Despite significant defence trade reforms under the AUKUS agreement, U.S. export controls still apply to nuclear submarine technology, hampering Australia's ability to participate fully in co-producing Virginia-class submarines.

Defence Minister Richard Marles said last month, ‘Whether the United States can overcome production delays to meet U.S. Navy targets are key to whether Australia can buy three Virginia-class nuclear powered submarines under AUKUS.’ Australia faces a 2025 deadline to pay $2 billion of the $3 billion it has pledged to improve the U.S. submarine industrial base.

Attempts to bring Australian companies into the Virginia submarine's U.S. supply chain have made slow progress. Australia, the United States and Britain removed significant barriers on defence trade between AUKUS countries in August, with 70% of defence exports from the United States to Australia, previously subject to the U.S. International Trafficking in Arms Regulations, becoming licence-free. A lengthy licence process remains for an Excluded Technology List, which largely covers advanced or sensitive defence areas. Kylie Wright, Assistant secretary of defence industry at Australia's Department of Defence said "Submarine technology is on the excluded technologies list, meaning it is not going under the AUKUS exemption." Seamless transfer of technology and information between Australia and the U.S. is key to the success of AUKUS.