Export Controls and Cyber-Surveillance Technologies: Regulation (EU) 2021/821 and ARGA's Position

This ARGA Observatory report examines the EU export-control framework for cyber-surveillance technologies, with particular attention to Article 5 of Regulation (EU) 2021/821. It distinguishes technical classification, catch-all controls, intangible transfers, end-user assessment and the separate requirements arising from sanctions and data protection law. The report considers relevant institutional materials and enforcement examples within their respective legal limits. Six hypothetical scenarios, a model assessment file and a decision protocol support practical due diligence and implementation. This publication includes the Russian and English versions.