Insights

Significant changes are planned for the International Traffic in Arms Regulations (ITAR) and the U.S. Munitions List (USML). On July 3, 2026, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) updated its regulatory agenda, listing nine rules it intends to publish over the next 12 months. One of these rules is already published in proposed form and open for public comment; four are in or have completed interagency clearance and should be published soon. This article summarizes DDTC's latest regulatory agenda.

Regulatory Agenda

The latest regulatory agenda focuses heavily on USML-related changes, with six of the nine listed rules targeting this area. This emphasis primarily results from two converging factors: many sections of the USML have not been updated in more than a decade, and Congress mandated more frequent USML reviews in 2023. Additional drivers include recent Executive Orders from the Trump Administration intended to improve defense trade.

With the focus on the USML, several long-standing agenda items have been removed, including a proposed rule to consolidate the ITAR’s licensing provisions and exemptions and a final rule to expand the ITAR’s licensing exemption for personal protective equipment. DDTC also moved a final rule concerning “deemed exports” to its long-term list, meaning no action is expected within the next 12 months.

Notably, DDTC’s planned regulatory actions take place against the backdrop of recent rulemaking that has sought to expand the USML’s scope. For instance, the 2025 targeted revisions rule added more items than it removed, and the proposed rules for defense services and space-related controls would further expand the USML. This development marks a significant departure from the Export Control Reform era.

USML Revisions

The six USML-related rules are:

• Space-Related Controls. DDTC plans to issue an interim final rule to revise USML Categories IV and XV. While this rule primarily concerns the ITAR’s space-related controls, it will make other changes to the USML and ITAR, such as possibly adding “loitering munitions.” In October 2024, DDTC published the proposed rule and received more than 800 public comments. DDTC is preparing this interim final rule for publication and sent it for interagency clearance on June 24, 2026.
• Omnibus Targeted Revisions. DDTC plans to issue a proposed rule for targeted additions, removals, and other changes to the USML. This rulemaking likely consolidates several actions listed in DDTC’s previous regulatory agendas. Those actions included revising the semiconductor controls, updating Category XVI, modernizing the USML and Supplement No. 1 to Part 126, and responding to the public comments regarding Categories IV, V, VIII, XI, and XV from a 2018 interim final rule. DDTC is preparing this proposed rule for publication and sent it for interagency clearance on January 2, 2026.
• Firearm Suppressors. DDTC plans to issue an interim final rule to remove certain firearm silencers, mufflers, and sound suppressors. These items are currently designated as significant military equipment. DDTC is preparing to publish this interim final rule, which received interagency clearance on April 7, 2026; the companion rule for the Export Administration Regulations (EAR) received interagency clearance on July 7, 2026.
• Supplemental USML Removals. DDTC plans to publish an interim final rule to remove certain items from the USML and “to exclude certain ITAR requirements for reexports, retransfers, and temporary imports.” DDTC is preparing this interim final rule for publication and sent it for interagency clearance on December 9, 2025.
• Defense Service Controls. DDTC plans to publish a final rule to revise the ITAR’s definition of “defense service” and enumerate certain military and intelligence assistance on the USML. DDTC published the proposed rule in July 2024 and received significant public comments. The latest proposal follows three earlier iterations in 2011, 2013, and 2015. In those proposals, DDTC conceded that the current definition is “overly broad,” but the latest version seeks to expand its scope.
• Technical Data Controls and Other Changes. DDTC plans to issue a proposed rule to make several changes to the USML and ITAR. This rule would revise the ITAR’s definition of “technical data,” clarify how items are evaluated to determine whether they are described on the USML, create separate USML paragraphs for defense services and technical data, revise the ITAR’s definition of “significant military equipment,” and make other corrections and clarifications in Parts 120 and 126.

Other ITAR Revisions

The three remaining rules are:

• Clarifying Policies of Denial, Updating the Major Non-NATO Ally List, and Minor Corrections. DDTC plans to issue a final rule to “clarify certain policy-of-denial provisions,” update the ITAR’s Part 126 country policies for Ethiopia, Iraq, and Somalia, and revise the ITAR’s listing of major non-NATO allies to include Saudi Arabia and Peru, both of which received that status in January 2026. The rule also would make other minor corrections.
• Regular Employee Definition. DDTC plans to issue a second proposed rule to revise the ITAR’s definition of a “regular employee.” The proposed definition would “allow subject persons to work remotely” and “clarify the contractual relationships that meet the definition of regular employee.” The first proposed rule was published in May 2021, and public comments were critical of the proposed approach requiring certain contract employees to have a security clearance to satisfy the revised definition.
• Part 130 Requirements. The regulatory agenda also includes the proposed rule to revise ITAR Part 130 regarding the payment of certain political contributions, fees, and commissions. DDTC already published the proposed rule on June 15, 2026, and is accepting public comments through August 14, 2026. The proposed rule seeks to increase the thresholds that trigger reporting and to shift reporting from a per-transaction to an annual basis. It also seeks to create a standard form for reporting the information.

Next Steps

The public should review whether any of these rulemakings may affect them and monitor the Federal Register for their publication. Early warning of pending publication is available through the Regulatory Review Dashboard, which shows when rules are sent for interagency clearance. It is also important to be aware that the regulatory agenda does not prevent DDTC from issuing a rule that is not listed. Once a rule is published, it should be carefully reviewed to determine its impact, such as whether it moves items to or from the USML. Submitting public comments should also be considered, as they can dramatically shape the ITAR.

If you have questions about how a rule may affect you or would like to submit public comments, please contact us.

This article is for general information purposes only and does not constitute legal advice or establish an attorney-client relationship.