The UAE Moves to Country Group A:5: What Exporters Need to Know

What Changed?

Well, well, well…UAE, the country that exporters for years have been warned about for diversion risks, was just upgraded to Country Group A:5 and completely removed from Country Group D, specifically D:3 and D:4.   (Note that Supplement 1 to Part 740 is yet to be updated, but the press release is on the BIS website.)

So, what does this mean for exporters?  As of July 10^th, this change provides access to a broad range of export license exceptions under the EAR and eliminates many destination-based licensing requirements (i.e., No X in the box!).  UAE now joins other close United States’ allies within Country Group A, such as Australia, Canada, Japan, and the United Kingdom.  This status change illustrates the U.S. Government’s designation of the UAE as a U.S. Major Defense Partner and its overall support of U.S. national security and foreign policy objections.

New Opportunities for Exporters

This shift allows exporters to evaluate License Exception STA for their export, reexports and transfers of Commerce-controlled military items; certain commercial satellites and spacecraft; and dual-use items useful in oil and gas production, desalination, civil nuclear power generation, and/or other items available to Country Group A:5 destinations license-free.  Enabling exporters to evaluate STA for their exports to the UAE will support key UAE commercial and infrastructure needs and better equip the UAE defense establishment to support U.S. interests in the Middle East.  BIS justified this change as “warranted in light of the ongoing U.S.-UAE military partnership and the UAE’s commitment to preventing the diversion and misuse of sensitive U.S. technology.”

This update eliminates certain restrictions for UAE UAV programs.  Of most interest is that approved UAE entities are eligible to receive advanced computing technologies without the previously required BIS export license (keeping in mind that this includes AI chips and servers), which is consistent with the U.S.-UAE Artificial Intelligence Cooperation framework signed in May 2025.  The UAE continues to reaffirm its commitment to make matching investments in the U.S. AI digital infrastructure buildout.

Next Steps for Exporters

With this change, exporters should reevaluate their export license determination for their controlled items to the UAE.  Need support or assistance in understanding how this change affects your export program? Contact us today for a free consultation.