rules do not regulate services supplied to foreign clients.	Law No. 222-VIII licenses manufacture of and trade in weapons and military equipment; Law No. 4616-VI licenses private security activity (protection of persons and property). Neither licenses the provision of military-support services abroad.	Article 447 of the Criminal Code criminalises recruiting, financing, supplying, training and using mercenaries; the Constitution bars armed formations not envisaged by law. Between criminal prohibition and domestic security licensing there is no lawful, supervised category for overseas military services.	National control list aligned with the EU/Wassenaar regimes, administered by SSECU under Law No. 549-IV.	State-secrets legislation with SBU-led facility and personnel clearances; wartime confidentiality regimes constrain public verification.	Law No. 549-IV covers technologies and technical assistance, giving Ukraine an existing hook for intangible transfers — the report treats this as the natural anchor for PMC contract review rather than a new parallel regime.	National sanctions system and SSECU end-use certificates; no post-authorisation monitoring designed for services performed abroad.	Partially Verified
GermanyDE	War weapons require Federal Government permission to manufacture, transport or market (Basic Law art. 26(2), KrWaffKontrG). Military equipment on the AWV Export List needs an export licence; BAFA is the central licensing authority, including for dual-use goods.	BMWE (economy ministry) screens foreign acquisitions under the AWG/AWV. A sector-specific review (AWV §§ 60–62) covers acquisitions of German defence companies by any foreign investor, including EU investors; a cross-sector review (AWV §§ 55–59) covers non-EU/EFTA acquirers. The defence ministry supports the defence-sector reviews.	Not yet researched — pending verification against a primary official source.	Manufacturing and marketing war weapons requires a permit under KrWaffKontrG § 2. Other activity licensing (including private security) is not yet researched.	Not yet researched — pending verification against a primary official source.	BAFA licenses dual-use exports under EU Regulation 2021/821 and the AWG/AWV.	Not yet researched — pending verification against a primary official source.	Not yet researched — pending verification against a primary official source.	Not yet researched — pending verification against a primary official source.	Partially Verified
PolandPL	Trade abroad in strategic goods (dual-use goods and armaments) is prohibited unless the conditions of the Act of 29 November 2000 are met. The licensing authority has not yet been verified from a primary source.	Under the Act of 24 July 2015 on the control of certain investments, the President of UOKiK (competition authority) reviews acquisitions of significant stakes or control in protected Polish companies by investors from outside the EU, EEA and OECD (regime in force since July 2020).	The Armament Agency (Agencja Uzbrojenia, Ministry of National Defence) defines equipment requirements, initiates R&D and runs procurement of military equipment and services for the Polish Armed Forces, and prepares and supervises offset agreements.	Not yet researched — pending verification against a primary official source.	Not yet researched — pending verification against a primary official source.	Dual-use goods are covered as strategic goods under the Act of 29 November 2000.	Not yet researched — pending verification against a primary official source.	The Act of 29 November 2000 covers technologies and services as well as goods.	Not yet researched — pending verification against a primary official source.	Partially Verified