UK expands export licences for GCAP

The Export Control Joint Unit has revised the UK’s Open General Licence for the Global Combat Air Programme and introduced a separate licence for qualifying low-value UK content in multinational defence systems.

The changes reflect two related pressures in collaborative weapons development: controlled technology has to remain within defined security and export boundaries, while engineering teams and suppliers still need to move hardware, software, and technical data across borders quickly enough to keep multinational programmes functioning.

The revised GCAP licence replaces the version introduced in August 2024. It adds Supply Chain Nations, provides for authorised Observer Nation activity, and updates programme terminology as GCAP moves further into development and its industrial structure expands beyond the governments and principal companies in the UK, Japan, and Italy.

Subject to its conditions, the licence can cover specified military and dual-use goods, software, and technology transferred for development, production, testing and evaluation, through-life support, use, disposal, or decommissioning. Exporters still have to be eligible participants and comply with the registration and record-keeping requirements attached to the licence.

That framework becomes more important as detailed design work spreads through the supply chain. A combat-air programme requires specialists in propulsion, electronics, sensors, structures, software, materials, manufacturing equipment, and test systems, and those suppliers may need repeated access to controlled data before a component ever reaches production.

Using individual licences for every routine transfer can add delay each time a design file, test item, software package, or controlled component crosses a border. An Open General Licence does not remove export control, but it establishes a repeatable route for defined transactions so companies do not have to recreate the licensing process for every qualifying movement.

The addition of Supply Chain Nations acknowledges that programme activity will not remain confined to the three core countries. Specialist capability may be sourced elsewhere, while production and support arrangements can bring additional jurisdictions into the programme as work packages mature.

Observer Nation provisions address a different stage of participation. A government may need limited access to programme activity before it becomes a formal development partner or customer, but even preliminary technical engagement can involve controlled information. The revised licence creates a mechanism for authorised activity without treating observer status as unrestricted access.

Existing GCAP users still have compliance responsibilities. Exporters must remain registered, retain the evidence required by ECJU, and ensure both the goods and destination fall within the licence. Companies that cannot meet the conditions still require another export-control route.

The separate Defence Export Controls ‘De-Minimis’ licence addresses systems in which UK-origin content represents only a limited proportion of a final product developed or integrated elsewhere. It applies to specified exports to France, Germany, and Spain under the relevant defence export-control agreement.

The threshold is set at no more than 20% of the value of the final system, subject to the licence’s detailed conditions and destination restrictions. The purpose is to prevent a relatively small UK-origin subsystem, component, or software element from creating a disproportionate licensing dependency around an otherwise foreign-led product.

That situation is increasingly common in European defence manufacturing. A missile, radar, aircraft subsystem, or vehicle can contain components from several countries, and the final exporter may not be the country that produced one sensitive electronic module or software package. Without an agreed de-minimis route, a relatively minor contribution can still bring the complete product into another national licensing process.

The new licence does not make those UK-origin elements uncontrolled. It creates a pre-defined route where the value threshold, destination, product type, and other conditions are met, while retaining records and restrictions around onward movement.

For manufacturers, predictability is as important as speed. Engineering schedules are easier to manage when companies know in advance which transfers can use an open licence and which will require specific approval. Uncertainty around export permissions can delay design reviews, integration testing, supplier changes, and production troubleshooting even where the technical work itself is on schedule.

GCAP makes the issue particularly visible because the programme is being built as an international industrial structure from the outset. Hardware and software are expected to move repeatedly between companies and countries during design, test, production, upgrade, and support, making export-control architecture part of programme infrastructure rather than an administrative task at the end of development.

The licensing changes therefore reduce friction without removing the boundaries around sensitive technology. Their effectiveness will depend on whether companies can use them consistently across the programme and whether the scope evolves with the actual supply chain rather than lagging behind it.

As GCAP moves into deeper engineering work, that balance will become harder to maintain. The programme needs rapid movement of controlled information to function as one development effort, while each partner still has national obligations around technology security and export policy. The revised licences are designed to give routine, authorised transfers a clearer path through that tension.