Is AQAP 2110 Mandatory in Ukraine? The Full Legal Basis for a Defense Manufacturer (2026)

No Ukrainian law contains a rule saying "an arms manufacturer must hold AQAP 2110." In that narrow sense, is AQAP 2110 mandatory? No. It isn't a license or a permit you'll be shut down without. But stop at that answer and you'll be misled.

In practice, a different mechanism is at work. AQAP 2110 becomes de facto mandatory through two things: the terms of a specific defense contract, and the state quality assurance system, where "AQAP-series standards" are formally written in as the reference framework. The law doesn't force you to certify. Your customer does, leaning on the law.

For a defense manufacturer, and especially a drone maker eyeing serial Ministry of Defense contracts and exports to NATO, the distinction is purely academic. Without an AQAP 2110 certificate you either fail qualification or lose to a competitor who has one. Below we break down the exact regulatory basis, with law numbers, resolutions and dates, so you understand what your customer is actually referring to, and where in that chain your obligation sits.

Start with the base law that governs the status of any standard in the country: the Law of Ukraine "On Standardization" No. 1315-VII of 5 June 2014.

Article 23 states the principle plainly: national standards and codes of practice apply on a voluntary basis, except where their mandatory application is established by a separate regulatory act. Translated out of legalese: no ДСТУ (national standard) obliges anyone to do anything on its own. The obligation appears only when some other document, a law, a resolution, a technical regulation, or a contract term, references that standard and turns its application into a requirement.

There's a second detail people routinely miss. The same Article 2 of Law No. 1315-VII explicitly excludes military standards from its scope. The civilian standardization law doesn't cover defense standards at all. So hunting for AQAP 2110 in the regular ДСТУ register is a waste of time. It lives in a separate military standardization system with its own adoption rules. You can check the law's text on the Verkhovna Rada portal.

Hence a conclusion that should take the edge off the first wave of panic: the "mandatory/voluntary" label isn't a stamp on the standard. It's about who referenced it, and where. And AQAP 2110 has been referenced in several places at once. Those references are what create the real obligation.

Many people treat AQAP 2110 as a "foreign NATO document" with no footing in Ukrainian law. That hasn't been true since 2021.

First, the framework. Law No. 2742-VIII "On Amendments to Certain Laws of Ukraine Regarding Military Standards" (adopted 6 June 2019, in force from 3 July 2019) created Ukraine's military standardization system and stated directly: NATO standards also count as military standards. So Alliance documents, including the AQAP series, gained the official status of a category of Ukrainian military standard rather than remaining something external. The procedure for developing and adopting such standards was approved by Ministry of Defense Order No. 56 of 24 February 2020.

Now the specifics. AQAP-2110 Edition D was adopted in Ukraine as a military standard under the designation ВСТ 01.057.004-2021(01) "Quality of defense-purpose goods, works and services. Requirements for design, development and production quality." It was adopted together with STANAG 4107 Ed.13 by the confirmation method, as an identical translation (the IDT marker), by Order No. 70 of the Ministry of Defense's Standardization, Codification and Cataloguing Directorate, dated 17 November 2021. The standard took effect on 22 November 2021. The confirmation notice is published on the Ministry of Defense site.

There's a terminology trap here that even lawyers stumble over. ВСТ is a military standard, not a civilian ДСТУ. So it's correct to say AQAP 2110 was adopted primarily as ВСТ 01.057.004-2021, not as a "ДСТУ AQAP 2110." One more thing: sources disagree on the STANAG 4107 edition. Some write Ed.11, others Ed.13. The authoritative Ministry of Defense source pins it to Ed.13 for this ВСТ. If a consultant or certification body cites a different edition, it's worth asking what exactly they're relying on. We unpack the logic of the standard itself in our complete guide to AQAP 2110.

If you're looking for the one document everything in this story revolves around, it's the Law of Ukraine "On Defense Procurement" No. 808-IX of 17 July 2020. It's a living law that changes often. The latest revision as of our check is dated 26 December 2024 (amendments made by Law No. 4111-IX). Before any serious decision, always verify the "in force" status and the current revision on the Verkhovna Rada portal.

This law does two things that matter for our question.

First, it introduces the concept of state quality assurance (SQA), an authorized body establishing that the quality assurance processes for defense-purpose goods, works and services conform to the requirements of state contracts. Separately, it authorizes the Cabinet of Ministers to designate the SQA body and approve the procedure for its work. This is where the whole layer of resolutions we'll cover below grows from.

Second, and this is the spot where AQAP is named in the law outright, Article 17 on evaluation criteria. The law lets a state customer additionally apply, as a selection criterion, the existence of certificates of conformity to NATO standards (AQAP) under previously fulfilled state contracts. Note the word "additionally." There's no rule here saying "no AQAP, no admission." It's an additional, encouraging criterion, not a mandatory qualification barrier at the level of the law. In practice a customer may well make AQAP a hard condition of a specific tender, but that's their call within the contract, not a blanket requirement of 808-IX. Keep that distinction in mind when you read other people's categorical claims that "AQAP is mandatory by law."

Law No. 808-IX set the framework; the actual mechanism was built out by subordinate acts. This is the level where "AQAP-series standards" turn from an abstract mention into a working inspection tool.

First the Cabinet assigned the responsible authority: Resolution No. 622 of 16 June 2021 designated the Ministry of Defense of Ukraine as the authorized state quality assurance body. Then Resolution No. 781 of 28 July 2021 approved the procedure for controlling the quality of defense-purpose goods, works and services across the whole lifecycle, from development and production to modernization, repair and disposal.

Next the state locked in a strategy. Order No. 976-r of 1 November 2022 approved the Concept for creating an SQA system for 2022-2026, and action plan No. 172-r of 24 February 2023 set its implementation in motion. The Concept names the Law "On Defense Procurement" as its legislative basis and international ISO standards plus NATO AQAP-series standards as the system's normative basis. So at the level of state policy, AQAP is already baked in as the reference point.

The most recent and most concrete act is CMU Resolution No. 452 of 15 April 2025, in force from 22 April 2025. It approved the Procedure for performing state quality assurance work and defines "quality assurance standards" directly: NATO AQAP-series standards, plus national and military standards identical to the AQAP series. In other words, AQAP has been made the operational framework of the entire SQA system, for domestic suppliers and for supplies from NATO member-state entities alike. This is the strongest argument against the "AQAP doesn't apply to us" line: at the level of a current Cabinet resolution, it applies, and directly. We covered what this resolution means for a supplier in practice in a separate piece on Resolution No. 452 and quality assurance.

Alongside the new SQA system, an older control model still operates in Ukraine, through state customer representations at enterprises. These are the Ukrainian equivalent of what NATO documents call the GQAR (Government Quality Assurance Representative).

They're governed by CMU Resolution No. 1107 of 21 October 2009, which approved the Regulation on representations of state customers in the defense sphere at enterprises, institutions and organizations. The resolution is in force, with the latest revision made in 2023 (by Resolution No. 256). The representations' core function is quality control of defense-purpose products at every stage: development, production, modernization, delivery, installation and repair. The legal basis is Part 2 of Article 39 of Law No. 808-IX.

Here's an interesting point for drone makers. The text of Resolution No. 1107 itself mentions neither NATO nor AQAP. It's a purely Ukrainian acceptance model via a military representative. But the 2023 amendments introduced exceptions for unmanned systems: for UAVs and certain other systems, simplified acceptance applies, against the manufacturer's quality certificate for each unit of goods, without the classic representative at every stage. That's an acknowledgment of reality: the pace of drone production is incompatible with a Soviet-spirited model of total military acceptance.

For you, this means the following. Simplified acceptance removes some of the bureaucracy at the entry point, but it doesn't cancel the requirements for a quality system. Quite the opposite. When the state trusts your "manufacturer's quality certificate," it wants to see a mature system behind it, built to a recognizable framework. And the framework recognizable to NATO and to the customer is AQAP 2110 layered on top of ISO 9001. How those two standards relate, we break down in a separate piece on the difference between AQAP 2110 and ISO 9001.

Half the confusion among defense manufacturers comes from blending four different "NATO requirements" into one mush. Let's separate three things that are regularly confused with AQAP 2110 certification, even though they're distinct tracks.

NATO codification is record-keeping, not quality. Ukraine has been a full member of the NATO Codification System (Tier 2 level) since 2019. Through it, an item gets a stock number (NSN) and a manufacturer code (NCAGE), and the item lands in the NMCRL catalogue maintained by the NSPA agency. Ukrainian manufacturers file applications via the mil-tech.mod.gov.ua service; the process takes about 10 working days and is free. But codification assigns a number for logistics and accounting. It's not an assessment of your quality system. A drone can get NATO codification without an AQAP 2110 certificate, and vice versa. Don't conflate the two actions.

Supplier verification by the Defense Procurement Agency and the State Logistics Operator is compliance, not AQAP. The supplier check at the entry to the procurement agencies is built around the anti-bribery standard ISO 37001:2016 and a sanctions screen: no entries in anti-corruption registers, no tax debt, no bankruptcy, no ties to aggressor states. Product quality isn't assessed at this stage. It runs on the separate SQA track and through military representations. So passing supplier verification doesn't mean the quality question is closed, and the reverse holds too.

The "industrial visa-free" regime (the ACAA agreement) is about civilian products. Law No. 4831-IX on industrial visa-free trade concerns conformity assessment of civilian industrial products for access to the EU market. Since military standards are, as we saw, excluded from the scope of the Law on Standardization, the ACAA's direct relevance to defense supplies is low. It's a parallel track: the ACAA opens the European market for civilian goods, while AQAP 2110 opens NATO defense tenders. If you make both civilian and dual-use products, you may need both, but one doesn't replace the other.

Let's reduce all of this to practical takeaways you can use in a meeting without re-reading nine resolutions.

To the question "does the law oblige me to hold AQAP 2110," the honest answer has three parts. There's no direct rule saying "you must be certified." But AQAP-2110 Ed. D was adopted in Ukraine as a current military standard, ВСТ 01.057.004-2021. And the current CMU Resolution No. 452 made AQAP-series standards the official framework of state quality assurance. So in practice it's the entry ticket to a serious defense contract, legally dressed up as "voluntary."

For exports to NATO there's one more mechanism, STANAG 4107 (the same Ed.13). It's the Alliance's agreement on mutual recognition of state quality assurance: an AQAP certificate issued by an accredited body in one NATO country is accepted by procurement authorities in other countries without re-checking your management system. That's what turns AQAP 2110 from a "Ukrainian piece of paper" into a pass to international tenders. We covered the logic of supplying the Alliance in our piece on NATO-compatible supply, and the sector specifics are gathered on the defense industry page.

What to do concretely. If you already have a contract or tender on the horizon, read its qualification requirements literally and find what the customer actually demands: the AQAP 2110 certificate itself, conformity to ВСТ 01.057.004-2021, or passing SQA. These are different wordings with different consequences. If there's no contract yet but the direction is clear, the smartest first step is a diagnostic audit: in 3-5 days you'll see the gap between your current system and AQAP 2110 requirements, a realistic budget and a timeline. Skip this step and you're planning blind, then reworking things halfway through the project.

And a last piece of advice the Ekontrol team gives at every first consultation: don't wait until the customer makes AQAP 2110 a hard condition. Building a quality system to this standard takes 4-6 months for a company with a working ISO 9001 and noticeably longer from scratch. Start preparing when the contract is still on the horizon, not when it's already out to tender with a one-month deadline.