On 1 April 2026, the Federal Office for Economic Affairs and Export Control (BAFA) introduced significant changes to the General Authorisations (AGG). General Authorisations are issued by the authorities. By using AGGs, all exports that meet the conditions of the relevant General Authorisation are automatically authorised.
Extension of the AGG
All General Authorisations (AGG) issued by the BAFA (with the exception of No. 30) have been extended until 31 March 2027, provided they would have expired on 31 March 2026.
New AGG No. 47 in the defence sector
On 1 April 2026, General Authorisation No. 47 of the BAFA (the so-called ‘complementary authorisation’) will come into force. It applies to exports or transfers in connection with the War Weapons Control Act (KrWaffKontrG) and thus replaces the individual export/transfer licences from the BAFA previously required for this purpose.
If the requirements of AGG No. 47 are met, in future only a licence under the War Weapons Control Act will need to be applied for from the Federal Ministry for Economic Affairs and Energy for the export or transfer of war weapons. An additional BAFA licence for each individual export or transfer project will then no longer be required, as this is replaced by AGG No. 47.
This is subject to registration on the ELAN-K2 portal and compliance with half-yearly reporting obligations. The regulation will initially apply until April 2028.
To the BAFA information sheet (AGG No. 47)
Further changes regarding defence equipment
The list of privileged destination countries has been expanded to include, amongst others, India and, in certain circumstances, the Republic of Korea, Singapore and the Philippines. In addition, existing General Authorisations have been amended in terms of content, technical details and wording, for example with regard to reporting requirements and clarifications concerning the number of permitted intermediate recipients.
Changes regarding dual-use goods
Kyrgyzstan has been removed from the list of privileged destination countries for certain General Authorisations. At the same time, a new ancillary provision has been introduced: companies must submit a sanctions compliance declaration prior to the first use of certain General Authorisations, document this for each General Authorisation and ensure compliance with the relevant EU sanctions requirements.
BAFA guidance on the sanctions compliance declaration
Links:
BAFA guidance on the sanctions compliance declaration
BAFA information sheet (AGG No. 47)
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