On 23 July 2025, the Federal Office for Economic Affairs and Export Control (BAFA) published an updated version of General Authorisation No. 42. The background to this is the entry into force of the European Union's 18th package of sanctions on 18 July 2025.
BAFA's AGG No. 42 regulates the provision of enterprise software and certain services to so-called non-sensitive recipients in third countries, particularly in connection with the EU's sanctions against Russia. The new version of AGG 42 will enter into force on 1 August 2025 and brings with it some important changes.
One of the most significant changes is the extension of the period of validity. The authorisation can now be used until 31 March 2027. This is intended to give companies more planning security, especially for longer-term projects in the field of export control.
AGG No. 42: additional user groups permitted
In addition, other user groups are now also permitted to use General Authorisation No. 42. These include private individuals as well as companies, organisations and institutions, provided they are based or registered in a so-called partner country. These countries are listed in Annex VIII of the Russia Embargo Regulation (EU Regulation No. 833/2014).
It is also important to note that the software covered by this authorisation (listed in Annex XXXIX) must be provided from Germany.
The partner countries currently include: the USA, Japan, the United Kingdom, South Korea, Australia, Canada, New Zealand, Norway, Switzerland, Liechtenstein and Iceland.
Extended scope of application (banking sector)
AGG 42 now also covers software for specific purposes in the banking and financial sector, as specified in Annex XXXIX, which was expanded by the 18th EU sanctions package.
Registrations and notifications remain valid
This does not result in any further changes to the content. Registrations and notifications made on the basis of previous versions of General Authorisation No. 42 remain valid.
Link:
Neubekanntgabe der Allgemeinen Genehmigung Nr. 42
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