Key Takeaways: The UAE’s reclassification to Country Group A:5 in the U.S. Export Administration Regulations (“EAR”) is one of the most significant expansions of U.S. export licensing flexibility extended to a Middle Eastern partner in recent years. Exporters should promptly assess whether existing licensed shipments or pending BIS applications can now be restructured under a license exception under the EAR. This easing of export controls on the UAE likely will benefit U.S. aerospace and defense, oil and gas, and advanced technology sectors, including AI-enabling semiconductors.
What Happened: On July 10, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced a final rule granting the United Arab Emirates (“UAE”) significantly more favorable treatment under the EAR by moving the UAE to the more permissive Country Group A:5. BIS cited the UAE’s status as a “U.S. Major Defense Partner” and its support in advancing U.S. national security interests, including Operation Epic Fury, as the basis for the regulatory change.
Scope: Specifically, BIS removed the UAE from EAR Country Groups D:3 and D:4 lists, which will, among other things, eliminate restrictions on support for the UAE’s unmanned vehicle programs and simultaneously reclassified the UAE as Country Group A:5. The A:5 designation would ordinarily provide the UAE with eligibility for license exception Strategic Trade Authorization (“STA”), authorizing BIS exports, reexports, and in-country transfers for:
- specific 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 other sectors.
However, the change comes with a limitation – License Exception STA can only be used for exports to the UAE government or select approved commercial entities (currently two UAE entities and eight major U.S. technology companies) and their subsidiaries, which are identified in a supplement listing Approved Ultimate Consignee and End Users for Advanced Computing Items and/or License Exception STA in the UAE. All other UAE-based recipients cannot rely on License Exception STA and are subject to standard license requirements. UAE commercial entities may submit requests to be included on the supplement.
There is a similar carveout for the UAE in the export controls on AI-related semiconductors and similar items – no license is required only if it is an approved end user identified on the supplement. This posture is consistent with the U.S.-UAE Artificial Intelligence Cooperation framework signed in May 2025, where BIS approved the UAE government and certain companies to receive advanced computing items, including AI chips and servers, in the UAE subject to the UAE’s reaffirmed commitment to make matching investments in U.S. AI digital infrastructure development.
Rationale for Change: This BIS considered this special status under the EAR warranted, citing the ongoing U.S.-UAE military partnership and the UAE’s commitment to preventing the diversion and misuse of sensitive U.S. technology.
Implications for Exporters: For exporters and trade compliance professionals, this rulemaking warrants attention. Companies with open export licenses or pending applications for UAE-destined shipments should assess whether the changed country group status permits restructuring under a license exception – including the newly available license exception STA – reducing administrative burden and processing time. Commercial entities may also consider requesting that BIS add them to the supplement identifying companies eligible for this more permissive treatment.
Crowell & Moring will continue to monitor BIS guidance and further regulatory developments related to the UAE’s expanded access to U.S.-controlled technology.