UK Notice to Exporters 2026/19: Updated GCAP Open General Licence and New Open General Export Licence for 'De Minimis' Exports under the Agreement on Defence Export Controls

Mechanism

The Agreement on Defence Export Controls (UK Treaty Series 13.2026, published 10 December 2025) is a multilateral framework among the UK, France, Germany and Spain that streamlines export authorisation for intergovernmental defence programmes and industrial-cooperation projects between the Contracting Parties. Its core operative mechanism is the "de minimis" principle: where the value of a Contracting Party's content integrated into a final system by another Contracting Party stays at or below a 20% threshold, the requested party must issue export/transfer/re-export authorisation "without delay," subject only to a national-security exception.

NTE 2026/19 is the UK's domestic implementation step: it (a) revokes and replaces the existing Open General Licence (Global Combat Air Programme) — the UK-Italy-Japan trilateral next-generation fighter programme, first licensed under OGEL in August 2024 — with an updated version, and (b) creates a wholly new Open General Export Licence specifically for de-minimis exports/transfers to France, Germany and Spain under the Agreement. Both are general licences: eligible exporters registered to use them no longer need to file individual export-licence applications for each covered shipment, which is the practical friction point in multinational defence-industrial programmes (parts crossing partner-nation borders repeatedly during integration, testing and maintenance).

Downstream implications

• Structurally lowers the compliance/licensing-lead-time cost of

parts and sub-systems crossing UK-France-Germany-Spain borders during collaborative defence-programme integration — a direct input cost for primes and Tier 1/2 suppliers on any qualifying programme.

• Extends the UK's existing general-licence approach to multinational

collaborative programmes (previously used for GCAP and the Typhoon collaborative-project OGEL) to a broader treaty-level partner set, making France/Germany/Spain integration procedurally comparable to the GCAP UK-Italy-Japan arrangement.

• Watch for the equivalent French, German and Spanish domestic

implementing instruments under the same Agreement, and for further UK Notices to Exporters extending de-minimis treatment to additional Contracting Parties or programmes.

Open questions

• Whether other Agreement signatories have published, or plan to

publish, their own de-minimis general licences on a comparable timeline.

• Whether the 20% de-minimis threshold is uniform across all

categories of goods/technology or varies by product category — the treaty text (TS 13.2026) is the primary source for detail beyond what this Notice discloses.