On 21 July 2025, the UK government issued the General Trade Licence: Russia Sanctions – Sectoral Software and Technology (the “Sectoral Software Licence”) under Regulation 65 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the “UK Russia Regulations”). The Sectoral Software Licence came into force on 21 July 2025 and will expire on 20 October 2025.
The Sectoral Software Licence authorises providers located in or operating from within the UK and UK persons to transfer and make available business enterprise software, technology and related ancillary services to multinational clients headquartered outside of Russia, with global subsidiaries and affiliates, including in Russia. Use of the Sectoral Software Licence is subject to the conditions that the software or technology is provided in satisfaction of an obligation arising under a contract concluded before 23 April 2025 and only for a non-predominant use by a subsidiary established in Russia.
Any provider seeking to rely on the Sectoral Software Licence must register online via SPIRE within 20 days of their first use of the licence and comply with certain record-keeping requirements outlined in the licence, standard to general licences issued under the UK Russia Regulations, including but not limited to a 4 year retention period for certain documents.
Pre-existing contracts notification deadline
When the UK “sectoral software” prohibitions under Chapter 4N of the UK Russia Regulations came into effect on 24 April 2025, an exemption was provided in respect of acts carried out under contracts entered into before 23 April 2025, or ancillary contracts necessary for the satisfaction of such contracts, provided that (i) the act is carried out before the end of 22 July 2025, and (ii) notification is made to the UK Secretary of State before the end of 22 July 2025. Accordingly, parties that have relied on this exemption should ensure that they meet the imminent notification deadline.
We discussed the “sectoral software” prohibitions in further detail in our previous blog post.
