Most notably, the Federal Council also lifted the autonomous, sanctions-related prohibitions and authorization requirements for exports to Ukraine, in particular for armaments and dual-use goods, as well as goods for the military or technological enhancement or development of the defense and security sector. Crucially, this amendment applies strictly to sanctions law: standard export control licensing requirements under the War Materiel Act (WMA) and the Goods Control Act (GCA) remain fully applicable.

Background

In 2022, Switzerland not only adopted the EU's sanctions regime regarding Russia, but also enacted autonomous export restrictions under the Ukraine-Ordinance anchored in Swiss neutrality law. Under this regime, the export of war materiel and specific military goods to Ukraine was prohibited, while exports of dual-use goods and certain non-controlled goods of military or technological relevance were subject to an individual authorization requirement from the State Secretariat for Economic Affairs (SECO) (Articles 2a, 4 and 5 Ukraine-Ordinance). In practice, SECO routinely imposed ancillary reporting obligations on authorized transactions. These sanctions-specific requirements applied in addition to, and independently of, the general export control regime under the WMA and the GCA.

Lifting of sanctions-based prohibitions and authorization requirements

Effective 1 September 2026, Articles 2a, 4 and 5 of the Ukraine-Ordinance, in particular, have been substantively amended to eliminate this sanctions-related prohibition and authorization regime for exports to Ukraine.

The Swiss Federal Council justifies this deregulation by noting that the general export control framework (WMA and GCA) already provides robust and sufficient control mechanisms. Furthermore, as confirmed by the Federal Council's press release of 22 April 2026, export transactions falling exclusively under Articles 2a, 4 and 5 Ukraine-Ordinance – without triggering WMA or GCA requirements – were consistently authorized in practice, rendering the separate sanctions layer administratively redundant.

Practical implications for exporters

• Elimination of duplicate sanctions filings: Companies exporting war materiel and dual-use goods to Ukraine no longer require an additional sanctions permit from SECO under Articles 2a, 4 or 5 Ukraine-Ordinance.
• Status of existing general exemption authorizations and reporting obligations: General exemption authorizations issued by SECO for sanctions-related exports to Ukraine have largely become obsolete. While associated obligations (e.g., reporting obligations) should lapse ex lege to the extent they are strictly tethered to the repealed authorization requirements, exporters must ensure that historical reporting obligations for completed transactions have been formally satisfied.

Recommended next steps

• Screen against remaining export control regimes: The revision alters sanctions law exclusively. Exporters must continue to classify relevant items under the WMA and GCA. Any export meeting statutory control thresholds still requires standard export control licensing from SECO.
• Review product scope and cross-sanctions applicability: Verify on a case-by-case basis whether goods remain restricted under other sanctions provisions, such as targeted asset freezes, specific service bans, transshipment or diversion controls involving third countries or any other restrictions requiring end-user/end-use controls.
• Clarify legacy authorizations with SECO: For outstanding general exemption authorizations or open reporting cycles, submit a concise written enquiry to SECO to confirm that all administrative and reporting files have been formally closed without residual liability.