UZBEKISTAN LEGAL NEWSLETTER: JULY 2025

On 7 July 2025, the Law "On the Limitation of Greenhouse Gas Emissions" was adopted. It enters into force on 9 January 2026 and, among other things, introduces the following:

• the Law defines greenhouse gases (GHG), GHG emissions and reductions, carbon footprints, carbon credits, green projects, and participants of the carbon credit trading market. Projects aimed at reducing GHG emissions are qualify as green projects, with detailed eligibility criteria to be approved by the Cabinet of Ministers;
  
  
• carbon credits must be verified before issuance. Their disposal is managed by the government of Uzbekistan. Private entities may sell part of the credits generated in Uzbekistan to foreign buyers only with the approval of the Ministry of Economy and Finance (MoEF). The Cabinet of Ministers will establish procedures for such sales;
  
  
• entities emitting GHG will be included in a special register maintained by the MoEF. Regulated entities must submit annual reports to the MoEF by 1 July, which will be published to ensure transparency. The Cabinet of Ministers will define: (i) criteria for inclusion in the register; (ii) reporting procedures; and (iii) reports verification rules;
  
  
• the Ministry of Ecology, in coordination with the MoEF, will maintain the GHG emissions register (inventory), and the GHG cadastre, as well as collect compensation payments from emitters;
  
  
• the Green Energy Projects Centre under the MoEF will operate the carbon credit registry. Credits will be held in accounts opened with the Centre, and all registry operations will be conducted under a contract with it. The Cabinet of Ministers will approve: (i) procedures for maintaining the register and (ii) a model agreement governing registry operations and operator fees;
  
  
• within 3 months of the Law’s adoption, the Cabinet of Ministers will approve industry-specific target parameters for reducing GHG emissions.

Additionally, the President has adopted a Resolution regulating the participation in the international market of carbon credits:

• by 2030, GHG emissions per unit of national GDP are to be reduced by 35% compared to 2010 level;
  
  
• carbon credits may be generated only in sectors covered by the Nationally Determined Contributions[1] and specified in the national GHG inventory, with priority given to credits created through international climate finance;
  
  
• 20% of domestically generated carbon credits will be reserved to meet Uzbekistan’s emission reduction commitments and to prevent overselling, and will not be traded internationally. The remaining 80% will be sold on the international carbon market, except for credits from projects with state participation (PPPs or other forms), which will be managed by the Cabinet of Ministers. For such projects, the Cabinet of Ministers will determine the volume of credits to be sold, the procedure for engaging servicing organizations, and the distribution of sale proceeds;
  
  
• а state duty will be imposed on each carbon credit unit, with the rate to be determined by the Cabinet of Ministers;
  
  
• the national carbon credit register as mentioned in the Law will be launched by 1 January 2026;
  
  
• the MoEF will oversee the implementation of carbon credit projects and issue approvals for them. By 1 January 2026 , it shall submit proposals to amend the Law "On Licensing, Permitting, and Notification Procedures" to introduce permits for: (i) implementing carbon credit projects; (ii) selling generated carbon credits; and (iii) approving the volumes of credits to be sold;
  
  
• within 2 months of the Resolution, the MoEF shall submit to the Cabinet of Ministers a draft regulation on participation in international carbon credit markets;
  
  
• within 3 months of the Resolution, the MoEF shall prepare a list of promising green projects.

[1] Under Article 4 of the Paris Agreement, member states set out their objectives and plans - known as Nationally Determined Contributions (NDCs) - to reduce GHG emissions.

Law No. ZRU-1073 of 7 July 2025  
Decree of the President № UP-110 of 7 July 2025

 2.  ADOPTION OF WATER CODE

On 30 July 2025, a new Water Code was adopted to consolidate water regulations. It will enter into force on 31 October 2025, replacing, among other acts, the current Law "On Water and Water Use". The Code, among other things, provides for the following:

• the Code introduces legal definitions of water bodies, water facilities, hydraulic structures, and water users. Water bodies are recognised as state property and a national treasure, while water facilities may be publicly or privately owned. Facilities constructed by private entities remain in their ownership;
  
  
• water may be used for: (i) drinking, household, recreational, therapeutic, and other personal needs; (ii) agricultural, forestry, and hunting purposes; (iii) industrial, energy, transport, and other state or public needs; and (iv) wastewater discharge;
  
  
• general use of water bodies covers everyday activities without special equipment and does not require a permit. Special use requires a permit when abstracting more than 5 m³ of water per day, operating pumping stations or hydroelectric plants, or discharging wastewater or collector–drainage water into water bodies or onto land;
  
  
• water bodies and facilities may be transferred for permanent (without a set time limit) or temporary use (for a minimum of 3 years and a maximum of 49 years) or operated under PPP arrangements. Outsourcing and PPP projects must be awarded through competitive selection, with direct negotiations prohibited. Private partners are required to supply water, ensure metering and accounting, and modernize facilities within their service zones. Small water facilities may be privatized through auctions, while larger facilities may be managed under PPPs pursuant to a Presidential Decree or a Resolution of the Cabinet of Ministers;
  
  
• water abstraction is permitted only under agreements with the State Institution “Water Supply Service” at registered intake points. Users must submit requests physically or electronically;
  
  
• the Ministry of Water Resources (MoWR) is designated as the specialised authority for water matters, responsible for maintaining water resource accounting, issuing permits, and ensuring delivery of water within approved limits;
  
  
• easements may be established for general use of water resources, passage of individuals and vehicles, watering and driving livestock, use of water bodies as waterways for small vessels, and access to or crossing of coastal zones. Public easements are set by municipalities, while private easements are established by agreement or court decision. Easements do not require a special water use permit, may be subject to charges, and remain valid despite changes in land ownership;
  
  
• new and reconstructed industrial facilities must include recirculating (closed-loop) water supply systems, unless technically impossible. Existing enterprises without such systems must agree with the MoWR and the Ministry of Ecology on a transition deadline;
  
  
• payments for water use include: (i) water use tax; (ii) fees for water delivery and related services; (iii) payments for purchasing abstraction quotas (quota assignment); (iv) fees for exceeding usage limits; and (v) compensation for environmental pollution. Water supply fees may be partly or fully included in the water use tax.

Water Code of 30 July 2025