On July 14, 2026, the Bureau of Industry and Security (BIS) published a final rule “Enhanced Favorable Treatment for the United Arab Emirates under the Export Administration Regulations” (Final Rule) that amends the Export Administration Regulations (EAR) (15 C.F.R. Parts 730-774) to significantly improve the status of the United Arab Emirates (UAE) under the EAR, and relatedly eases certain license requirements, in recognition of the UAE’s status as a U.S. Major Defense Partner and its support in advancing U.S. national security interests. BIS explained in an associated press release that the “special status under the EAR is warranted in light of the ongoing U.S.-UAE military partnership and the UAE’s commitment to preventing the diversion and misuse of sensitive U.S. technology.”

The Final Rule removes the UAE from Country Groups D:3 and D:4 and adds it to Country Group A:5. In so doing, the Final Rule:

• Maintains an export license requirement on the export, reexport or transfer of advanced computing items destined to or within the UAE, except for the following entities, listed on the “Approved Ultimate Consignees and End Users for Advanced Computing Items and/or License Exception STA in the UAE” in a new Supplement No. 8 to part 740 of the EAR (Approved Entities):
  • UAE government agencies, including the Ministry of Defense and Armed Forces (excluding UAE state-owned corporations or contractors or grantees of UAE government agencies).
  • Approved UAE commercial entities who apply for and receive approval through the Advisory Opinion process in EAR Section 748.3(c), based on a case-by-case assessment of U.S. national security and foreign policy interests, including the applicant’s compliance capabilities and track record:
    • G42 and Core42 are pre-approved for a period of 270 days, after which these entities must become “U.S. companies” or apply for an Advisory Opinion to remain approved.
  • Certain U.S.-headquartered artificial intelligence (AI) entities and their subsidiaries (including their UAE-based subsidiaries). The current list of approved U.S.-headquartered AI entities is: Amazon.com Inc; Apple Inc; Google LLC, Meta Platforms Inc; Microsoft Corporation; OpenAI Group PBC; Oracle Corporation; and X.AI LLC.
• Creates a new footnote 5 to the Country Groups in Supplement No. 1 to Part 740, which states that license exception Strategic Trade Authorization (STA) is only available for export, reexport or transfers to/within the UAE to certain of the Approved Entities.
• Lifts several other restrictions associated with Country Group D status on the UAE, including restrictions on the use of license exceptions Temporary Imports, Exports, Reexports and Transfers (in-country) (TMP), Governments, International Organizations, International Inspections Under the Chemical Weapons Convention, and the International Space Station (GOV), Additional Permissive Reexports (APR), Technology and Software - Unrestricted (TSU), Aircraft, Vessels and Spacecraft (AVS), Advanced Computing Authorized (ACE) and Baggage (BAG), and end-use restrictions on the export, reexport or transfer to or within the UAE of any items for use in, or U.S. person support of, certain missile systems, rockets or Unmanned Aerial Vehicles (UAVs).

Implications for Exports, Reexports or Transfers of Advanced Computing Items

The Trump administration has enforced the Regional Stability (RS) export license requirements in place prior to the issuance of the Biden-era AI Diffusion Rule, as noted in its May 13, 2025 press release and confirmed in the preamble of the Final Rule. This means that an export license is required for the export, reexport or transfer of all advanced computing items (e.g., 3A090.a and 3A090.b items, and related Export Control Classification Numbers (ECCNs)) to or within destinations specified in Country Groups D:1, D:4 and D:5, excluding destinations also specified in Country Groups A:5 and A:6.

The Final Rule removes the UAE from Country Group D:4, consistent with the close U.S.-UAE military and commercial partnership, and in recognition of the UAE’s commitment to implementing effective export controls to protect sensitive technology. However, the Final Rule retains the license requirement for the export, reexport or transfer of advanced computing items to or within the UAE, unless destined for the Approved Entities, which can now receive the advanced computing items license free.

Notably, the regulatory text reflected in the EAR only amends the license requirement in Section 742.6(a)(6)(iii)(B) to create a license-free path for receipt of “.b” advanced computing items (i.e., 3A090.b) by Approved Entities, and not “.a” items (i.e., 3A090.a) (see redline in the Appendix below). With regard to “.a” items, BIS makes it clear in the preamble to the Final Rule that “BIS will continue enforcing the license requirements for exports, reexports, and transfers (in-country) of [“.a” items] to or within the UAE, except when the ultimate consignee and all end users are [Approved Entities].” Accordingly, as provided in the preamble and regulatory text, Approved Entities in the UAE may now receive both “.a” and “.b” advanced computing items license-free, provided that the ultimate consignees and all end users are Approved Entities authorized to receive advanced computing items license-free. Purchasers, intermediate consignees, and other parties to the transaction need not be listed as Approved Entities to take advantage of this license-free pathway for advanced computing items, as long as the ultimate consignee and all end-users are Approved Entities. BIS notes, however, that approval in Supplement No. 8 to part 740 does not overcome the end-use and end-user based license requirements in part 744 of the EAR.

The Final Rule specifically identifies two UAE entities, G42 and Core42, as Approved Entities. This Approved Entity status expires after 270 days unless G42 and Core42 either become “U.S. companies” or apply via BIS’s Advisory Opinion process to remain Approved Entities. The Final Rule also identifies the UAE entity MGX as benefiting from a favorable license review policy for BIS license applications involving the export of advanced semiconductors and servers to the UAE but does not list MGX as an Approved Entity.

Finally, other commercial entities in the UAE seeking to become Approved Entities may apply through the Advisory Opinion process outlined in EAR Section 748.3(c). BIS will review these requests within 30 days and will do so in consultation with the Secretary of State and the Assistant to the President for National Security Affairs. Within five days of a determination, BIS will notify the entity requesting the advisory opinion and, if approved, initiate the process to add the entity to the list of Approved Entities. Addition to the list of Approved Entities may be limited by scope, e.g., for the receipt of advanced computing items license-free and/or for the use of license exception STA. For example, Core42 and G42 are only authorized to receive advanced computing items license-free but are not authorized for use of license exception STA.

Implications for Use of License Exception STA

By adding the UAE to Country Group A:5, certain Approved Entities are now eligible to receive items controlled for national security (NS), chemical and biological weapons (CB), nuclear nonproliferation (NP), regional stability (RS), crime control (CC) and significant items (SI) reasons pursuant to license exception STA. The same parties can rely on license exception STA to authorize deemed exports and deemed reexports to UAE nationals for technology and source code controlled for NS, CB, NP, RS, CC and SI reasons. This enables license-free access to certain items, including military (600 series) items, commercial space-related (500 series) items, and certain advanced dual-use items usable in semiconductor packaging, oil and gas production, and civil nuclear power generation, subject to the conditions in license exception STA.

The Approved Entities currently eligible for license exception STA are UAE government agencies and the listed U.S.-headquartered AI companies. Core42 and G42 are not eligible for license exception STA.

Other Implications

• License Exceptions
  • With removal from Country Groups D:3 and D:4, additional exports, reexports, and transfers (in-country) of chemical and biological (CB)- or missile technology (MT)-controlled items are authorized to the UAE under license exceptions TMP, GOV, TSU, AVS and APR.
  • Additional provisions of License Exceptions ACE and BAG also become available for the UAE.

• End Use/User Controls
  • Rocket systems and unmanned aerial vehicle-related end-use restrictions: Exporters no longer need a license to ship items to the UAE with knowledge that they will be used in certain missile, rocket, or UAV projects, removing a diligence trigger that previously restricted UAE-bound aerospace transactions (See EAR Section 744.3(a)).
  • U.S. person controls: U.S. persons may now provide certain support, such as servicing, financing, and shipping, to covered missile and UAV activities in the UAE without the specific authorization previously required (See EAR Section 744.6(b)).