UK extends Russia sectoral software general trade licence

**LONDON, April 1, 2026 **— The U.K. Export Control Joint Unit has extended the validity of its General Trade Licence for Russia sanctions covering sectoral software and technology, replacing the previous version dated Oct. 16, 2025. The updated licence took effect on April 1, 2026, and now runs until Oct. 30, 2026.

The licence remains a narrow carveout. It authorizes the transfer and making available of business enterprise software and technology, plus related ancillary services, to multinational clients headquartered outside Russia, including where they have subsidiaries and affiliates in Russia, but only under specified conditions. Those conditions include that the activity satisfies an obligation under a contract concluded before April 23, 2025, and that the software, technology or related services are only for non-predominant use by a subsidiary established in Russia. Predominant use in Russia remains excluded.

The ECJU said the extension is intended to provide additional time for licensing processes to be completed so that legitimate use of sanctioned software and technology can continue without disruption. Users of the licence must register on SPIRE within 20 calendar days of first use and keep records in line with Regulation 76, with records retained for four years beyond the end of the calendar year in which they were created.

The background is important. The U.K. introduced Chapter 4N and Schedule 3IA into its Russia sanctions regime through the Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025. Those rules prohibit the transfer and making available of sectoral software and technology to a person connected with Russia or for use in Russia, including by intangible means such as downloads, software-as-a-service and app-based access. Government guidance says the measures are aimed at increasing economic pressure on Moscow and degrading its ability to fund the war.

Schedule 3IA captures a broad set of business enterprise software, including enterprise resource planning, customer relationship management, business intelligence, supply chain management, enterprise data warehouse, computerized maintenance management, project management and product lifecycle management software, along with related components such as HR, accounting and fleet management modules.