The latest amendments to the DTCA are designed to strengthen regulatory oversight on the export, supply, publication, and brokering of controlled military and dual-use technologies. From 1 March 2025, breaches of these provisions will carry criminal penalties, underscoring the Australian Government’s commitment to national security and its international trade obligations.
For industry stakeholders, these changes mean:
· Stricter permit requirements managed through Defence Export Controls (DEC).
· Expanded record-keeping obligations, including for exports conducted under exemptions.
· Increased compliance reporting requirements, such as voluntary disclosures for non-compliance.
· Enhanced self-audit expectations to ensure ongoing regulatory adherence.
Australia Defence Export Controls has provided a helpful bulletin below to support this transition.
DEC Bulletin
Compliance Transition Period Ends
On 1 March 2025, the criminal penalty provisions for each of the three new permit types (Section 10A, 10B and 10C) take effect.
Compliance
It is important to have clear policies and procedures around actions, processes, and behaviours that enable you to meet your compliance obligations under Australia’s export controls law. This broadly includes:
attaining permits from DEC when required
keeping records, both under permits and when relying on an exception
adhering to the licence-free environment terms and conditions (if relevant)
completing a DEC Compliance Report across two categories:
a report outlined as a condition of a DEC permit or certificate
making a voluntary disclosure (if non-compliance is detected).
conducting a self-audit.
These activities can be conducted through the MADE Portal. Visit our Compliance webpage for more information.
DEC is here to help
DEC has a range of online resources available to assist with compliance.
DEC Guidance, FAQs and online eLearning modules: Outreach and training
Overview of Australia’s Export Control Framework: Legislation
MADE portal guides and factsheets: My Australian Defence Exports portal
Outreach
We are pleased to see many attendees participate in outreach activities over the past 3 months. More than 1,100 people attended these events. Session recordings, along with other guidance materials, are available on our outreach and training webpage.
Next Steps for ECAG Members
With the compliance transition period now ending, organisations should take the opportunity to review internal policies, train key personnel, and ensure alignment with the updated requirements before enforcement begins.
If you haven't yet implemented Technology Trade Control Plans or evaluated your Supply Chain to comply with the new Permit Requirements, it is now a pressing priority in order to avoid criminal offense penalties.
• Conduct a Compliance Audit: Review your organisation’s policies and procedures to ensure they align with the updated DTCA provisions.
• Engage with Legal & Compliance Teams: Seek advice to understand how these changes affect your operations and the necessary steps to achieve compliance.
• Attend Industry Briefings: Stay informed through ECAG and official government updates, workshops, and training sessions.
• Update Internal Processes & Training: Ensure all relevant personnel are aware of and trained in the new compliance requirements before 1 March 2025.
The ECAG will continue to provide resources, guidance, and industry engagement opportunities to support our members through this transition. We encourage all members to proactively assess their exposure and take the necessary steps well ahead of the compliance deadline. Please reach out to us with any concerns or questions.
For further details, refer to the Department of Defence – Defence Export Controls (DEC) website or reach out to ECAG for additional support.
Stay Compliant – Stay Informed
We look forward to working together to navigate these changes successfully. If you have any questions or require further information, please do not hesitate to get in touch.
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