CMU Resolution No. 452: NATO AQAP-Series Standards Become the Official Basis of Defense State Quality Assurance

Cabinet of Ministers Resolution No. 452 of 15 April 2025, in force from 22 April 2025, approved the Procedure for performing state quality assurance work for defense-purpose goods, works and services. Its key provision for a manufacturer is simple: the definitions now include quality assurance standards, and those are, directly, NATO AQAP-series standards, plus national and military standards identical to the AQAP series.

In other words, at the level of a current resolution the state has made AQAP the operational framework of the entire quality assurance system, for domestic suppliers and for supplies from entities of NATO member states and partner states under foreign trade contracts alike. That closes the old "AQAP is somewhere over in NATO, it doesn't concern us" debate. It does concern you, and it's written into the text of the resolution word for word.

The event isn't fresh on the calendar, the resolution has been working for over a year. But for most defense manufacturers only now reaching serial contracts and exports, its practical consequences are becoming tangible right about now.

Resolution No. 452 didn't appear out of nowhere. It's the latest element in a chain stretching back to the base law.

It all starts with the Law "On Defense Procurement" No. 808-IX of 17 July 2020. It introduced the concept of state quality assurance and authorized the Cabinet to designate the responsible body and approve the procedure for its work. The state then built out the mechanism step by step: Resolution No. 622 (2021) named the Ministry of Defense as the quality assurance body, Resolution No. 781 (2021) set quality control across the whole lifecycle, and Order No. 976-r (2022) approved the system Concept for 2022-2026, naming ISO standards and NATO AQAP-series standards as its normative basis.

Resolution No. 452 completed this logic: what was a policy reference point in the Concept became a working definition in the procedure for performing work. That's the difference between "the state plans to move toward AQAP" and "the state assesses quality against AQAP", the second carries direct weight for a supplier. The full breakdown of the regulatory basis is in our piece on whether AQAP 2110 is mandatory in Ukraine.

In parallel with the resolutions, the standard is already integrated into law as a document. AQAP-2110 Edition D was adopted in Ukraine as the military standard ВСТ 01.057.004-2021(01), together with STANAG 4107 Ed.13, 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. It took effect on 22 November 2021; the confirmation notice is published on the Ministry of Defense site.

Note the terminology: this is a ВСТ, a military standard, not a civilian ДСТУ. So you won't find AQAP 2110 in the register of civilian ДСТУ standards. Together, Resolution No. 452 and ВСТ 01.057.004-2021 form a "what to apply" and "how to verify" pair: the standard sets the requirements for the quality system, and the SQA procedure sets how conformity to those requirements is assessed.

The Procedure doesn't stop at definitions. It spells out the actual sequence of work the authorized body performs. Under clause 5, the procedure runs through seven steps:

1. setting quality assurance requirements based on risk identification and analysis;
2. forming a request to carry out the work;
3. developing a plan of measures and work;
4. assessing the conformity of the quality management system of the selection participant or contractor;
5. monitoring how the contractor's quality management system functions;
6. inspecting production processes;
7. compiling reporting materials.

The result is a certificate of conformity valid for three years (clause 36 of the Procedure). This isn't a one-off checkbox: the state confirms the status of your quality system for a limited period, and you'll have to renew it. So budget the resource for maintaining the system and recertification up front, not a month before the term runs out.

It's easy to jump to "so AQAP is mandatory now." That's not quite right, and the detail matters.

Under the Law "On Standardization" No. 1315-VII, standards in Ukraine apply voluntarily until a separate act establishes their mandatory status. Resolution No. 452 makes AQAP-series standards the framework of state quality assurance, that is, the reference point against which the authorized body assesses a supplier's processes. It's a strong link, but it works through the contract and the SQA procedure, not through a direct rule saying "you must be certified."

In practice, for a serious defense contract the distinction dissolves: if the customer runs quality assurance against the AQAP framework, a supplier without a matching system simply won't pass. So de facto it's the entry ticket, even when the standard's formal status is voluntary.

A few practical takeaways while the sector moves en masse toward serial contracts and exports to NATO.

First, read the tender documents literally. Find what the customer actually requires: an AQAP 2110 certificate, conformity to ВСТ 01.057.004-2021, or passing state quality assurance. These are different wordings with different consequences for timelines and budget.

Second, don't confuse quality assurance with adjacent procedures. NATO codification (assigning an item number) and supplier verification at a procurement agency (an anti-corruption screen against ISO 37001) are separate tracks that don't close the quality-system question. Count them separately. And don't confuse AQAP with the "industrial visa-free" regime either: the ACAA agreement, which we covered in the news on the signing of Law 4831, concerns civilian products for the EU market, not defense supplies.

Third, if the contract is still on the horizon, the smartest move is to start with a diagnostic audit: in 3-5 days you'll see the gap between your system and AQAP 2110 requirements, a realistic budget and a timeline. Building a system to this standard takes 4-6 months for a company with a working ISO 9001, and noticeably longer from scratch.

Fourth, don't put off preparation until the customer makes AQAP a hard tender condition with a one-month deadline. A quality system isn't built in two weeks, and it's the part you can't compress with nice-looking charts. The sector context and the full list of standards are on the defense industry page.