Executive Summary
- What’s new: BIS published a final rule expanding the items that can be exported to the UAE without the need for a U.S. export license. The rule went into effect on July 10, 2026.
- Why it matters: The rule is a meaningful liberalization of U.S. export controls on the UAE, including seven license exemptions and permitting the shipment of advanced graphics processing units (GPUs) and servers, with some limitations.
- What to do next: Companies will want to assess whether new license exceptions apply to pending or planned UAE transactions; verify whether the ultimate consignee and all end users are approved in Supplement No. 8 for the specific authorization claimed; and continue full restricted-party, end-use, sanctions and recordkeeping reviews. Companies in the UAE (including subsidiaries of U.S. AI and other companies) can assess whether they want to submit a request to BIS to become an approved Supplement No. 8 entity.
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Background
On July 14, 2026, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) published a final rule enabling potentially significant quantities of additional exports to the United Arab Emirates (UAE) without an export license under the Export Administration Regulations (EAR).
The rule liberalized the UAE’s designation under the EAR’s list of “Country Groups” (15 C.F.R. 740, Supplement 1), which means that more items will be eligible for shipment to the UAE under a license exception. Specifically, the rule (i) removed the UAE from Country Groups D:3 and D:4, which restrict the availability of license exceptions for exports to countries identified for Chemical and Biological Weapons (CB) and Missile Technology (MT) proliferation concerns, respectively; (ii) added the UAE (with an asterisk) to Country Group A:5, which lists countries that are eligible for one of the EAR’s most significant license exceptions — License Exception Strategic Trade Authorization (STA); and (iii) established a new Supplement No. 8 to Part 740 of the EAR to identify the UAE ultimate consignees and end users approved for specified License Exception STA.
The rule also established license-free treatment for shipments of certain advanced-computing integrated circuits to companies in the UAE listed in Supplement No. 8.
As rationale for the change, BIS cited the UAE’s close military and commercial relationship with the United States, including the UAE’s designation as a U.S. Major Defense Partner, its role as the largest U.S. trading partner in the Middle East and its participation in the May 2025 U.S.-UAE technology cooperation framework covering AI and semiconductors.
Removal From Country Groups D:3 and D:4
The UAE’s removal from Country Groups D:3 and D:4 means that shipments to the UAE of certain export-controlled items, including certain rockets and drones, can be made without a license in some circumstances, in reliance on license exceptions such as:
- Exception TMP for Temporary Imports, Exports, Reexports, and Transfers.
- Exception GOV for Governments and International Organizations.
- Exception TSU for unrestricted Technology and Software – Unrestricted.
- Exception AVS for Aircraft, Vessels and Spacecraft.
- Exception APR for Additional Permissive Reexports.
- Exception ACE for Authorized Cybersecurity Exports.
- Exception BAG for Baggage.
A permitted shipment is subject to the conditions of each exception.
As a result of this update, shipments to the UAE also will no longer be subject to end-use restrictions related to missile systems, and U.S. persons will not be prohibited from providing “support” to missile-related end uses in the UAE.
Addition to Country Group A:5
The rule also adds the UAE to Country Group A:5, which identifies countries eligible for License Exception STA — one of the most favorable exceptions in the EAR. License Exception STA allows for shipments of items controlled for the following reasons: national security (NS category); restricting chemical and biological weapons (CB category); nuclear nonproliferation (NP category); regional stability (RS category), crime control (CC category); and significant items (SI category) — including deemed exports and deemed reexports to UAE nationals, provided all STA conditions and general license-exception restrictions are met.
The benefits of the UAE’s A:5 status, however, are limited to explicitly approved entities. Specifically, the rule limits reliance on License Exception STA for UAE shipments to transactions in which the ultimate consignee and all end users are approved UAE entities listed in a new supplement to the EAR (15 CFR 740, Supplement No. 8).
License-Free Shipments of Advanced Computing Items
The rule also established license-free treatment for the same Supplement 8 entities for shipments of certain advanced semiconductors and computers classified under ECCNs 3A090.a, 4A090.a, 3A090.b, 4A090.b (and related “.z” paragraph items). Where Supplement No. 8 provides license-free treatment for advanced-computing items, that approval does not override end-use or end-user license requirements in Part 744 or any other transaction-specific restrictions.
Supplement No. 8: Approved Entities and Scope of Authorization
Supplement No. 8 identifies three categories of UAE ultimate consignees and end users as eligible for License Exception STA and for license-free shipments of the advanced computing items identified above:
a. UAE government agencies. UAE government agencies, including the Ministry of Defense and Armed Forces, are approved to receive the advanced-computing items identified above without a license, and to receive other eligible items in reliance on License Exception STA. This approval does not extend to UAE state-owned corporations or to government contractors/grantees of UAE government agencies.
b. Group 42 Holding Ltd. (G42) and Core42 Technology Projects LLC (Core42). G42 and Core42 are approved for license-free receipt of the advanced computing items identified above, but not for License Exception STA. The rule provides that if these entities “fail to become U.S. companies on or before April 10, 2027,” their eligibility under Supplement No. 8 will expire.
c. Certain U.S.-headquartered AI companies and subsidiaries. Several U.S. companies, together with their subsidiaries, are approved for both license-free receipt of the advanced computing items identified above and full use of License Exception STA. The provision is intended to facilitate UAE data center build-outs for these companies by allowing qualifying exports of specified advanced-computing items and other eligible items on the Commerce Control List (CCL) under License Exception STA.Advisory Opinion Process for Additional Entities
The rule allows other entities located in the UAE, including “U.S.-headquartered AI entities,” to seek approval for advanced-computing access, License Exception STA or both by submitting a BIS advisory opinion request.Implications for Industry
The rule should facilitate potentially significant additional exports to the UAE without a license, particularly regarding advanced semiconductors and services, subject to compliance considerations. Companies exporting, reexporting or transferring EAR-controlled items involving the UAE will need to verify that for License Exception STA or advanced-computing transactions, the ultimate consignee and every end user — not just the purchaser — appear on Supplement No. 8 for the specific authorization claimed. Entities in the UAE seeking approval to receive advanced computing items license-free or wishing to become approved for use of License Exception STA can submit a request for an advisory opinion to BIS. Companies added to Supplement No. 8 will also have fewer mandatory filing requirements to the Committee on Foreign Investment in the United States (CFIUS) for investments in U.S. businesses.
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