On July 14, 2026, the US Bureau of Industry and Security (BIS) published a final rule that significantly upgrades the Export Administration Regulations (EAR) treatment of the United Arab Emirates, effective July 10, 2026. The rule opens new paths for UAE-related exports, eases some export licensing requirements, and reduces certain mandatory Committee on Foreign Investment in the United States (CFIUS) filing obligations. The practical benefit will depend on the item, end user, end use, license exception conditions, and, where relevant, Supplement No. 8 approval.
The rule moves the UAE from Country Groups D:3 and D:4 to Country Group A:5, which is one of the least restrictive designations under the EAR. This change makes additional provisions of several license exceptions available for items controlled for Chemical/Biological (CB) and Missile Technology (MT) reasons. MT controls restrict exports of items that could contribute to the development or production of missiles, rockets, unmanned aerial vehicles (UAVs), space launch vehicles, and other delivery systems capable of carrying weapons of mass destruction. CB controls restrict items usable in chemical and biological weapons development, including certain chemicals, pathogens, toxins, and related equipment.
As a practical matter, the rule removes restrictions on the use of certain license exceptions to the UAE, including TMP, GOV, TSU, AVS, and APR, where the relevant conditions are satisfied. Additional provisions of License Exceptions ACE and BAG also become available. The rule also removes the UAE from certain missile-related end-use and US-person support restrictions under §§ 744.3 and 744.6(b)(2). It does not, however, eliminate other Part 744 end-use or end-user restrictions.
Together these changes allow certain CB and MT items to go to the UAE license-free in certain circumstances and remove end-user restrictions based on knowledge that an item would be used in missiles and UAVs. Companies exporting CB- and MT-controlled items to the UAE should reassess whether license exceptions now apply to their shipments.
The rule makes the UAE eligible for License Exception STA (§ 740.20), but only where the ultimate consignee and all end users appear in Supplement No. 8 to Part 740 and are specified as approved for STA. The rule states that all ultimate consignees and end users of an item must be listed in Supplement No. 8 for the transaction to qualify for STA — not just the primary recipient of the item. UAE government agencies, including the Ministry of Defense and Armed Forces, qualify for full STA use. That authorization does not extend to state-owned corporations, contractors, or grantees unless BIS separately lists them.
This is an important distinction: Companies dealing with UAE state-linked commercial entities cannot assume STA eligibility based on government approval alone. Defense and technology companies should carefully verify whether their UAE counterparties appear in Supplement No. 8 before relying on STA.
Because License Exceptions TSU and STA are listed among eligible license exceptions for CFIUS purposes, this rule also eases mandatory CFIUS filing requirements for transactions that meet the provisions of those license exceptions. Companies involved in UAE-related investments or joint ventures should evaluate whether these changes affect their CFIUS analysis.
Advanced computing items controlled under ECCNs 3A090.a, 4A090.a, and related “.z” entries still require a license for export to Country Groups D:1, D:4, and D:5. Although BIS removed the UAE from Country Group D:4, the rule makes clear that BIS will continue to enforce the license requirement against the UAE unless the end user appears in Supplement No. 8 to Part 740. In other words, the Country Group upgrade does not by itself free up AI chip exports.
Supplement No. 8 currently identifies several categories of approved recipients:
Other ultimate consignees and end users in the UAE that do not yet appear in Supplement No. 8 can seek approval by submitting an advisory opinion request under § 748.3(c). The rule commits BIS to a 30-day decision, with notification to the applicant within five days after that. BIS notes it will evaluate requests based on US national security and foreign policy interests, including the applicant’s compliance capabilities and track record.
The rule does not specify what information to include in the request, but applicants should provide enough detail to address these factors, including compliance program documentation, organizational structure, and end-use descriptions. As with any new regulatory process, how BIS will implement this process in practice remains to be seen. Companies considering an advisory opinion request should monitor for further BIS guidance.
BIS also separately stated that it will favorably review export license applications involving MGX (a UAE AI investment firm) for semiconductors and servers, even though it did not list MGX in Supplement No. 8. This signals that BIS may extend favorable treatment to additional UAE entities through licensing policy rather than formal Supplement No. 8 listing.
We are following these developments closely. If you have questions about how this rule affects your operations, please contact the Latham lawyer with whom you normally consult or one of the authors of this Client Alert.