Regulatory tracker
What changed in the rules that decide who may supply European defence programmes. Each entry gives the official source, one sentence of it copied word for word, and the day we last read it.
Each entry gives the primary source and one sentence of it, copied word for word, and the day we last read it. It is a reading aid for suppliers, not legal advice. Where a point is not settled by a text we could read, the status says unconfirmed. Last checked 18 Oct 2026. Atom feed
Newest event first. Each entry has a link to itself and a line you can copy into a note.
- AdoptedDirective 2009/81/EC
Defence procurement directive: the simplification amendment is adopted by Parliament and Council
The directive amending Directives 2009/43/EC (transfers of defence products within the Union) and 2009/81/EC (defence and security procurement) passed the European Parliament at first reading on 16 September 2026 and was adopted by the Council on 9 October 2026. The Legislative Observatory lists it as awaiting signature. It is not yet published in the Official Journal and not in force. We have not compared the final text with the Commission's proposal.
The institutions have adopted the act; it is not yet in force, or the source does not say it is.
Who is affected. Contracting authorities and suppliers in defence and security procurement under Directive 2009/81/EC; transfers of defence products between Member States.
09/10/2026 Act adopted by Council after Parliament's 1st reading
European Parliament, Legislative Observatory, procedure 2025/0177(COD), key eventsPrimary source(opens in new tab) On this site:Defence tenders
Last checked .
Cite this entry: DefenceGate regulatory tracker, “Defence procurement directive: the simplification amendment is adopted by Parliament and Council” (adopted, event of 2026-10-09; source last checked 2026-10-18). https://defencegatehub.com/regulation#defence-procurement-directive-adopted. Primary source: European Parliament, Legislative Observatory, procedure 2025/0177(COD), key events, https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0177(COD).
- UnconfirmedEDF
EDF: Ukraine's association is pending the signature of the agreement (not confirmed in force)
The EDF call documents of 2026 say, in a footnote to the list of countries associated to the EDF, that participation of entities established in Ukraine is pending the signature of the association agreement to the EDF (10 of 10 call documents read, the latest versions dated 8 September 2026). The Commission's page on support to Ukraine, which carries no date, says Ukraine "has been fully associated" to the European Defence Fund. We found no Official Journal text of the agreement, no Council decision on it and no notice of its entry into force, and steps taken in Ukraine, as the press reports them, do not settle the EU side. Until a primary text settles it, the readiness check treats a company established in Ukraine as conditional on the association agreement for the EDF, and DefenceGate marks no European Defence Fund call as open to Ukraine or as closed to it.
No primary text we could read settles this point; the entry says which.
Who is affected. Ukrainian companies deciding whether to join a consortium for an EDF call, and EU coordinators who would take them in.
Participation of entities established in Ukraine is pending the signature of the association agreement to EDF (see countries currently negotiating association agreements below).
European Commission, EDF call document EDF-2026-DA (version 1.3 of 8 September 2026), section 6, footnote to "Eligible participants"; the same footnote is in the other nine EDF call documents of 2026. Also: European Commission, DG DEFIS, Support to Ukraine (page without a date; read on 18 October 2026)Primary source(opens in new tab) On this site:EDF eligibility rulesReadiness check: EDFEDF callsGlossary: open to Ukraine
Last checked .
Cite this entry: DefenceGate regulatory tracker, “EDF: Ukraine's association is pending the signature of the agreement (not confirmed in force)” (unconfirmed, event of 2026-09-08; source last checked 2026-10-18). https://defencegatehub.com/regulation#edf-ukraine-in-force-unconfirmed. Primary source: European Commission, EDF call document EDF-2026-DA (version 1.3 of 8 September 2026), section 6, footnote to "Eligible participants"; the same footnote is in the other nine EDF call documents of 2026. Also: European Commission, DG DEFIS, Support to Ukraine (page without a date; read on 18 October 2026), https://ec.europa.eu/info/funding-tenders/opportunities/docs/2021-2027/edf/wp-call/2026/call-fiche_edf-2026-da_en.pdf.
- AdoptedSAFE
SAFE: the agreement with Canada is concluded
The Council approved the agreement between the European Union and Canada on the participation of Canadian legal entities and Canadian products in SAFE procurement on 15 June 2026 (Decision (EU) 2026/1381, published 18 June 2026). According to that decision, the agreement was signed on 14 February 2026 and has been applied provisionally from 13 April 2026; the agreement itself is published as OJ L 2026/445 (3 March 2026). Its Article 5 sets the conditions: a Canadian legal entity must be established in Canada and have its executive management structures in Canada, the Union, an EEA EFTA State or Ukraine, and must not be controlled by a third country (a guarantee verified by a Member State is the derogation); components originating in Canada may exceed 35 % of the component cost, at least 20 % must originate in the Union, an EEA EFTA State or Ukraine, and the cost of components from third countries may not exceed the cost of those from the Union, an EEA EFTA State or Ukraine, and in any case 35 %. The decision says the date of entry into force will be published in the Official Journal by the Council's General Secretariat; we have not found that notice. The readiness check treats a Canadian company as conditional for SAFE on these terms.
The institutions have adopted the act; it is not yet in force, or the source does not say it is.
Who is affected. Canadian suppliers, who may take part in SAFE procurement on the agreement's terms, and EU suppliers competing with them.
The Agreement between the European Union and Canada laying down the conditions for the participation of Canadian legal entities and products originating in Canada to procurement under the SAFE Instrument is hereby approved.
Council Decision (EU) 2026/1381 of 15 June 2026, Article 1 and recital (1); Official Journal L, 18.6.2026. The agreement: OJ L 2026/445, Article 5Primary source(opens in new tab) On this site:Readiness check: SAFE
Last checked .
Cite this entry: DefenceGate regulatory tracker, “SAFE: the agreement with Canada is concluded” (adopted, event of 2026-06-15; source last checked 2026-10-18). https://defencegatehub.com/regulation#safe-canada. Primary source: Council Decision (EU) 2026/1381 of 15 June 2026, Article 1 and recital (1); Official Journal L, 18.6.2026. The agreement: OJ L 2026/445, Article 5, https://publications.europa.eu/resource/celex/32026D1381.
- In forceEDIP
EDIP common procurement: only contracting authorities, international organisations, SEAPs and the EDA may apply
Under Article 11(2) of Regulation (EU) 2025/2643 only contracting authorities of Member States or associated countries, international organisations, SEAPs (structures for European armament programmes) and the European Defence Agency are eligible for common procurement actions. A company or a research body cannot apply to a call of that kind (the EDIP calls whose topic code contains CPA); it can take part in other roles, such as associated partner or subcontractor, as the call documents say. Industrial reinforcement actions (Article 12) are not under this rule.
The act is published and in force.
Who is affected. Companies that look at the EDIP common procurement calls (topic codes EDF-EDIP-P-...-FNLC-CPA-...) as applicants, and the contracting authorities that would lead them.
Only the following legal entities shall be eligible for common procurement actions:
Regulation (EU) 2025/2643, Article 11(2); Official Journal L, 29.12.2025Primary source(opens in new tab) On this site:EDIP eligibility rulesReadiness check: EDIP
Last checked .
Cite this entry: DefenceGate regulatory tracker, “EDIP common procurement: only contracting authorities, international organisations, SEAPs and the EDA may apply” (in force, event of 2025-12-30; source last checked 2026-10-18). https://defencegatehub.com/regulation#edip-common-procurement-applicants. Primary source: Regulation (EU) 2025/2643, Article 11(2); Official Journal L, 29.12.2025, https://publications.europa.eu/resource/celex/32025R2643.
- In forceEDIP
EDIP Regulation in force: EUR 1.2 billion for the Programme and EUR 300 million for Ukraine
Regulation (EU) 2025/2643 establishing the European Defence Industry Programme was adopted on 16 December 2025 and published on 29 December 2025, so it entered into force on 30 December 2025. For 30 December 2025 to 31 December 2027 the Programme has EUR 1 200 000 000 in current prices and the Ukraine Support Instrument EUR 300 000 000 in current prices (Article 3), plus additional contributions.
The act is published and in force.
Who is affected. Suppliers in EDIP common procurement, industrial reinforcement and supporting actions, and Ukrainian and EU suppliers in the Ukraine Support Instrument.
The financial envelopes for the implementation of the Programme for the period from 30 December 2025 to 31 December 2027 shall be composed of: (a) EUR 1 200 000 000 in current prices; and (b) additional contributions in accordance with Article 5.
Regulation (EU) 2025/2643, Article 3(1); Official Journal L, 29.12.2025Primary source(opens in new tab) On this site:EDIP eligibility rulesReadiness check: EDIP
Last checked .
Cite this entry: DefenceGate regulatory tracker, “EDIP Regulation in force: EUR 1.2 billion for the Programme and EUR 300 million for Ukraine” (in force, event of 2025-12-30; source last checked 2026-10-18). https://defencegatehub.com/regulation#edip-in-force. Primary source: Regulation (EU) 2025/2643, Article 3(1); Official Journal L, 29.12.2025, https://publications.europa.eu/resource/celex/32025R2643.
- In forceEDIP
EDIP: at most 35 % of component cost from outside the Union and associated countries
For EDIP procurement supported by Union funding the cost of components originating outside the Union and associated countries may not exceed 35 % of the estimated cost of the components of the end product, and no component may come from a third country that contravenes the security and defence interests of the Union and its Member States. Article 10(4) sets the same share for industrial reinforcement actions. The readiness check applies it (rule EDIP-ORIGIN-35).
The act is published and in force.
Who is affected. Manufacturers and component suppliers in EDIP common procurement and industrial reinforcement actions.
For procurement carried out pursuant to Articles 11, 13 and 35 which is supported by Union funding, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the end product.
Regulation (EU) 2025/2643, Article 10(3)Primary source(opens in new tab) On this site:EDIP eligibility rules
Last checked .
Cite this entry: DefenceGate regulatory tracker, “EDIP: at most 35 % of component cost from outside the Union and associated countries” (in force, event of 2025-12-30; source last checked 2026-10-18). https://defencegatehub.com/regulation#edip-origin-35. Primary source: Regulation (EU) 2025/2643, Article 10(3), https://publications.europa.eu/resource/celex/32025R2643.
- In forceEDIP
Ukraine Support Instrument: open to entities established in Ukraine
Under the Ukraine Support Instrument of EDIP only legal entities established in the Union or in Ukraine, with their executive management structures in the Union or in Ukraine, are eligible for funding. Entities established in the non-government-controlled areas of Ukraine are not. DefenceGate marks the funding calls of this instrument as open to Ukraine.
The act is published and in force.
Who is affected. Ukrainian and EU companies applying to calls of the Ukraine Support Instrument (their topic codes start with EDF-EDIP-USI).
Only legal entities established in the Union or in Ukraine and having their executive management structures in the Union or in Ukraine shall be eligible to be recipients of Union funding under this Regulation.
Regulation (EU) 2025/2643, Article 26(1)Primary source(opens in new tab) On this site:Readiness check: Ukraine Support InstrumentFunding calls open to UkraineGlossary: open to Ukraine
Last checked .
Cite this entry: DefenceGate regulatory tracker, “Ukraine Support Instrument: open to entities established in Ukraine” (in force, event of 2025-12-30; source last checked 2026-10-18). https://defencegatehub.com/regulation#usi-open-to-ukraine. Primary source: Regulation (EU) 2025/2643, Article 26(1), https://publications.europa.eu/resource/celex/32025R2643.
- In forceEDIP
Ukraine Support Instrument: at most 35 % of component cost from outside the Union and Ukraine
For procurement supported under the Ukraine Support Instrument the cost of components originating outside the Union and Ukraine may not exceed 35 % of the estimated cost of the components of the end product, and no component may come from a third country that contravenes the security and defence interests of the Union and its Member States. Article 27(4) sets the same share for industrial reinforcement actions. The readiness check applies it (rule USI-ORIGIN-35).
The act is published and in force.
Who is affected. Manufacturers and component suppliers in calls of the Ukraine Support Instrument.
For procurement carried out pursuant to paragraph 1, points (a) and (c), which is supported by Union funding, the cost of components originating outside the Union and Ukraine shall not be higher than 35 % of the estimated cost of the components of the end product.
Regulation (EU) 2025/2643, Article 27(3)Primary source(opens in new tab) On this site:Readiness check: Ukraine Support Instrument
Last checked .
Cite this entry: DefenceGate regulatory tracker, “Ukraine Support Instrument: at most 35 % of component cost from outside the Union and Ukraine” (in force, event of 2025-12-30; source last checked 2026-10-18). https://defencegatehub.com/regulation#usi-origin-35. Primary source: Regulation (EU) 2025/2643, Article 27(3), https://publications.europa.eu/resource/celex/32025R2643.
- In forceEDF
EDF: Ukraine can be an associated country
Regulation (EU) 2025/2653, published on 22 December 2025 and in force from 23 December 2025, replaced Article 5 of the European Defence Fund Regulation. The Fund is now open to the participation of EEA EFTA members, and of Ukraine in accordance with the conditions laid down in the EU-Ukraine Association Agreement. The text makes Ukraine's participation possible; it does not say that the conditions are met (next entry).
The act is published and in force.
Who is affected. Ukrainian companies and EU companies that would form consortia with them in EDF calls.
Ukraine, in accordance with the conditions laid down in the EU-Ukraine Association Agreement.
Regulation (EU) 2025/2653, Article 3(1), replacing Article 5 of Regulation (EU) 2021/697Primary source(opens in new tab) On this site:EDF eligibility rulesReadiness check: EDFGlossary: open to Ukraine
Last checked .
Cite this entry: DefenceGate regulatory tracker, “EDF: Ukraine can be an associated country” (in force, event of 2025-12-23; source last checked 2026-10-18). https://defencegatehub.com/regulation#edf-ukraine-legal-basis. Primary source: Regulation (EU) 2025/2653, Article 3(1), replacing Article 5 of Regulation (EU) 2021/697, https://publications.europa.eu/resource/celex/32025R2653.
- UnconfirmedSAFE
SAFE: no agreement with the United Kingdom (UK government statement of 1 December 2025)
On 18 September 2025 the Council authorised the Commission to open negotiations with the United Kingdom and with Canada on their participation in SAFE (Decision (EU) 2025/2134). For Canada they ended in the agreement above. For the United Kingdom, a written statement of the UK government to Parliament on 1 December 2025 (HCWS1114) says the UK and the EU had not been able to conclude the negotiations with an agreement, and that UK companies continue to have access to SAFE under standard third-country terms, which the statement puts at up to 35 % of their content. That matches Article 16 of the SAFE Regulation, which treats United Kingdom entities like those of any other third country. We found no later primary text (an agreement, a signature or a new round), so what holds after 1 December 2025 is unconfirmed.
No primary text we could read settles this point; the entry says which.
Who is affected. United Kingdom suppliers, and EU suppliers that work with them in SAFE procurements.
However, we have not been able to conclude these negotiations with an agreement.
UK Parliament, written statement HCWS1114, Statement on UK-EU Relations, Paymaster General and Minister for the Cabinet Office, 1 December 2025 (text read through the Parliament's public written-statements API on 18 October 2026; the web page itself is behind a bot check)Primary source(opens in new tab) On this site:Readiness check: SAFE
Last checked .
Cite this entry: DefenceGate regulatory tracker, “SAFE: no agreement with the United Kingdom (UK government statement of 1 December 2025)” (unconfirmed, event of 2025-12-01; source last checked 2026-10-18). https://defencegatehub.com/regulation#safe-uk-unconfirmed. Primary source: UK Parliament, written statement HCWS1114, Statement on UK-EU Relations, Paymaster General and Minister for the Cabinet Office, 1 December 2025 (text read through the Parliament's public written-statements API on 18 October 2026; the web page itself is behind a bot check), https://questions-statements.parliament.uk/written-statements/detail/2025-12-01/hcws1114.
- AnnouncedDirective 2009/81/EC
Defence procurement directive: a fuller revision is announced
The Commission says the Defence Readiness Roadmap of October 2025 announced the upcoming revision of the legal framework of Directive 2009/81/EC, a separate initiative from the simplification amendment above. We found no published proposal at the date checked, so we state neither its content nor whether it will include a preference for European products.
The Commission has said it will propose; no proposal is published.
Who is affected. Contracting authorities and suppliers in defence and security procurement.
the Defence Readiness Roadmap of October 2025 announced the upcoming revision of the legal framework.
European Commission, DG DEFIS, Simplifying EU rules on defence and sensitive security procurement, 25 November 2025Primary source(opens in new tab) Last checked .
Cite this entry: DefenceGate regulatory tracker, “Defence procurement directive: a fuller revision is announced” (announced, event of 2025-11-25; source last checked 2026-10-18). https://defencegatehub.com/regulation#defence-procurement-directive-revision. Primary source: European Commission, DG DEFIS, Simplifying EU rules on defence and sensitive security procurement, 25 November 2025, https://defence-industry-space.ec.europa.eu/simplifying-eu-rules-defence-and-sensitive-security-procurement-2025-11-25_en.
- ProposedDirective 2009/81/EC
Defence procurement directive: the Commission's proposal of 17 June 2025
The Commission proposed to raise the thresholds of Directive 2009/81/EC (point (a) of Article 8 from EUR 443 000 to EUR 900 000, point (b) from EUR 5 538 000 to EUR 7 000 000) and to extend the maximum duration of a framework agreement from 7 to 10 years. These are the figures of the proposal; the adopted text may differ and we have not checked it.
A proposal exists; the institutions have not adopted it.
Who is affected. Contracting authorities and suppliers in defence and security procurement.
The rules governing framework procurement agreements will be clarified, and the maximum duration of a framework agreement will be extended from 7 to 10 years.
Commission proposal COM(2025) 823 final of 17 June 2025, explanatory memorandum; thresholds in the operative textPrimary source(opens in new tab) Last checked .
Cite this entry: DefenceGate regulatory tracker, “Defence procurement directive: the Commission's proposal of 17 June 2025” (proposed, event of 2025-06-17; source last checked 2026-10-18). https://defencegatehub.com/regulation#defence-procurement-directive-proposal. Primary source: Commission proposal COM(2025) 823 final of 17 June 2025, explanatory memorandum; thresholds in the operative text, https://publications.europa.eu/resource/celex/52025PC0823.
- In forceSAFE
SAFE can be opened to other third countries by agreement (Article 17)
The Union may conclude agreements with acceding, candidate and potential candidate countries other than Ukraine, and with other third countries that have a Security and Defence Partnership with the Union, to open SAFE's eligibility conditions to them. Each agreement says how the conditions of Article 16 apply (location of management, control, location of infrastructure, share of components).
The act is published and in force.
Who is affected. Suppliers from countries with a Security and Defence Partnership, and EU suppliers who would meet their competition in SAFE procurements.
The Union may conclude bilateral or multilateral agreements with acceding, potential candidate and candidate countries other than Ukraine and other third countries with which the Union has entered into a Security and Defence Partnership (NBI) in order to open the eligibility conditions referred to in Article 16 to those countries and their territories, in accordance with paragraphs 2 and 3 of this Article.
Council Regulation (EU) 2025/1106, Article 17(1)Primary source(opens in new tab) On this site:Readiness check: SAFE
Last checked .
Cite this entry: DefenceGate regulatory tracker, “SAFE can be opened to other third countries by agreement (Article 17)” (in force, event of 2025-05-29; source last checked 2026-10-18). https://defencegatehub.com/regulation#safe-art17-agreements. Primary source: Council Regulation (EU) 2025/1106, Article 17(1), https://publications.europa.eu/resource/celex/32025R1106.
- In forceSAFE
SAFE: who may be a contractor or subcontractor
Contractors and subcontractors involved in a SAFE common procurement must be established, and have their executive management, in the Union, an EEA EFTA State or Ukraine, and must not be controlled from another third country. Article 16(5) allows a derogation for an entity established in the Union that is controlled from elsewhere, if it was screened under the investment-screening Regulation or provides guarantees verified by the Member State.
The act is published and in force.
Who is affected. Contractors, and the subcontractors involved in a SAFE common procurement: legal entities that provide critical inputs, are allocated at least 15 % of the value of the contract and need access to classified information (Article 16(12)). Other suppliers are not bound by this paragraph, but the components they supply count towards the 35 % limit on the end product.
Contractors and subcontractors involved in the common procurement shall be established and have their executive management structures in the Union, in an EEA EFTA State or in Ukraine.
Council Regulation (EU) 2025/1106, Article 16(3)Primary source(opens in new tab) On this site:Readiness check: SAFE
Last checked .
Cite this entry: DefenceGate regulatory tracker, “SAFE: who may be a contractor or subcontractor” (in force, event of 2025-05-29; source last checked 2026-10-18). https://defencegatehub.com/regulation#safe-establishment. Primary source: Council Regulation (EU) 2025/1106, Article 16(3), https://publications.europa.eu/resource/celex/32025R1106.
- In forceSAFE
SAFE Regulation in force: EUR 150 billion of loans for common defence procurement
Council Regulation (EU) 2025/1106 was adopted on 27 May 2025 and published in the Official Journal on 28 May 2025, so it entered into force on 29 May 2025. The maximum amount of financial assistance in the form of loans under SAFE is EUR 150 000 000 000.
The act is published and in force.
Who is affected. Member States that request SAFE loans, and the contractors and subcontractors in the common procurements those loans pay for.
This Regulation shall enter into force on the day following that of its publication in the Official Journal of the European Union.
Council Regulation (EU) 2025/1106, the final Article; Official Journal L, 28.5.2025Primary source(opens in new tab) On this site:Readiness check: SAFESAFE component rule
Last checked .
Cite this entry: DefenceGate regulatory tracker, “SAFE Regulation in force: EUR 150 billion of loans for common defence procurement” (in force, event of 2025-05-29; source last checked 2026-10-18). https://defencegatehub.com/regulation#safe-in-force. Primary source: Council Regulation (EU) 2025/1106, the final Article; Official Journal L, 28.5.2025, https://publications.europa.eu/resource/celex/32025R1106.
- In forceSAFE
SAFE: at most 35 % of component cost from outside the Union, EEA EFTA States and Ukraine
In a SAFE-supported procurement the cost of components originating outside the Union, the EEA EFTA States and Ukraine may not exceed 35 % of the estimated cost of the components of the end product, and no component may be sourced from a third country that contravenes the security and defence interests of the Union and its Member States. These are two rules: a threshold and a categorical exclusion.
The act is published and in force.
Who is affected. Manufacturers of end products sold in SAFE-financed procurements, and their component suppliers.
The cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the end product. For the purpose of procurements supported by the SAFE instrument, no component shall be sourced from a third country that contravenes the security and defence interests of the Union and its Member States.
Council Regulation (EU) 2025/1106, Article 16(10)Primary source(opens in new tab) On this site:SAFE component ruleReadiness check: SAFE
Last checked .
Cite this entry: DefenceGate regulatory tracker, “SAFE: at most 35 % of component cost from outside the Union, EEA EFTA States and Ukraine” (in force, event of 2025-05-29; source last checked 2026-10-18). https://defencegatehub.com/regulation#safe-origin-35. Primary source: Council Regulation (EU) 2025/1106, Article 16(10), https://publications.europa.eu/resource/celex/32025R1106.