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Event Report - War in Sudan: Outside Weapons and What Can Be Done Next (October 8, 2026)

10/13/2026

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On 8 October 2026, 2026, Control Arms and the Forum on the Arms Trade* hosted an online discussion on the role of transferred weapons to the warring parties in Sudan and where to next for efforts to end this conflict.

Video of the event is available at https://youtu.be/i2U6fJdjixI.
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(Correction: at timestamp 18:00 Caroline Buisman meant to identify the Rapid Support Forces (RSF), not the Sudanese Armed Forces (SAF).)
​
Panelists:
  • Navid Kermani, author (recently returned from Sudan, see upcoming book In the Other Direction Now: Dispatches from East Africa)
  • Kholood Khair, Founder and Director, Confluence Advisory 
  • Frank Slijper, Arms Trade Policy Expert, PAX
  • Caroline Buisman, Coordinator, Independent International Fact-Finding Mission for the Sudan
  • Hine-Wai Loose, Director, Control Arms (moderator) 

* The Forum provides a platform for sharing of views but does not itself take positions.

Select recommendations:

We encourage watching the entire video for fuller context. Below are timestamps for discussion of some of the recommendations made by event panelists.
  • Kholood Kermani (35:55-): Justice and accountability must be central, including renewal of Fact-Finding Mission, and forward movement of the ICC process on past and possible cases. Need greater protection of civilians, including empowering local communities, in part because of use of drones against civilians. See also closing remarks (1:00:30-) on international and domestic needs. 
  • Navid Kermani (31:02-): Activists should be more active on Sudan, and especially pressure the UAE at sporting events, in the art business, and other venues. Also should boycott Sudanese gold.  
  • Frank Slijper (27:40-): Arms embargo should be extended to entire country. Countries should end arms supplies and military assistance to the United Arab Emirates and other states violating the embargo, which should be on the agenda for the Arms Trade Treaty.
  • Caroline Buisman (55:51-): The Fact-Finding Mission has called for expanded arms embargo, and prosecution of direct and indirect facilitators of violations.

Suggested additional resources:
On the Fact-Finding Mission
  • "Fuelling Sudan’s conflict: weapons, fighters and external support networks," Report for the UN Independent International Fact-Finding Mission for the Sudan, September 3, 2026.
  • “Sudan: Extend the Fact-Finding Mission’s mandate and ensure adequate resources for investigations and reporting,” civil society letter, August 20, 2026.
On weapons supplies
  • "How has Sudan's drone war adapted to shifting supply lines?" ACLED, June 4, 2026.
  • Stan Brabant, “Who is Fuelling the Sudan 2023 Civil War?” Royal Higher Institute for Defence, October 2025.
  • “European weapons in Sudan (1/5): Bulgarian mortar shells in Darfur’s desert,” France24, April 17, 2025.
  • “Sudan: Abusive Warring Parties Acquire New Weapons,” Amnesty International, September 9, 2024.
  • “New Weapons Fuelling the Sudan Conflict,” Amnesty International, July 25, 2024.
Other
  • Navid Kermani, In the Other Direction Now: Dispatches from East Africa, forthcoming in November.
​​
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Final Report - Webinar - Pathways Through the Worsening Crises In the U.S.-Mexico Relationship (August 18, 2026)

8/26/2026

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Introduction

On August 18, 2026, the webinar "Pathways Through the Worsening Crises In the U.S.-Mexico Relationship" was held, co-organized by Global Exchange, Stop US Arms to Mexico, and the Forum on the Arms Trade.

Panelists

  • Elena Gutiérrez, U.S-Mexico Director, Global Exchange 
  • Josué Martinez Leal, Deputy Coordinator, Oasis De Paz Del Espiritu Santo Amparito Ac
  • John Lindsay-Poland, Coordinator, Project to Stop US Arms to Mexico
  • Marco Castillo, Co-Executive Director, Global Exchange  (moderator)

Video of the event with audio entirely in English  is available at https://youtu.be/QBh2L4ylJTE 
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Quick review of recommendations

(Note: The Forum provides a platform for sharing of views but does not itself take positions.)  

During the recommendations portion of the conversation, Elena Gutiérrez (starting at 28:00) remarked that people in Mexico do not want a U.S. intervention in Mexico, but instead peaceful solutions. The Mexican government does need to address disappearances in Mexico. More broadly, the U.S.-Mexico relationship needs to be cooperative, and not based on militarization. The Stop Arming Cartels Act would be helpful. Judicial cooperation could help combat money laundering. Change punitive approach in drug policy. 

Josué Martinez Leal (starting at 33:50) reminds that we need to remember that we are talking about human lives and their realities. Must recognize connection of weapons and migration. Given that migration won’t stop, current approach only helps organized crime. Need structural reforms in both countries that includes a strategy of safeguarding people.  

John Lindsay-Poland (starting at 38:20) notes that drug addiction is an internal struggle, but current strategy externalizes that struggle and creates approaches that are not productive. Need to have community conversations about where to draw the line on guns since none believe it beneficial to sell guns to cartels. Democratic party members, gun violence prevention movement members, and immigration rights movement members need to make connections because their issues overlap in life. Selling of 50 calibre firearms should not be legal and greater oversight of international gun trade is needed, even as many countries in the region are loosening gun restrictions.

Marco Castillo (starting at 53:00) mentions that border communities, and publics in U.S. and Mexico more generally, want a more cooperative approach, rather than tension. He  mentions the upcoming Binational Peace Summit 2026 taking place in El Paso and Ciudad Juárez from September 18–19 as an example of civil society coming together (registration).
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Informe final - Seminario web - Caminos a Través de las Crisis que se Agravan en la Relación México-Estados Unidos (18 de agosto, 2026)

8/26/2026

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Introducción

El 18 de agosto de 2026 se celebró el seminario web «Caminos a Través de las Crisis que se Agravan en la Relación México-Estados Unidos», organizado conjuntamente por Global Exchange, Stop US Arms to Mexico y el Forum on the Arms Trade.

Panelistas
  • Elena Gutiérrez, Directora para México-EE. UU., Global Exchange
  • Josué Martínez Leal, Subcoordinador, Oasis De Paz Del Espiritu Santo Amparito Ac
  • John Lindsay-Poland, Coordinador, Project to Stop US Arms to Mexico
  • Marco Castillo, Codirector Ejecutivo, Global Exchange (moderador)

El vídeo del evento con audio íntegramente en español está disponible en: https://youtu.be/RoWQx3UAum8 
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Breve resumen de recomendaciones

(Nota: El Forum ofrece un espacio para compartir opiniones, pero no asume posiciones propias.)

Durante la sección de recomendaciones de la conversación, Elena Gutiérrez (a partir del minuto 28:00) señaló que la población mexicana no desea una intervención de Estados Unidos en México, sino soluciones pacíficas. El gobierno mexicano debe abordar la problemática de las desapariciones en el país. En un sentido más amplio, la relación entre Estados Unidos y México debe basarse en la cooperación y no en la militarización. La Ley para Dejar de Armar a los Cárteles (*Stop Arming Cartels Act*) sería de gran utilidad. La cooperación judicial podría ayudar a combatir el lavado de dinero. Es necesario cambiar el enfoque punitivo de la política de drogas.

Josué Martínez Leal (a partir del minuto 33:50) recuerda que estamos hablando de vidas humanas y de sus realidades. Se debe reconocer la conexión entre el tráfico de armas y la migración. Dado que la migración no se detendrá, el enfoque actual solo beneficia al crimen organizado. Se requieren reformas estructurales en ambos países que incluyan una estrategia para proteger a las personas.

John Lindsay-Poland (a partir del minuto 38:20) señala que la drogadicción es una lucha interna, pero la estrategia actual externaliza dicho conflicto y genera enfoques improductivos. Es necesario entablar diálogos comunitarios sobre dónde establecer límites respecto a las armas, ya que nadie considera beneficioso venderlas a los cárteles. Los miembros del Partido Demócrata, del movimiento de prevención de la violencia armada y del movimiento por los derechos de los inmigrantes deben establecer vínculos, pues sus causas se entrelazan en la vida cotidiana. La venta de armas de calibre .50 no debería ser legal y se requiere una mayor supervisión del comercio internacional de armas, incluso cuando muchos países de la región están flexibilizando sus restricciones al respecto.

Marco Castillo (a partir del minuto 53:00) menciona que las comunidades fronterizas, y la opinión pública de Estados Unidos y México en general, desean un enfoque más cooperativo en lugar de uno basado en la tensión. Destaca la próxima Cumbre Binacional por la Paz 2026, que se celebrará en El Paso y Ciudad Juárez los días 18 y 19 de septiembre, como un ejemplo de la unión de la sociedad civil (inscripción).
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Final Report - Webinar A Wretched Anniversary: The Implications of One Year of U.S. Boat Strikes (August 19, 2026)

8/24/2026

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Introduction

On August 19, 2026, the webinar "A Wretched Anniversary: The Implications of One Year of U.S. Boat Strikes" was held, organized by the Washington Office on Latin America (WOLA) and the Forum on the Arms Trade.

Panelists

  • Adam Isacson, Director for Defense Oversight, Washington Office on Latin America (WOLA)
  • María Teresa Ronderos, Director, El Centro Latinoamericano de Investigación Periodística (CLIP - Latin American Center for Investigative Journalism) .
  • Sarah Harrison, Nonresident Fellow, Stimson Center.
  • Annie Shiel, US Director, Center for Civilians in Conflict (CIVIC) (moderator) 

Video of the event is available at https://youtu.be/WIOtbqBgZ8c
Audio traducido al español. (A version of the video with Spanish interpretation is available at:) https://youtu.be/kTq12zvslg0 
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English video
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video en español
Recommendations and Resources

During or following the event, panelists offered the following recommendation and suggested resources. (Note: The Forum provides a platform for sharing of views but does not itself take positions.) 

Adam Isacson
  • Halt all boat strikes immediately, rescind all orders enabling the boat strikes.
  • Reassert Congressional war powers by passing a resolution, within the framework of the 1973 War Powers Resolution, explicitly prohibiting the boat strikes and Operation Southern Spear.
  • Conduct a full investigation into the boat strikes, determine which statutes may have been violated, and, where warranted, launch prosecutions.
  • Remove profit-seeking criminal groups from the State and Defense Departments’ lists of terrorist organizations. Terrorist groups, motivated by ideology or other non-economic goals, are fundamentally different adversaries with far greater antagonism to U.S.-aligned governments. Address organized crime by devoting U.S. resources to supporting prosecutions, investigations, witness protection, judicial reform, prison reform, police reform, transparency measures, and community-level violence prevention initiatives in Latin America and the Caribbean. Place the highest priority on working with regional governments and civil society to break corrupt links between organized crime and government officials at all levels, thereby depriving organized crime of its strongest source of protection and support.
Additional suggested resource:
  • Adam Isacson and John Walsh, “Killing Spree: Extrajudicial executions in the U.S. boat strikes campaign,” Washington Office on Latin America, July 24, 2026. 

María Teresa Ronderos
  • Media should keep trying to put names and stories to these persons, with more detail and giving a human face.
  • Public officers who are fearful now should collect information, so that this will not be forgotten and accountability is possible in the future.
Additional suggested resource:
  • Maria Teresa Ronderos, Jose Luis Peñarredonda, Giannina Segnini, Ronna Risquez, Lorena Meléndez, César Molinares, Juan Pablo Barrientos, Sibylla Brodzinsky, Andrés García, Asha Javeed, “La humanidad detrás de los casi 200 bombardeados por Estados Unidos,” El Centro Latinoamericano de Investigación Periodística (CLIP - Latin American Center for Investigative Journalism), May 12, 2026.  Available in English as “Humanity behind the nearly 200 bombed by the United States.”

Sarah Harrison
  • Congress should speak plainly about the boat strikes. They can do this by: (1) refusing to concede Trump’s lie that this is a war (e.g., do not call the strikes “war crimes”) (2) calling these crimes what they are: murder and crimes against humanity, and (3) decline to debate about which branch gets to decide these killings and instead reiterate Congress has already spoken on this issue in Title 18 and the Uniform Code of Military Justice (UCMJ). 
  • Congress should defund operations at sea and on land in the SOUTHCOM area of responsibility (AOR) if they involve the lethal targeting of drug traffickers. 
  • Foreign and international courts should quietly collect evidence against US officials for these crimes to prepare for future cases to hold the perpetrators accountable. 
  • The General Assembly should request an International Court of Justice (ICJ) advisory opinion on the international law questions involving the boat strikes. 
Additional suggested resources:
  • Tracey Begley, Benjamin R. Farley and Sarah Harrison, “International Accountability for U.S. Crimes in the Caribbean and Pacific," Just Security, May 27, 2026.  
  • Sarah Harrison and Mark Nevitt, "The Caribbean Strikes and the Collapse of Legal Oversight in U.S. Military Operations," Just Security, October 23, 2025.
  • Benjamin Farley, “Why Trump’s Justifications for Drone Killings Fall Short,” Foreign Policy, November 18, 2025. ​
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Uganda

7/13/2026

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This is one of a group of eight country profiles authored by an emerging expert, originally published as part of the "Comparative Study on Arms Trade Transparency" report (see full report). The assessments and opinions expressed are the views of each assessment's author. The Forum does not itself take positions.
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Tabitha R Agaba

Uganda is located in Sub-Saharan Africa, with South Sudan to the north, the Democratic Republic of Congo to the west, Kenya to the east, and Tanzania to the south. Unfortunately, two of its neighbors are involved in ongoing conflicts, which has resulted in Uganda’s complicated relationship with arms control.
 
Uganda is an importer, exporter, and transit hub for arms. In 2024, it was reported that Uganda spent $2,470 on military weapon imports, making it 127 out of 133 weapons importers globally.[1] The main sources of these imports were Saudi Arabia, China and Turkey. The country also manufactures and exports small arms and light weapons. In September 2024, the country held its first defense and security exposition, where it showcased a number of items, including modified AK-47 guns, helmets, high level bullet proof vests, modified tankers and troop carriers.[2]
 
National Transparency and Reporting

Uganda regulates its firearms control through the Ministry of Internal Affairs, while the Ministry of Defence and Veteran Affairs handles the procurement and supplies of military equipment.
 
Uganda's defense budget is among the largest in the country, frequently receiving a greater share of funding than critical sectors such as the ministry of health. Between 2022- 2024, the defense ministry received an average of $1 billion.[3]
 
Uganda doesn't provide public reporting on its arms transfers. In 2018, a report by Conflict Armament Research noted the country had sent weapons to South Sudan. [4] Uganda is a signatory to a few regulatory frameworks, including the UN Programme of Action to Prevent, Combat and Eradicate the Illicit Trade in Small Arms And Light Weapons. It is also a signatory to the Nairobi Protocol on Small Arms and Light Weapons. Though not a signatory to the Arms Trade Treaty, Uganda has been working towards implementation.
 
Uganda doesn't strike a balance between transparency and national interests, but rather prioritizes national interests. Nationally, arms transfers information that is not publicly available or accessible is always accessed through third party research organizations like SIPRI and Conflict Armament Research, among others.
 
Corruption Concerns

The country has been previously implicated by United Nations (UN) reports on its role in arms transfers to neighboring countries, South Sudan and the Democratic Republic of Congo. Uganda has played a critical role in the ongoing conflicts in both countries, despite UN arms embargoes. Regionally, small arms and light weapons (SALW) are accessible and commonly trafficked and smuggled across borders; aiding transnational and cross-border crime, such as wildlife crime, illegal mining, and cattle rustling, among others.
 
The country was implicated in several dubious arms trade deals in the 1990s. Between 1997 and 1999, the government of Uganda purchased tankers from Bulgaria and Romania, anti-aircraft guns from North Korea, and jet fighters from Belarus, all priced suspiciously high, which is common in corrupt deals.[5] Such deals are enabled by the opacity of the arms trade within Uganda. Another example of corruption within the arms trade involved the sale of a surface-to-air missile defense system by an Israeli company to the Ugandan Air force, where bribery was identified.[6]
 
The Role of Civil Society

Whereas there’s limited active engagement from civil society when it comes to the issue of arms trade, it is occasionally addressed through anti-corruption work. However, select non-governmental organizations, including SaferWorld, play a critical role in holding the Ugandan government accountable when it comes to arms, weapons and ammunition. They often don't critique the arms trade, but rather focus on the impact of these weapons themself. Small arms are prevalent in the country as well as the region because they are easily accessible and as such they are easy to move around, particularly with the conflict in Eastern Democratic Republic of Congo, as well as other rebel groups whose base is in the DRC. These organizations work closely with the Ministry of Internal Affairs, through the National Focal Point on Small and Light Weapons. The collaboration efforts between the two is part of the country's wider efforts to combat SALW, but does not extend to other conventional arms.
 
A report by Transparency International on Uganda’s defense and security notes that there is a high corruption risk in this sector. The report noted that the law is robust, yet enforcement remains inconsistent, and therefore procurement and operations remain risky for corruption. The report, which assessed the period between May 2024 through August 2025, indicated that Uganda didn't export any arms but rather imported from Russia, the United States of America, Belarus, France and South Africa.[7]
 
The transparency challenges encountered by the defense and security sector is highest at the operational level, followed by procurement, financial, political, and finally, personnel.[8] The sensitivity of the sector has often been used as a scapegoat for transparency. One of the biggest challenges in the country’s defense spending stems from offset spending and secret spending. These play a key role in obstructing transparency in the defense sector. Despite Parliament’s role of oversight of defense expenditure, the challenges presented by conflict of interest, in addition to influence from the executive, hinder its ability to effectively carry out this role.[9]
 
Regardless of its numerous measures to strengthen transparency frameworks, Uganda struggles with corruption across the board, with the corruption index ranking it 148 out of 182 countries in 2025.[10] This is a drop from its position in 2024. Furthermore, a 2018 survey indicated that 38% of the population had to pay a bribe to access public services.[11]
 
Looking Forward

To redefine transparency in Uganda, the country should adhere to the implementation of more regulatory frameworks like the Arms Trade Treaty.
 
Looking at the data above, the transparency efforts in the country will most likely not improve due to the increased hostile environment around civil society in Uganda. It is important to note that the information used in this report was mainly from non-governmental organisations.
 
Transparency around the arms trade would greatly improve if details on contracts are shared in addition to a clearer bidding process. This would avert issues like the 1997 junk helicopters, and allow citizens and civil society to keep future deals in check.

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Tabitha R Agaba is an independent writer and researcher based in Uganda whose work focuses on issues of transnational crime, crime based illicit financial flows, conflict, the arms trade and international security. Email: [email protected] 


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[1] ‘Military Weapons in Uganda’ (The Observatory of Economic Complexity) <https://oec.world/en/profile/bilateral-product/military-weapons/reporter/uga> accessed 9 July 2026

[2] Blanshe M, ‘Uganda: Defence Industries Come of Age…at What Cost?’ (The Africa Report, 20 September 2024) <https://www.theafricareport.com/362193/uganda-defence-industries-come-of-ageat-what-cost/> accessed 19 June 2026

[3] ibid.

[4] ‘WEAPON SUPPLIES INTO SOUTH SUDAN’S CIVIL WAR | Conflict Armament Research’ (Conflict Armament Research, November 2018) <https://www.conflictarm.com/reports/weapon-supplies-into-south-sudans-civil-war/> accessed 19 June 2026

[5] ‘Guns, Tanks & Jet Fighters – Ugandan Corruption in the 90s’ (Corruption Tracker, 24 January 2023) <https://corruption-tracker.org/case/uganda-90s> accessed 19 June 2026

[6] Dolev, D. and Blau, U. ‘Leak Hints at Corruption in Arms Deal between Israeli Company and Ugandan Air Force’ (The Times of Israel, 27 May 2023) <https://www.timesofisrael.com/leak-hints-at-corruption-in-arms-deal-between-israeli-company-and-ugandan-air-force/> accessed 19 June 2026

[7] ‘Uganda’ (Government Defence Integrity Index) <https://ti-defence.org/gdi/countries/uganda/> accessed 19 June 2026

[8] ibid.

[9] ibid.

[10] ibid.

[11] ‘Uganda: Overview of Corruption and Anti-Corruption’ (U4 Anti-Corruption Resource Centre, 21 May 2018) <https://www.u4.no/publications/uganda-overview-of-corruption-and-anti-corruption-2018> accessed 19 June 2026
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Sudan

7/13/2026

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This is one of a group of eight country profiles authored by an emerging expert, originally published as part of the "Comparative Study on Arms Trade Transparency" report (see full report). The assessments and opinions expressed are the views of each assessment's author. The Forum does not itself take positions.
Picture
Tabitha R Agaba

​Sudan is located in North Africa, with South Sudan as its neighbor to the south, Egypt and Libya to the north, Ethiopia to the southeast, Eritrea to the east, and Chad to the west. South Sudan used to be a part of Sudan until its independence on 9th July 2011.
 
The country has its own military industry that includes an ammunition plant that was opened to produce small arms ammunition in 1960.[1] Its scope of work includes weapons, artillery, ammunition, military vehicles, and military gear, among others.[2]
 
In 2014, the Small Arms Survey named Sudan the third leading arms manufacturer on the African continent.[3] In a bid to export arms, the country participated in the 2015 international defense exhibition and conference in the United Arab Emirates. Its display was described as one of the largest displays at the conference,[4] a practice it has continued since, including in its participation in the 2025 International Defence Industry fair in Istanbul.[5]
 
Sudan has previously received military support that included arms transfers from China, Iran, Iraq, Russia, France, South Africa, Libya, and Chile.[6]
 
Impact of Conflict

The current conflict in the country is between the Rapid Support Forces and the Sudanese Armed forces, a conflict that has drawn in regional allies like Saudi Arabia and the United Arab Emirates. As this latest bout of conflict continues, the military industry in Sudan is under control of the Sudanese Armed forces, while the Rapid Support Forces have continuously attacked them.[7]
 
The current conflict was sparked by a coup in 2021 that saw the military take over the country's leadership. In 2023, war broke out between two factions in the military, the paramilitary Rapid Support Forces and the Sudanese Armed Forces.[8] The Rapid Support Forces have received illicit arms from the United Arab Emirates in exchange for gold.  The Sudanese Armed Forces receive arms from Russia, Belarus and China.[9] A 2024 report by Amnesty International noted that Sudan’s neighbors were players in violating the arms embargo and supplying the country with arms, further blurring the transparency in Sudan’s arms transfers.[10]
 
Overall, Sudan struggles with transparency. The 2019 ouster of President Bashir was triggered by high levels of corruption that contributed to sanctions, high levels of living, state capture and bribery among others. This ouster was taken over by a caretaker government, led by a civilian government, which was later ousted by the military in 2021, leading to a falling out between the Sudanese Armed forces and the Rapid Support Forces, according to Transparency International. The resource notes that land grabbing and secret investment deals, among other factors, have marked the agriculture, energy and environment sectors.[11]
 
Though Sudan manufactures some of its weapons, it imports others. The supply of arms to Sudan has been mainly illegal, because the country has been under an arms embargo since 2004.[12] The black market in arms, particularly in the Darfur region, has also thrived due to the conflict.[13] Calls from the Rapid Support Forces for civilians to carry arms increased access to illicit arms and weakened transparency in arms in Sudan.[14] The arms trade between the RSF and UAE points to economic abuse as Sudanese gold is exploited illegally in exchange for arms
 
In 2023, the Small Arms Survey estimated that there are 3 million weapons in the country.[15] Weapons supplies to Sudan have been facilitated by Chad, Libya, Central African Republic, Uganda, and South Sudan, and through the Red Sea.[16] A report by Amnesty International also noted that arms manufactured in Turkey for civilian use can't easily be traced and often end up in the conflict in Sudan.[17]
 
The arms trade and arms transfers in the country have conflicted with reshaping regional affairs within the region, an example of the influential role of arms. Uganda has previously accused Sudan of supporting the Lord's Resistance Army, a rebel group which terrorized northern Uganda in the 2000s, yet Amnesty International has reported that Uganda is a transit route for arms to Sudan from the United Arab Emirates.
 
Transparency

The country’s level of transparency is difficult to assess as ongoing conflict has undermined state institutions and significantly limited availability of reliable information. Sudan’s transparency is under the spotlight, though adequate information is unavailable due to the breakdown in state structures due from the ongoing conflict in the country.  The country has previously expressed interest in joining the Convention on  Cluster Munitions though it hasn’t signed up despite its participation in its creation and consensus adoption.[18] In 1981 Sudan signed the Convention on Certain Conventional Weapons but never ratified.[19]
 
However, analysis of the arms industry is critical due to its role in the country's state of affairs. In Sudan as in any conflict, the supply of arms is key for armed groups to sustain conflict. When it comes to access to weapons in Sudan, the lines are blurred making transparency difficult with the involvement of third parties such as the use of Chad, Libya and South Sudan as a transit route for arms supply from the UAE into Sudan.[20]
 
Looking forward

Sudan could benefit from more transparency in all sectors, as well as institutional  reform. However, key emphasis should be directed towards the military. Arms transfers are a stepping stone towards peace, though its practicality remains questionable due to the breakdown of monitoring structures. Transparency could start with declaration of sourced arms, clear data on arms exports though all this is subject to the stability of the country. Data on arms access should be part of the peace process negotiations as this would enable transparency on who is supplying the country with arms and where its arms are headed. This clarity would provide support in tracking and addressing illegal arms as well as support efforts to ensure implementation of regulations such as the UN arms embargo.
 
----------------------

Tabitha R Agaba is an independent writer and researcher based in Uganda whose work focuses on issues of transnational crime, crime based illicit financial flows, conflict, the arms trade and international security. Email: [email protected] 

 
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[1] ‘Home | Military Industry Corporation’ (Military Industrial Corporation Sudan)  <http://mic.sd/en/home/homepage> accessed 19 June 2026

[2] ‘Products | Military Industry Corporation’ (Military Industrial Corporation Sudan) <http://mic.sd/en/home/products/1> accessed 19 June 2026

[3]Dabanga, ‘“Sudan’s Military Industry Expanding”: Small Arms Survey’ (Dabanga Radio TV Online, 6 July 2014) <https://www.dabangasudan.org/en/all-news/article/sudan-s-military-industry-expanding-small-arms-survey> accessed 19 June 2026

[4] ‘Sudan “stepping up Efforts” to Sell Weapons Abroad: Report - Radio Tamazuj’ (Radio Tamazuj, 9 March 2015) <https://www.radiotamazuj.org/en/news/article/sudan-stepping-up-efforts-to-sell-weapons-abroad-report> accessed 19 June 2026

[5] Agenzia Fides, ‘AFRICA/SUDAN - Despite the damage suffered by the war, the Sudanese military industry participates in the important Turkish arms fair’ (Agenzia Fides, 28 July 2025) <https://www.fides.org/en/news/76642-AFRICA_SUDAN_Despite_the_damage_suffered_by_the_war_the_Sudanese_military_industry_participates_in_the_important_Turkish_arms_fair> accessed 19 June 2026

[6]Human Rights Watch, ‘Arms Transfers to the Government of Sudan’ (Human Rights Watch, 1998) <https://www.hrw.org/legacy/reports98/sudan/Sudarm988-05.htm> accessed 19 June 2026

[7] Agenzia Fides, ‘AFRICA/SUDAN - Despite the damage suffered by the war, the Sudanese military industry participates in the important Turkish arms fair’ (Agenzia Fides, 28 July 2025) <https://www.fides.org/en/news/76642-AFRICA_SUDAN_Despite_the_damage_suffered_by_the_war_the_Sudanese_military_industry_participates_in_the_important_Turkish_arms_fair> accessed 19 June 2026

[8] ‘Sudan: Overview of Corruption and Anti-Corruption’ (Transparency International Knowledge Hub) <https://knowledgehub.transparency.org/helpdesk/sudan-overview-of-corruption-and-anti-corruption-3> accessed 19 June 2026

[9] Jaeger J, ‘Weapons Fuel Humanitarian Crisis in Sudan’ (Project Ploughshares, 17 September 2024) <https://ploughshares.ca/weapons-fuel-humanitarian-crisis-in-sudan/> accessed 19 June 2026

[10] ‘New Weapons Fuelling the Sudan Conflict’ (Amnesty International, 24 July 2024) <https://www.amnesty.org/en/latest/research/2024/07/new-weapons-fuelling-the-sudan-conflict/> accessed 19 June 2026.

[11] ‘Sudan: Overview of Corruption and Anti-Corruption’ (Transparency International Knowledge Hub) <https://knowledgehub.transparency.org/helpdesk/sudan-overview-of-corruption-and-anti-corruption-3> accessed 19 June 2026.

[12] ‘Sudan’ (Global Sanctions) <https://globalsanctions.com/region/sudan/> accessed 19 June 2026

[13] United Nations Security Council, ‘Small arms and light weapons – Report of the Secretary General’ (UN Security Council, 23 October 2025) <https://share.google/JVwq1lRYqF2tHD0LO> accessed 23 June 2026.

[14] Jaeger J, ‘Weapons Fuel Humanitarian Crisis in Sudan’ (Project Ploughshares, 17 September 2024) <https://ploughshares.ca/weapons-fuel-humanitarian-crisis-in-sudan/> accessed 19 June 2026

[15] Jaeger J, ‘Weapons Fuel Humanitarian Crisis in Sudan’ (Project Ploughshares, 17 September 2024) <https://ploughshares.ca/weapons-fuel-humanitarian-crisis-in-sudan/> accessed 19 June 2026

[16] Ali, H. ‘The War in Sudan: How Weapons and Networks Shattered a Power Struggle’ (German Institute for Global and Area Studies, 2024) <https://www.giga-hamburg.de/en/publications/giga-focus/the-war-in-sudan-how-weapons-and-networks-shattered-a-power-struggle> accessed 19 June 2026

[17] ‘New Weapons Fuelling the Sudan Conflict’ (Amnesty International, 24 July 2024) <https://www.amnesty.org/en/latest/research/2024/07/new-weapons-fuelling-the-sudan-conflict/> accessed 19 June 2026

[18] ‘Online Reader: Cluster Munition Ban Policy’ (The Monitor, 20 August 2025) <https://the-monitor.org/country-profile/sudan/cluster-munition-ban-policy> accessed 19 June 2026

[19] ibid.

[20] “Letter dated 15 January 2024 from the Panel of Experts on the Sudan addressed to the President of the Security Council’ (15 January 2024) <https://digitallibrary.un.org/record/4039195/files/S_2024_65-EN.pdf> accessed 19 June 2026
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South Africa

7/13/2026

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This is one of a group of eight country profiles authored by an emerging expert, originally published as part of the "Comparative Study on Arms Trade Transparency" report (see full report). The assessments and opinions expressed are the views of each assessment's author. The Forum does not itself take positions.
Picture
Abongile Nkamisa

Introduction
 
South Africa occupies a distinctive position in the global arms trade. As both a constitutional democracy committed to human rights and a significant exporter of conventional arms, it has constructed a relatively sophisticated regulatory framework to govern arms transfers. Central to this framework is the commitment to transparency and accountability. However, recent developments suggest a widening gap between legal commitments and implementation. This report evaluates the state of transparency in South Africa’s arms trade through three lenses: (1) domestic legislation and institutional design; (2) international legal obligations; and (3) contemporary performance, including criticisms from Parliament and civil society.
 
Domestic Legislation and institutional design

The cornerstone of South Africa’s arms control regime is the National Conventional Arms Control Act 41 of 2002 (NCAC Act), which established the National Conventional Arms Control Committee (NCACC). The NCAC Act mandates a system that is ‘legitimate, effective and transparent’ and requires accountability in all arms trade decisions.[1] The NCACC is tasked with assessing permit applications for arms exports and imports; ensuring compliance with international law; preventing transfers to states engaged in repression, terrorism, or armed conflict; and reporting regularly to Parliament.[2]
 
Transparency is operationalised primarily through annual and quarterly reports submitted to Parliament. However, the NCAC Act places significant limitations on disclosure. Section 23 of the Act restricts publication of sensitive information, permitting only aggregate data such as destination countries, categories of arms, and total values.[3] This statutory limitation reflects a tension between transparency and national security. While designed to protect classified information, it has been criticised for enabling opacity.
 
The Regulation of Foreign Military Assistance Act 15 of 1998 (FMAA) complements the NCAC Act by regulating private actors. It criminalises mercenary activity and requires authorisation for any foreign military assistance provided by South African citizens or entities.[4] Although not directly focused on transparency, the FMAA Act contributes to accountability by extending regulatory oversight beyond state-sanctioned arms transfers to private military involvement.
 
In addition to statutory regulation, South Africa’s constitutional framework provides a strong legal foundation for transparency in governance, including in sensitive sectors like the arms trade. Section 32 of the Constitution guarantees everyone the right of access to information held by the state, as well as information held by private actors where such information is required for the exercise or protection of rights. This provision is widely regarded as central to ensuring openness, accountability, and responsiveness in a democratic society, particularly in light of South Africa’s historical legacy of secrecy under apartheid.
 
These constitutional guarantees are given practical effect through the Promotion of Access to Information Act 2 of 2000 (PAIA), which creates formal mechanisms through which individuals may request access to information held by public and private bodies. PAIA seeks to promote a culture of openness and accountability by enabling public scrutiny of government decision-making, including in areas such as arms transfers. At the same time, PAIA recognises that access to information is not absolute, permitting certain limitations where disclosure would undermine legitimate interests such as national security, commercial confidentiality, or disrupt effective governance.
 
The NCAC Act explicitly requires adherence to international agreements, integrating  the Arms Trade Treaty (ATT) principles into domestic decision-making.[5] South Africa is a party to the ATT, which imposes obligations to assess the risk that arms exports could facilitate human rights violations or breaches of international humanitarian law, deny exports where there is an overriding risk, and maintain transparency through reporting obligations. South Africa is also bound by United Nations Security Council arms embargoes, regional norms within the African Union, including commitments to ‘silence the guns”, and customary international humanitarian and human rights law.

Oversight and Reporting Mechanisms

The NCACC is a sui generis Cabinet Committee appointed by the president, comprising a group of Cabinet Ministers and Deputy Ministers that typically serve a five-year term. The NCACC reports to Parliament through the Joint Standing Committee on Defence.

Recent parliamentary statements have emphasised that transparency requires regular tabling of reports and meaningful scrutiny.[6] However, concerns persist regarding the frequency and quality of reporting, limited access to detailed data and delays in publishing reports. South Africa’s most recent reports from the NCACC indicate that the country remains an active and diversified exporter of conventional arms. Between January and June 2025, a total of 283 export permits for munitions valued at just under R5 billion were approved, alongside 79 permits for dual-use goods worth approximately R287 million ($17 million).[7] These exports span a wide range of equipment, including ammunition, armoured vehicles, combat aircraft, and electronic warfare systems, reflecting South Africa’s capabilities as a mid-tier arms producer.
 
International Legal Obligations

In terms of destination, South Africa’s arms exports are globally dispersed rather than concentrated in a single region. Europe accounted for approximately 59% of exports in the first quarter of 2025. This strong European demand aligns with broader global trends, where heightened security concerns, particularly in the context of the North Atlantic Treaty Organization (NATO) region, have driven increased procurement and importation of military equipment.[8]

By the second quarter, however, there was a notable shift in regional distribution. Africa emerged as a prominent recipient, accounting for roughly 35% of South Africa’s arms exports, with a particular emphasis on armoured vehicles and dual-use technologies.[9] Europe remained a significant market, and countries such as Germany continued to feature among the major recipients.[10] Beyond this period, extensive research points to a parallel expansion of exports to regions such as the Middle East, including countries like the United Arab Emirates and Saudi Arabia, often involving armoured vehicles and munitions.[11] These exports have raised concerns about diversion and use in ongoing conflicts, particularly where South African-produced weapons have been linked to war zones, like Yemen.

Recent parliamentary engagements reveal growing dissatisfaction with the transparency of South Africa’s arms trade. Members of Parliament have raised concerns about the absence of end-user verification mechanisms, limited data on the final destination and use of exported weapons, and insufficient responsiveness by the NCACC.[12] Critics argue that without effective end-use monitoring, South Africa risks complicity in human rights violations.

Civil society organisations have been particularly critical. Reports indicate that South Africa exported arms to 69 countries between 2022 and 2025, including to states accused of war crimes or governed by military juntas.[13] The NCACC has allegedly failed to suspend permits in situations where international law would require it; transparency in reporting remains inadequate, with calls for “timely, transparent export reports.”[14] A 2024 analysis described South Africa’s approach as “hypocritical,” highlighting inconsistencies between its human rights rhetoric and export practices.[15]

Recent reporting suggests that institutional weaknesses further undermine transparency. The NCACC has faced operational challenges, including irregular meetings and administrative inefficiencies.[16] Parliamentary oversight bodies have expressed concerns that limited functionality could weaken regulation,[17] and there is increasing pressure to reform reporting requirements and strengthen oversight mechanisms.

Transparency challenges in the arms trade must also be understood within South Africa’s broader governance environment. The country continues to face systemic corruption concerns, reflected in a relatively low score on the Corruption Perceptions Index.[18] The legacy of the 1999 Arms Deal scandal continues to shape public distrust in arms procurement and oversight processes.[19] South Africa’s arms trade transparency framework is robust but practically constrained.

On paper, the legal regime aligns with international standards, embeds transparency as a core principle, and provides for parliamentary oversight. In practice, however, transparency is undermined by statutory secrecy provisions limiting disclosure, weak end-use monitoring and verification mechanisms, institutional inefficiencies within the NCACC, and inconsistent compliance with international human rights obligations. The result is a system that produces formal compliance but falls short of substantive transparency.

Ultimately, bridging the gap between legal commitments and implementation will determine whether South Africa can maintain credibility as a responsible arms exporter in the international system. To strengthen transparency, South Africa should amend the NCAC Act to expand public reporting requirements, introduce robust end-use monitoring systems, improve the timeliness and composition of NCACC reports, and enhance parliamentary and civil society oversight.
 
Transparency Reports
Annual Reports 2000-2021
Annual Report 2023
UNROCA Report 2025
 
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Abongile Nkamisa is a Research Advisor at the South African Human Rights Commission, she previously worked for the non-profit organization Open Secrets as a Lawyer. She worked on issues related to corporate and private actors’ accountability in the arms trade. She holds an LLM from University of Cape Town and is completing an LLM in Public International Law at the University of London.  
Email:  [email protected]

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[1] Deputy Minister Andries Nel, Presentation of 2025 First and Second Quarter Reports of the National Conventional Arms Control Committee (NCACC) (25 July 2025) https://www.gov.za/news/speeches/deputy-minister-andries-nel-presentation-2025-first-and-second-quarter-reports-ncacc.

[2] ibid.

[3] ibid.

[4] Regulation of Foreign Military Assistance Act 15 of 1998.

[5] section 15.

[6] Stockholm International Peace Research Institute, Trends in International Arms Transfers, 2025 (SIPRI, March 2026).

[7] Deputy Minister Andries Nel, Presentation of 2025 First and Second Quarter Reports of the National Conventional Arms Control Committee (NCACC) (NCACC, 25 July 2025) https://www.gov.za/news/speeches/deputy-minister-andries-nel-presentation-2025-first-and-second-quarter-reports-ncacc.

[8] Open Secrets, ‘Not exactly at arm’s length: How South Africa’s weapons trade undermines its stance on Israel and Palestine’ (Africa Is a Country, 15 November 2024) https://africasacountry.com/2024/11/not-exactly-at-arms-length. 

[9] Michael Marchant, ‘South Africa’s arms export regulator sleeps, as world goes to war’ (Currency, 17 March 2026) https://currencynews.co.za/south-africas-arms-export-regulator-sleeps-as-world-goes-to-war/

[10] ‘Mapping South Africa’s arms exports: trends, key markets, and regional demand’ (Export Focus Africa, 2025) https://exportfocusafrica.com/2025/03/01/mapping-south-africas-arms-exports-trends-key-markets-and-regional-demand-2/

[11] Marchant M, ‘South Africa’s Arms Export Regulator Sleeps, as World Goes to War’ (Currency News, 16 March 2026) <https://currencynews.co.za/south-africas-arms-export-regulator-sleeps-as-world-goes-to-war/> accessed 19 June 2026

[12] Dladla BN, ‘Arms Committee Fails to Explain SA’s Weapon Sales to Saudi Arabia and UAE’ (GroundUp News, 5 March 2026) <https://groundup.org.za/article/sa-arms-control-committee-delays-producing-record-of-weapons-sales-for-five-years/> accessed 19 June 2026
https://defenceweb.co.za/industry/industry-industry/practicing-what-they-preach-a-look-at-south-african-arms-control-compliance/

[13] Open Secrets, ‘Unaccountable: National Conventional Arms Control Committee’ (Open Secrets, 2020) https://www.opensecrets.org.za/unaccountable-00005/

[14] SA arms exports under scrutiny amid calls for greater oversight and transparency’ (DefenceWeb, 29 July 2025) https://defenceweb.co.za/featured/sa-arms-exports-under-scrutiny-amid-calls-for-greater-oversight-and-transparency/

[15] By, ‘Not Exactly at Arm’s Length’ (Africa is a Country, 2024) <https://africasacountry.com/2024/11/not-exactly-at-arms-length> accessed 19 June 2026

[16] ‘Remarks by Mr Phiroane Phala, Chairperson of the Joint Standing Committee on Defence, During the Peace and Security Cluster Media Briefing - Parliament of South Africa’ (19 March 2026) <https://www.parliament.gov.za/press-releases/remarks-mr-phiroane-phala-chairperson-joint-standing-committee-defence-during-peace-and-security-cluster-media-briefing> accessed 19 June 2026

[17] ibid.

[18] ‘Corruption Perceptions Index 2024’ (Transparency.org, 11 February 2025) <https://www.transparency.org/en/cpi/2024> accessed 19 June 2026

[19] Hennie van Vuuren, Apartheid Guns & Money: A Tale of Profit (Jonathan Ball 2017); Open Secrets, Unaccountable: National Conventional Arms Control Committee (Open Secrets, 2020) https://www.opensecrets.org.za/unaccountable-00005/ accessed 30 March 2026
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Poland

7/13/2026

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This is one of a group of eight country profiles authored by an emerging expert, originally published as part of the "Comparative Study on Arms Trade Transparency" report (see full report). The assessments and opinions expressed are the views of each assessment's author. The Forum does not itself take positions.
Picture
Patrick Bodovitz

Introduction

Ever since the end of communist rule in Poland, Warsaw has sought to increase its power projection across Europe and beyond. Besides having an economy that is among the fastest-growing in the world, Poland’s arms industry has boomed. The historical memory of being conquered by Germany and Russia means that the Polish governing establishment has prioritized a strong national defense and arms industry, regardless of whatever coalition is in power. As Poland has become a major player in Europe, its arms exports have drawn increased scrutiny. While major legal reforms following the 1999 T-55 scandal significantly improved Poland's arms export controls, current national security concerns and domestic political shifts continue to compromise its commitment to full public transparency.
 
Poland’s Role in the Global Arms Trade

From 2018-2024, Poland exported $5.4B worth of weapons to a variety of countries that are close partners with Warsaw.[1] This is a massive increase in weapons transfers by the Polish arms industry, with most of the arms being exported going to Ukraine.[2] In 2024, Poland exported $2.64B in weapons, making it the 3rd-largest weapons exporter (out of 159) in the world. During the same year, weapons were the 33rd most exported product (out of 96) in Poland.[3] The days of Poland being a poor, post-communist country selling any goods it could to generate revenue are long gone. Additionally, many of the weapons now being exported are freshly produced in domestic factories, whereas in prior years, Poland often exported Soviet-designed weapons systems from the Cold War..
 
Poland has one of the largest arms manufacturing conglomerates in Europe. The Polska Grupa Zbrojeniowa (PGZ) controls over 50 subsidiaries and employs 20,000 people.[4] Besides PGZ, well over 100 other companies operate in the Polish arms industry: startups, branches of international arms companies operating in Poland, and smaller conglomerates. Approximately 62,500 people work in Polish weapons manufacturing. Demand for labor in the burgeoning industry is currently so high that both the Polish government and private companies are actively recruiting.[5] With Poland’s defense spending expected to rise to 4.7% of its GDP in 2026, the Poles are ensuring that they will become one of the largest arms manufacturers in the world per capita.[6]
 
National and International Transparency Frameworks

Poland is currently a member of the EU and NATO, and a signatory to the Arms Trade Treaty (ATT). As such, its arms export policies are subject to significant regulations that did not exist when the country was part of the Communist Bloc. These regulations have not been perfect at addressing transparency issues in Poland’s arms exports, but they do ensure that civil society has the legal protection available to demand accountability in the event of scandals. Currently, the Polish Ministry of Foreign Affairs provides annual reports called “Exports of Arms and Military Equipment from Poland”.[7] Poland is currently a signatory to most of the international accords surrounding arms exports.[8]
 
Part of Poland’s accession process to the EU involved signing many of these treaties, as well as introducing legal protections for whistleblowers. Due to major political transformations (including the 2023 parliamentary elections) in Poland over the past couple of years, its compliance with Article 19 of the United Nations International Convention on Civil and Political Rights (ICCPR) and Freedom of Information (FOI) standards is inconsistent. Its Act on Access to Public Information (2001) theoretically aligns with FOI standards, but its practical implementation is currently in flux.[9] Despite an improved political climate, Polish journalists can still face SLAPPs (Strategic Lawsuits Against Public Participation) and judicial harassment.[10]
 
Poland’s T-55 Scandal

In 1999, the Polish arms company Bumar-Łabędy agreed to a sale to the Yemeni government of 50 surplus T-55 tanks.[11] Poland’s government approved of the sale, despite concern expressed by United States officials that there was a serious possibility the tanks could be transferred to Sudan, a country then under an arms embargo because of its role in sponsoring terrorism. The Americans proved correct; the Yemeni officials rerouted the first shipment while it was at sea to Sudan. Bumar-Łabędy, the Polish Military Property Agency, and the arms export company Cenzin were implicated in the failure to stop the diversion of these tanks.  Furthermore, the Polish government could not verify the vehicles' destinations once they left port because Yemeni government officials had provided fraudulent end-user certificates. In August 1999, the Polish newspaper Gazeta Wyborcza uncovered that 20 of the 50 tanks had arrived in Sudan.[12] There were demands in the Polish Sejm and Senate to stop the transfer of the remaining tanks. While no top-tier ministers resigned immediately over the scandal, it triggered internal audits within the Military Property Agency and contributed to broader reforms of the military intelligence services (WSI), which were suspected of lacking sufficient oversight over international brokers.
 
This scandal proved to be a major turning point for accountability and independent journalism in Poland. It also led to major reforms in Poland’s arms export practices.
 
In 1999, the Sejm and Senate passed the Act on Arms and Ammunition, which explicitly listed the government agencies authorized to hold arms. The Act on Strategic Foreign Trade, the strongest Polish law governing arms export regulation passed to date, followed in 2000.[13] The Act contained three central reforms:

1)      Centralized Licensing: It formalized the Minister of Economy's power to coordinate and control all trade in military equipment and dual-use goods.
2)      "Catch-All" Clause: This allowed the government to control items not specifically on a restricted list if there was a suspicion they could be used for illicit military purposes.
3)      Intangible Technology Controls: For the first time, the law regulated the transfer of "invisible" assets, such as software and technical data related to military production.
 
Challenges and Opportunities

Poland has bolstered arms trade transparency over the last few decades by tightening export monitoring laws and maintaining its commitment to annual transfer reports. The war in Ukraine has posed some challenges to this trend. Due to security concerns, the Polish Prime Minister and Presidential offices have chosen to keep details of security cooperation with Ukraine private, including certain weapons systems, monitoring of end-use agreements, and cooperation between the intelligence services of both nations.[14] Poland formally listed all of the military items provided to Ukraine (to date) in late 2025, but since then additional aid has been sent without public acknowledgement, officially for security reasons. As such, Poland has several opportunities to improve transparency, including by:

1)      Introducing a mechanism for mandatory parliamentary consultation before sensitive export licenses are issued, similar to models used in countries such as Sweden.
2)      Mandating that the government publish more comprehensive and clearly structured data on transfers, including transit and transshipment, to be debated by parliament at least once a year.
3)      Establishing dedicated cross-party select committees (comprising members from defense, trade, and foreign affairs) to produce regular, public reports on export practices.
4)      Ending the use of "single-procurement" plans that lack public spending breakdowns.
5)      Expanding the 2024 Whistleblower Protection Act to cover more areas related to national security (including arms exports).
 
Best ways to improve transparency

Poland faces a difficult security situation that has left people on edge. In addition to the war in Ukraine, the country has faced attacks from Russian agents on its critical infrastructure and major political polarization related to the previous elections.[15] Amidst these challenges, there have been bright spots: the current government is under pressure to increase transparency after the prior government’s scandals. On June 21st, 2026, the President signed into law a bill protecting journalists from SLAPP lawsuits by ordering courts to examine national security claims early in the publication process.[16] Poland can ensure that its whistleblower protection laws extend to people working in national security positions or the arms industry. The Polish government should be more transparent about what it is sending to Ukraine. Additionally, it should station more officers in Ukraine to ensure that the weapons it supplies are not being diverted from their intended recipients on the front lines. Lastly, single sourcing contracts should be publicly announced, which the Polish MoD is not currently required to do. 
 
Transparency Reports
Annual Reports 2008-2019
UNROCA Report 2025

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Patrick Bodovitz is a contributing writer for TheCollector and an assistant editor for the journal Fair Observer, exploring US foreign policy history and emerging technologies in military policy planning. He previously worked with the Lemkin Institute for Genocide Prevention and the Center for International Policy's Security Assistance Monitor program. He also published a book called The Jewish People’s Republic. Bodovitz holds a master's degree from American University's School of International Service. Email: [email protected]


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[1] ‘Weapons in Poland Trade’ (The Observatory of Economic Complexity, 2024) <https://oec.world/en/profile/bilateral-product/weapons-1993/reporter/pol?selector2787id=trade_i_baci_a_17&selector1151id=2024&selector1205id=2018> accessed 4 February 2026

[2]  ibid.

[3]  ibid.

[4]  Adamowski J, ‘PGZ- Homegrown Innovation and Strategic Alliances in Defence of Poland, Ukraine and Europe’ (European Defence Agency, 2024) <https://eda.europa.eu/webzine/issue28/cover-story/pgz-homegrown-innovation-and-strategic-alliances-in-defence-of-poland-ukraine-and-europe> accessed 4 February 2026

[5] Brzeziński B, ‘Poland Is Europe’s Top Military Spender but Its Defense Industry Is a Dwarf’ (POLITICO, 10 December 2025) <https://www.politico.eu/article/poland-europe-top-military-spender-defense-industry-is-a-dwarf/#:~:text=%E2%80%9CThis%20could%20be%20the%20first,battle%20tanks%20and%20recovery%20vehicles.> accessed 29 April 2026

[6] Ptak A, ‘Poland Plans Record Defence Spending of 4.8% GDP in 2026 Budget along with Lower Deficit’ (Notes From Poland, 1 September 2025) <https://notesfrompoland.com/2025/08/29/poland-plans-record-defence-spending-of-4-8-gdp-in-2026-budget-along-with-lower-deficit/#:~:text=Poland%20has%20dramatically%20ramped%20up,course%2C%20support%20for%20citizens%E2%80%9D.> accessed 4 February 2026

[7] ‘National Reports: Poland’ (SIPRI) <https://www.sipri.org/databases/national-reports/Poland> accessed 4 February 2026

[8] These include the Arms Trade Treaty, the Anti-Personnel Mine Ban Convention, the Convention on Certain Conventional Weapons, the Chemical Weapons Convention, the Biological Weapons Convention, the Comprehensive Nuclear-Test-Ban Treaty, the UN Programme of Action on Small Arms and Light Weapons and the Wassenaar Arrangement. However, Poland plans to withdraw from the Ottawa Convention this coming year. ‘Poland Formally Withdraws from Ottawa Convention on Landmines, Citing Russian Threat | CBC News’ (CBCnews, 20 February 2026) <https://www.cbc.ca/news/world/poland-ottawa-convention-landmines-9.7098794> accessed 29 April 2026

[9] ‘How Does Access to Public Information Work in Poland?: In Principle’ (| In Principle, 11 January 2024) <https://codozasady.pl/en/p/how-does-access-to-public-information-work-in-poland-#:~:text=Access%20to%20public%20information%20in,public%20affairs%20is%20public%20information.> accessed 4 February 2026

[10] ‘Poland’ (Bienvenue sur le site de Reporters sans frontières, 4 December 2025) <https://rsf.org/en/country/poland#:~:text=Since%20a%20coalition%20led%20by,are%20trying%20to%20prevent%20it.> accessed 29 April 2026

[11] ‘Sudan, Oil and Human Rights ’ (Sudan Open Archive, 2002) <https://www.sudanarchive.net/?a=d&d=SLPD20021100-01.1.52> accessed 4 February 2026

[12] ibid

[13] Puk M, ‘Trade with Strategic Goods in Poland’ (Dudkowiak & Putyra, 22 August 2025) <https://www.dudkowiak.com/defense-military-law-in-poland/trade-with-strategic-goods-in-poland/#:~:text=Trade%20in%20this%20sense%20is,the%20Missile%20Technology%20Control%20Regime.> accessed 4 February 2026

[14] Court E, ‘Poland, Ukraine Sign Security Agreement’ (The Kyiv Independent, 8 July 2024) <https://kyivindependent.com/poland-ukraine-sign-security-agreement/#:~:text=The%20document%20consists%20of%2010,after%20Zelensky%20arrived%20in%20Poland.> accessed 4 February 2026

[15] Rfe/Rl, ‘Poland Suspects Russian Sabotage behind Railway Explosion’ (RadioFreeEurope/RadioLiberty, 19 November 2025) <https://www.rferl.org/a/poland-suspects-russian-sabotage-in-railway-explosion/33594773.html> accessed 29 April 2026

[16]  Ptak, Alicja. “Poland Introduces New Law against Slapp Lawsuits Aimed at Silencing Critics | Notes from Poland.” (Notes From Poland, 22 June 2026) https://notesfrompoland.com/2026/06/22/poland-introduces-new-law-against-slapp-lawsuits-aimed-at-silencing-critics/.
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The Netherlands

7/12/2026

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This is one of a group of eight country profiles authored by an emerging expert, originally published as part of the "Comparative Study on Arms Trade Transparency" report (see full report). The assessments and opinions expressed are the views of each assessment's author. The Forum does not itself take positions
​
Picture
Esmée de Bruin, after conversation w/ Frank Slijper (PAX)
Arms Trade

The Netherlands is a significant and established player in the arms trade. Over the years, it has been among the largest exporters of major arms in the world; between 2021 and 2025 it was the 12th largest exporter of major arms with a 1.2 percent share of global arms exports.[1] The main export products of the country include naval ships and their equipment, aerospace components, and defense electronics. The country also produces specialized parts and components for arms manufacturers further down the supply chain in other countries, including the United States.[2] With its port in Rotterdam and Schiphol Airport in Amsterdam, the country is an important transit country as well.[3]
 
While the Netherlands is a large arms exporter, it is also known for its transparency and relatively strict export controls.[4] In recent years, however, there have been concerns about the export of F-35 fighter jet parts to Israel and the United States. There have been several court cases on this topic, with one pending at a Dutch Appeals Court.[5] In addition, there are concerns about the planned accession to the Treaty of Aachen that could further affect arms control and transparency.
 
The Road to Greater Oversight in the Arms Trade

Although the Netherlands is currently one of the most transparent countries in regards to the arms trade (according to the Small Arms Trade Transparency Barometer from Small Arms Survey), it has not always been so.[6] The road to the Netherlands’ current level of transparency was characterized by the combined efforts of research journalists and civil society and subsequent demand for information from the Dutch House of Representatives.
 
In the 1990s, information about arms exports in the Netherlands was largely inaccessible to the public. The only data released each year consisted of two figures: the total value of arms exports to NATO countries and the total value of exports to non-NATO countries. The House of Representatives received confidential lists with more detailed information. A confluence of events in 1997 pushed this problem into the public eye: the House of Representatives lists wound up in the hands of research journalists, and a prominent Dutch newspaper published an article on the Dutch export of communication devices to Algeria based on information  requested via a Government Information (Public Access) Act procedure.[7] At the time, Algeria was in the midst of a violent civil war, which meant that these exports were likely to contribute to human suffering and exacerbate the conflict. This publication, followed by further revelations about other military exports to Algeria, triggered an active and critical political discussion.
 
In 1998, coinciding with the adoption of the Code of Conduct on Arms Exports by the EU Council, the Netherlands started publishing more information[8], following the example of Sweden. The Code of Conduct pushed EU Member States to develop common arms export standards. One of the key elements of this political agreement was that EU countries would publish an annual report in which arms exports, granted licenses and denials of licenses were listed.[9]
 
However, this did not mean that all information was timely and publicly accessible. As a result, in 1999, journalists again used the Government Information (Public Access) Act to request access to information related to arms trade from the previous 10 years.[10] When extensive information was disclosed following this request, the Dutch House of Representatives realized that they did not have the right information at their disposal to exercise democratic control. They called for reports to make this possible.[11] This became the basis of the monthly reports that are currently available.

Current State of Transparency in the Netherlands

The Netherlands sees itself as an ‘international leader’ when it comes to transparency concerning the export and transit of strategic goods.[12] The Netherlands publishes regularly-updated files of licenses for the export of military and dual-use goods and the transit of military goods.[13] These reports contain relatively more detail than most other countries’ reports: all destinations, values of the exported goods, and even detailed descriptions of the exports are included.[14] There is also an annual report that explains Dutch export policy of each year in greater depth, and a historic list of denied export licenses.[15]
 
In addition to these monthly and yearly reports, there is an accelerated reporting procedure in cases where an export license for a complete arms system is given to destination countries other than Australia, Japan, New Zealand, Switzerland, NATO-member states, or EU-member states. This procedure means that the House of Representatives must be informed within two weeks, with an explanatory note setting out why a license was given in accordance with the first four criteria from the EU Common Position on Arms Exports (EU Common Position).[16] An area for improvement for Dutch transparency policy is that the accelerated reporting procedure does not apply to parts and components, while these constitute a crucial part of Dutch exports.
 
Recent Cases and the Ongoing Role of Civil Society
Civil society still plays a substantial role in export control and transparency in the Netherlands, like the recent efforts by Oxfam Novib, PAX, and The Rights Forum in court cases concerning the export of F-35 fighter jet parts.
 
A global distribution hub for F-35 parts is located at the Woensdrecht Air Base in the Netherlands as part of the F-35 Lighting II program. Other countries that are part of this program, including Israel and the United States, can order F-35 parts from this hub. A general license was issued in 2016 for an indefinite period for the export of these parts.[17]
 
The Netherlands continued exporting F-35 parts from its distribution hub after it became clear that the parts would be used by the Israeli military in Gaza. This prompted civil society organizations to demand all Dutch F-35 transfers to Israel to cease.[18] They further questioned whether the indefinite and general nature of the license was in line with international law. In February 2024, the Appeals Court agreed with the NGOs and demanded that the government halt all F-35 related transfers to Israel.[19] In October 2025, the Dutch Supreme Court also ordered that the state reassess the export license, and suspend or revoke it if a clear risk was found. Interestingly, the Supreme Court ruled that courts should not make export control decisions themselves but could demand reviews from the government.[20]
 
Additionally, at time of writing, a related case is pending at the Dutch Appeals Court.[21] This case concerns the export of F-35 parts from the Netherlands to countries other than Israel, and especially to the United States, as a main contractor of the fighter jet. Under the current licensing system, it is often unclear which countries are the end-users of those exported parts.[22] This is a loophole in the system, and the parts could still end up being used by the Israeli military in Gaza if no prior export restrictions on the final destination are enforced by the Netherlands. However, the state has remained unwilling to stop these indirect deliveries, and has argued that its national security is dependent on its relationship with the United States. Civil society believes that any export of F-35 parts with Israel as an end-user is unlawful, regardless of whether the parts are delivered directly or indirectly via the United States.[23]
 
Factors affecting Transparency: the Impact of the Treaty of Aachen

The Netherlands’ recent accession request to the 2019 Treaty of Aachen is another major development that could have an impact on Dutch arms trade transparency. The Treaty of Aachen is a treaty between Germany, France and Spain, one of the goals of which is increased security and arms production cooperation between the countries. In practice, this means that export licenses will no longer be a requirement for arms trade between states that are party to the treaty. Instead, the responsibility for the export license assessment lies with the state that exports the final product to a state that is not part of the treaty.
 
The Netherlands would be relying on these other countries to make the appropriate export control decision as a result. This might not seem a problem at first, but civil society in the Netherlands warns of the implications.[24] Although Germany, France and Spain are bound by the same international regulatory framework as the Netherlands, these countries may follow less stringent domestic criteria with regards to transparency, or could have a different interpretation of the EU Common Position and the Arms Trade Treaty than the Netherlands.
 
In January 2026, the Dutch House of Representatives discussed whether the country would accede to the Treaty of Aachen if it could not be guaranteed that this would lead to less stringent export criteria than those currently applied. Less than 20 percent of the House was against accession if this would be the case. The results of this discussion illustrate the current sentiment in Dutch politics: the perceived security threat since the Russian invasion of Ukraine in 2022 and increasing geopolitical tensions may soon take a toll on transparency and export control.[25]
 
Conclusion
The Netherlands is an important conventional arms exporter and transit country. While it has not always been the case, currently, the Netherlands is among the most transparent countries in the world. Transparency in arms trade seems to be part of the identity of the country as it actively promotes this role in international forums and national documents. However, recent court cases regarding the export of F-35 components to Israel and the wish to accede to the Treaty of Aachen show that transparency and the regulatory framework can be fragile if a country perceives its national security to be at stake, even if this country is an ‘international leader’ in transparency.
 
Transparency Reports
Annual reports on arms export policy
Monthly report on the export of military goods
Monthly report on the export of dual-use goods
Monthly report on transit reports of the export of military goods
Historic overview of denied applications for a military goods license

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Esmée de Bruin* is a PhD candidate at the University of Amsterdam. She focuses on the effectiveness of arms control. With a background in international economics and international law, she addresses the functioning of treaties, the influence of the Arms Trade Treaty on arms trade, and arms export control regimes with a multidisciplinary research approach. Email: [email protected]

*Corresponding authors - contributed to the writing, editing, and administration of this publication

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[1] Stockholm International Peace Research Institute, Trends in International Arms Transfers, 2025 (Fact Sheet, March 2026) https://www.sipri.org/publications/2026/sipri-fact-sheets/trends-international-arms-transfers-2025  accessed 21 May 2026

[2] PAX, Arms Trade (PAX, 2025) https://paxforpeace.nl/what-we-do/programmes/arms-trade/ accessed 10 February 2026

[3] Ministry of Foreign Affairs (Netherlands), Maandelijkse rapportage doorvoermeldingen militaire goederen (11 December 2025) https://www.rijksoverheid.nl/documenten/rapporten/2016/10/01/overzicht-doorvoer-militaire-goederen accessed 19 February 2026

[4] For a discussion of the regulatory framework, see Jennifer Bunnik, Ana Gobillon, Jiaxin Li, Jan Melck and Zia Wendt (eds), Transparency in European Arms Exports: Access to Information and Accountability (T.M.C. Asser Instituut & University of Amsterdam Law Clinics, The Hague 30 June 2025) https://www.asser.nl/media/zujhz4ji/transparency_in_european_arms_exports_law_clinic_report_30_june_2025_asser_institute.pdf accessed 5 February 2026

[5] Hoge Raad (Netherlands), 3 October 2025, ECLI:NL:HR:2025:1435.

[6] Small Arms Survey, The Small Arms Trade Transparency Barometer 2022 (Small Arms Survey, 2022) https://www.smallarmssurvey.org/sites/default/files/SAS-Transparency-Barometer-2022.pdf accessed 10 February 2026

[7] Martin Broek and Frank Slijper, Explosieve materie: Nederlandse wapenhandel blootgelegd (Papieren Tijger, Breda 2003).

[8] The Netherlands followed Sweden’s example by publishing more information. Sweden is known for its detailed reporting. Author conversation with Frank Slijper.

[9] Sibylle Bauer and Mark Bromley, The European Union Code of Conduct on Arms Exports: Improving the Annual Report (SIPRI Policy Paper No 8, Stockholm International Peace Research Institute, November 2004) https://www.sipri.org/sites/default/files/files/PP/SIPRIPP08.pdf accessed 10 February 2026.

[10] The information that came to light after this procedure can be found in the following book: Broek and Slijper, Explosieve materie (n 98).

[11] Broek and Slijper (n 98).

[12] The country has repeatedly stated this in official communications at the Conference of States Parties to the Arms Trade Treaty and in its yearly Arms Export Policy documents, see for example Ministry of Foreign Affairs (Netherlands), Dutch Export Policy on Strategic Goods in 2023 (Government.nl, 2025) https://www.government.nl/topics/export-controls-of-strategic-goods/documents/reports/2024/11/22/dutch-export-policy-on-strategic-goods-in-2023 accessed 10 February 2026

[13] In practice these reports are updated around three times a year. Author conversation with Frank Slijper.

[14] These reports are the same ones as were referred to in the previous paragraph.

[15] For the reports, see Ministry of Foreign Affairs (Netherlands), Reporting practices with regard to military and dual-use goods (Government.nl, 2025) https://www.government.nl/topics/export-controls-of-strategic-goods/reporting-practices-with-regard-to-military-and-dual-use-goods accessed 5 February 2026

[16] Ministry of Foreign Affairs (Netherlands), Dutch Export Policy on Strategic Goods in 2023 (n 103).

[17] Annick Pijnenburg, Michiel Tjepkema and Casper Smeulders, ‘Dutch Supreme Court Orders Executive Branch to Reassess Export of F-35 Parts to Israel in Light of International Obligations’ (Opinio Juris, 8 October 2025) https://opiniojuris.org/2025/10/08/dutch-supreme-court-orders-executive-branch-to-reassess-export-of-f-35-parts-to-israel-in-light-of-international-obligations/ accessed 9 February 2026

[18] PAX, Lawsuit against Dutch state: stop delivery of F-35s (PAX, 18 January 2024) https://paxforpeace.nl/news/lawsuit-against-dutch-state-stop-delivery-of-f-35s/#content accessed 21 May 2026

[19] Gerechtshof Den Haag (12 February 2024) ECLI:NL:GHDHA:2024:191.

[20] Hoge Raad (3 October 2025) ECLI:NL:HR:2025:1435.

[21] PAX, Rechtszaak tegen Nederlandse staat: stop levering voor F-35’s (PAX, 3 October 2025) https://paxvoorvrede.nl/acties/rechtszaak-tegen-nederlandse-staat-stop-levering-voor-f-35s/ accessed 12 February 2026.

[22] This is the case for newly built F-35 fighter jets and the spare parts that are transferred to the US or elsewhere to become part of the ‘Global Spares Pool’.

[23] PAX (n 112).

[24] Frank Slijper and Wendela de Vries, Opinie: Nederland moet de grip op wapenexport niet verder uit handen gegeven (Volkskrant, 28 February 2024) https://www.volkskrant.nl/columns-opinie/opinie-nederland-moet-de-grip-op-wapenexport-niet-verder-uit-handen-gegeven~bf76c977b/ accessed 10 February 2026

[25] Tweede Kamer der Staten-Generaal, Motie van het lid Dobbe c.s. over niet toetreden tot het Verdrag van Aken totdat kan worden gegarandeerd dat dit niet zal leiden tot minder strenge exportcriteria dan Nederland nu toepast (22054-473) (14 January 2026) https://www.tweedekamer.nl/kamerstukken/moties/detail?id=2026Z00431&did=2026D01045 accessed 10 February 2026
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Germany

7/12/2026

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This is one of a group of eight country profiles authored by an emerging expert, originally published as part of the "Comparative Study on Arms Trade Transparency" report (see full report). The assessments and opinions expressed are the views of each assessment's author. The Forum does not itself take position

Anonymous author - Please contact corresponding authors Esmée de Bruin and Allie Hansen with any inquiries related to this publication.
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Anonymous author

German Arms Trade

Globally, Germany is the fourth largest arms exporter by volume from 2005 through 2025.[1] Over the past 20 years, it has been among the five largest arms exporters globally.[2]  Exports range from dual-use goods such as radar systems and navigation technology, to small arms and light weapons, to entire naval ships and submarines. The largest recipient of German exports in 2025 was Ukraine, followed by Egypt and Israel.[3]

The German arms trade is regulated by several international agreements, most importantly the Arms Trade Treaty (ATT) and the Wassenaar Arrangement, regional frameworks such as the European Common Position on Arms Transfers (EUCP), and domestic legislation. The domestic framework differentiates between two categories of military exports: “weapons of war”, which are listed in an exhaustive list in the Weapons of War Control Act[4] and any “other military equipment” falling under the Foreign Trade and Payments Act (FTPA).[5] Additionally, the German government seeks to align its arms export practices with internal guidelines, the Political Principles on Arms Exports,[6] which are updated periodically but not legally binding.
 
Situation of Transparency[7]

Principles of access to information are enshrined within the Freedom of Information Act (FIA). Crucially, however, this act contains exceptions to information that might impact Germany´s foreign relations.[8] The Berlin Administrative Court[9] concluded in a case in 2017 that such exceptions extend to requests relating to arms export decisions,[10] consequently severely limiting the FIA´s applicability to transparency on the arms trade.

Decisions on arms transfer licenses are generally made by the National Security Council, consisting of select Federal Ministers, and are only reported ex post facto in a non-public format to the Federal Parliament.[11] The federal government regularly publishes annual summary reports and semiannual interim reports, providing a general overview of Germany´s arms transfer activities over the previous period. These contain accumulated value numbers of exports, overviews of recipient states and categories of exports, but exclude information on individual exports or any further details beyond general transfer categories.[12]

Germany also participates in reporting within the context of the ATT and the EUCP. In the latter case, this data can be accessed through an EU database (usually with a delay of at least two years after export) which contains generalized information on total values of licenses, category of license, and destination country.[13] Germany also regularly submits reports to other international registers, again usually only containing information on total values of exports clustered in categories to recipient countries.[14] Here too, the reports typically reflect exports with a delay of  several months or years and do not contain detailed information on specific exports beyond general arms categories. Hence, while Germany diligently reports ex post on its overall arms trade volumes, there are currently no legal or political frameworks in place to identify individual arms transfers to specific recipient states. Therefore, transparency on individual exports, crucial for discussing their legal or political implications, relies entirely on publications by journalists, requests by parliamentarians[15] and strategic litigation by non-governmental organizations.
 
Recent cases and the role of strategic litigation for transparency

As mentioned above, a 2017 decision by the Frankfurt Administrative Court established that arms transfer licensing decisions are exempt from FIA requests, since transparency might adversely reflect on German foreign relations. Nevertheless, NGOs working with individuals affected by arms transfers have continued attempting to use legal procedures to achieve, among other objectives, increased transparency on German arms transfer licensing practices. A notable case was advanced by the European Center for Constitutional and Human Rights (ECCHR), which requested the relevant licensing authority access to administrative files for military equipment delivered to Saudi Arabia and the United Arab Emirates. After the licensing authority denied the request, they argued before the Frankfurt Administrative Court that the individual they were supporting, a Yemeni national, was adversely affected by the exports due to the ongoing armed conflict, and therefore had a right to receive access to those files.[16] The Administrative Court decided to grant access to these files. However, they were so heavily redacted by the licensing authority that their contribution to any higher standard of transparency was practically reduced to zero.[17]

Building on these initial efforts, strategic litigation continued to attempt to further transparency based on individual affectedness of arms exports. A number of additional cases before the Frankfurt Administrative Court and the Berlin Administrative Court emerged in 2024 and 2025 in relation to arms transfers to Israel, in which the plaintiffs requested numerous measures, including measures related to transparency.[18] The measures demanded ranged from access to licensing files, to being informed of ongoing licensing requests and of future licensing requests once submitted. The plaintiffs argued that without this crucial information, they could not effectively challenge licensing decisions, which adversely affected their constitutional rights to life and bodily integrity.[19] In all cases, the Courts rejected the requests, including those related to transparency measures. The judgments held that arms transfer licensing decisions fall into the exclusive domain of the executive branch and thus cannot be disclosed due to reasons of state secrecy.[20] Notably, several other measures were also rejected due to a lack of specificity against which export the plaintiffs directed their requests.[21] This resulted in the somewhat paradoxical outcome that judgments rejected certain measures due to a lack of information but also rejected requests that would provide this information. As these cases have exhausted all possible appeals, the status quo in Germany remains that there is no effective legal recourse to seeking increased transparency for individual arms transfer licenses. 
 
Conclusion

Germany is diligently reporting on arms transfers under all international legal regimes and publishes its own annual arms export control reports. However, these reports do not provide detailed information on individual licenses and are only published months after a transfer has taken place. Judicial attempts to seek more comprehensive transparency, especially with an eye to challenging individual arms transfers before they are conducted, remained unsuccessful. The resulting degree of opaqueness is seen by the executive and judiciary branches as inherent in the nature of arms transfers, which are described as situated clearly within the discretion of the government and intertwined with foreign policy. Therefore, transparency activities on arms transfers by the German government focus primarily on summary reports, while limiting meaningful public oversight and effectively excluding judicial challenges against arms transfer decisions.
 
Transparency Reports
Annual Report Federal Government
EU Database

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[1] Compare: SIPRI Fact Sheet, Trends in International Arms Transfers, 2025 (SIPRI, March 2026), available at https://www.sipri.org/sites/default/files/2026-03/fs_2603_at_2025.pdf, and SIPRI Arms Transfer Database, Top Largest Suppliers 2005-2025, available at https://armstransfers.sipri.org/ArmsTransfer/ImportExportTop.

[2] SIPRI Fact Sheet, Trends in International Arms Transfers, 2025 (SIPRI, March 2026), available at https://www.sipri.org/sites/default/files/2026-03/fs_2603_at_2025.pdf

[3] SIPRI Fact Sheet, Trends in International Arms Transfers, 2025 (SIPRI, March 2026), available at https://www.sipri.org/sites/default/files/2026-03/fs_2603_at_2025.pdf

[4] See for the list: Weapons of War Control Act (Kriegswaffenkontrollgesetz), 19 April 1961, para 1 (1) and Annex 1.

[5] Federal Office of Justice, Foreign Trade and Payments Act (Außenwirtschaftsgesetz), version of 23 May 2022, available at https://www.gesetze-im-internet.de/englisch_awg/englisch_awg.html.

[6] Federal Government (Bundesregierung), Political Principles for the Export of War Weapons and Other Military Equipment (Politische Grundsätze der Bundesregierung für den Export von Kriegswaffen und sonstigen Rüstungsgütern), version of 26 June 2019, available at https://www.bmwk.de/Redaktion/DE/Downloads/P-R/politische-grundsaetze-fuer-den-export-von-kriegswaffen-und-sonstigen-ruestungsguetern.pdf?__blob=publicationFile. 

[7] More extensively: See on this: Jennifer Bunnik et al., Transparency in European Arms Exports – Access to Information and Accountability, available at https://www.asser.nl/media/zujhz4ji/transparency_in_european_arms_exports_law_clinic_report_30_june_2025_asser_institute.pdf, pp. 30-39.

[8] Freedom of Information Act (Informationsfreiheitsgesetz), 05 September 2005, para 3 (1) a).

[9] Since the National Security Council – the entity which decides on licenses under the WWCA – is situated in Berlin, the Berlin Administrative Court is the relevant court for all cases relating to weapons of war. Similarly, the licensing authority for the FTPA is located in nearby Frankfurt, thus all cases related to other military equipment are adjudicated by the Frankfurt Administrative Court.

[10] Administrative Court Berlin, 2 K 260.16 of 18 July 2017.

[11] German Parliament (Bundestag), 02 September 2025, (BT-Drs.) 21/1460, available at: https://dserver.bundestag.de/btd/21/014/2101460.pdf, Geschäftsordnung des Nationalen Sicherheitsrates, para 1 (4).

[12] See: Bericht der Bundesregierung über ihre Exportpolitik für konventionelle Rüstungsgüter im Jahre 2024, available at https://www.bundeswirtschaftsministerium.de/Redaktion/DE/Publikationen/Aussenwirtschaft/ruestungsexportbericht-2024.pdf?__blob=publicationFile&v=4.

[13] Compare: European External Action Service, COARM Public (v2.0), Licenses – Detailed Overview, available at https://webgate.ec.europa.eu/eeasqap/sense/app/75fd8e6e-68ac-42dd-a078-f616633118bb/sheet/ea00a7e5-39aa-4cdb-aeb8-c00ff33db725/state/analysis.

[14] See for an overview: Small Arms Survey, The Small Arms Trade Transparency Barometer 2022, available at https://www.smallarmssurvey.org/sites/default/files/SAS-Transparency-Barometer-2022.pdf, p. 2.

[15] See on this: Jennifer Bunnik et al., Transparency in European Arms Exports – Access to Information and Accountability, available at https://www.asser.nl/media/zujhz4ji/transparency_in_european_arms_exports_law_clinic_report_30_june_2025_asser_institute.pdf, p. 32.

[16] ECCHR, Bombed in air war, stalled by redacted files (ECCHR, 2025), available at: https://www.ecchr.eu/en/press-release/im-luftkrieg-bombardiert-mit-geschwaerzten-akten-blockiert/.

[17] ibid.

[18] See exemplary: Administrative Court Berlin, 4 L 119/24 of 10 June 2024, Administrative Court Berlin, 4 L 148/24 of 10 June 2024, Administrative Court Berlin, 4 L 44/24, Administrative Court Frankfurt, 5 L 2333/24.F.

[19] ibid.

[20] ibid.

[21] Administrative Court Berlin, 4 L 119/24 of 10 June 2024, paras 18-19 and 22-23. 
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