- Relevant Laws
- Law No. 549-IV (2003) on state control over international transfers of military and dual-use goods; Law No. 222-VIII (2015) on licensing of economic activity; Law No. 4616-VI (2012) on security activity; Law No. 808-IX on defence procurement; Criminal Code art. 447 (mercenary activity). No framework law on private military services abroad.
- Licensing Requirements
- 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.
- Armed Contractor Rules
- 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.
- Export Control
- 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.
- Dual-Use Rules
- National control list aligned with the EU/Wassenaar regimes, administered by SSECU under Law No. 549-IV.
- Foreign Investment Screening
- No comprehensive FDI screening regime; strategic assets are controlled ad hoc, with no dedicated review of foreign ownership of PMC or defence-service providers.
- Defense Procurement
- 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.
- Classified Contract Rules
- State-secrets legislation with SBU-led facility and personnel clearances; wartime confidentiality regimes constrain public verification.
- Technology Transfer Restrictions
- 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.
- Sanctions & End-Use Monitoring
- National sanctions system and SSECU end-use certificates; no post-authorisation monitoring designed for services performed abroad.
- Government Agencies
- SSECU, Ministry of Defence, Ministry of Foreign Affairs, SBU, Ministry of Internal Affairs / National Police, Prosecutor General’s Office, Ministry of Strategic Industries, Defence Procurement Agency, Brave1.
- Lessons For Ukraine
- Ukraine already holds most of the required instruments — export-control licensing, activity licensing, security-activity rules and criminal liability. The report’s conclusion is that the missing element is a framework law joining them: a general PMC licence plus contract-specific authorisation routed through a single lead authority.
- Gaps Or Risks For Ukraine
- No statutory definition of private military services; no contract-level authorisation for foreign clients; no interagency review procedure; no continuing monitoring, suspension or revocation regime; no FDI screening over the sector.