On 9 June 2026, the Swedish Parliament adopted the government bill 2025/26:228 on a modern and adapted regulatory framework for military equipment. The bill contains, inter alia, revised guidelines for licensing under the Military Equipment Act (1992:1300), new exemptions from licensing requirements for subcontractors in the defence industry, extended reporting obligations for license holders, and a new requirement for a weapons manufacturer license under the new Firearms Act (2026:408), which entered into force on 1 June 2026. The legislative reforms will enter into force on 1 August 2026.
The purpose of export controls on military equipment is to ensure that products and technology do not go to recipients that are unacceptable to Sweden. Under the Military Equipment Act, a license is required to run a business related to the manufacture, supply, and export of military equipment from Sweden, as well as the provision of technical assistance regarding military equipment. The general principle for the license procedure is that a license may only be issued if issuance is warranted by national security or defence policy considerations and that the granting of the license does not conflict with Sweden’s international obligations or Sweden’s foreign policy in general. The Inspectorate of Strategic Products (“ISP”) is the authority responsible for reviewing license applications under the Military Equipment Act.
The granting of licenses is governed by the so-called guidelines, which consist of guiding statements from the government in the preparatory works of the Military Equipment Act. The guidelines have previously stated that a license to export military equipment or expertise, or to engage in other cooperation with a foreign party regarding military equipment, may only be granted if it is necessary to accommodate a need for equipment or expertise within the defence of Sweden, or if there are other security policy reasons for doing so, provided that the granting of the license does not conflict with the principles of Sweden’s foreign policy. Historically, the guidelines have therefore emphasized the defence of Sweden, even regarding issues concerning exports or other cooperation with other states.
Sweden’s membership in the NATO defence alliance entails commitments to assist allies in maintaining and developing defence capabilities within the alliance, which affects the conditions for Swedish export controls on military equipment. For this reason, the guidelines for licensing under the Military Equipment Act are now being revised to clarify that there may be defence and security policy reasons to grant a license, if it is necessary to ensure an ally’s need for equipment or expertise. The licensing will therefore not be determined by needs relating to the defence of Sweden to the same extent as before.
The changes to the guidelines are expected to have a positive impact on the growth of the domestic defence industry. According to the government, new and unestablished defence companies will be given further opportunities to manufacture, supply, and export military equipment or technical assistance to an allied state, since there is no longer a requirement for a corresponding interest regarding the defence of Sweden or from Swedish authorities.
According to the recently adopted bill, the government is authorised to issue regulations exempting certain subcontractors from the licensing requirements for the manufacture and supply of parts for military equipment. The reasons behind this include reducing the administrative burden on ISP, system manufacturers, and subcontractors, while also strengthening the incentives for licensees to maintain supply chains in Sweden.
In practice, the legislative changes mean that the government will be able to grant exemptions from the licensing requirement for subcontractors contracted by a license holder to carry out specific manufacturing, such as manufacturing that is entirely or largely based on the customer’s instructions, or processing and other services performed on existing materials, where military features are incorporated into the products in question. The licensing requirement will therefore no longer apply to certain subcontractors in the defence industry.
The exemption also applies to subcontractors’ suppliers, i.e. assignments at both direct and indirect levels. The ISP estimates that the number of licensees under the Military Equipment Act will decrease from approximately 450 to approximately 300. An important limitation to mention is that the exemption does not cover the manufacture of proprietary products, where the manufacturer intends to supply the products to multiple market operators, even if there is only one buyer of the product at the time of manufacture.
To ensure effective oversight of subcontractors as well, the government proposed in the proposition that holders of licenses for the manufacture of military equipment should be subject to an expanded obligation to include information about subcontractors in their annual report to the ISP. In practice, this means that the relief in licensing requirements for subcontractors results in licensees being subject to an expanded reporting obligation regarding subcontractors. The specific details of this reporting obligation will be set forth in regulations issued by the government.
Today, essentially all manufacturing of firearms is regulated by the Military Equipment Act. The granting of licenses to manufacture firearms therefore generally falls under the ISP’s mandate. Through the government bill 2025/26:228, the Swedish Parliament has decided that the manufacture of certain firearms will henceforth instead be subject to the licensing rules of the Firearms Act, with the Swedish Police Authority serving as the licensing authority. This means that licenses for the manufacture of certain firearms will no longer be subject to the security and defence policy guidelines that govern the ISP’s licensing process, but will instead be assessed on the basis of criteria similar to the existing requirements for arms dealer licences under the Firearms Act. According to the government, one consequence of the legislative changes will be that it will become possible to obtain a manufacturing license for firearms for civilian purposes, such as hunting and sport shooting.
The Swedish Parliament has approved the legislative proposals, and the changes will take effect on 1 August 2026. The government is now expected to issue the relevant laws and adopt regulations that will take effect at the same time as the new laws. Moving forward, it is therefore important to continue monitoring the government’s work on implementing the new laws.
