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UZBEKISTAN LEGAL NEWSLETTER: NOVEMBER 2025

In November 2025, Uzbekistan implemented a series of policy reforms aimed at strengthening corporate and customs legislation, liberalising the rules for the establishment and operation of businesses, and enhancing environmental protection. Several sector-specific reforms focused on technology, including Presidential decisions on the transformation of the International Digital Technologies Center “Enterprise Uzbekistan”, development of the fintech industry, and expansion of the use and protection of intellectual property.

Additional sectoral measures addressed private sector access to public railway infrastructure, development of the tourism sector, and improvements to the registration regime for medicines and medical devices. Finally, following President Mirziyoyev’s visits to the United States in September and November 2025, a Presidential Decree was issued to further enhance United States–Uzbekistan relations.

 1.  IMPROVEMENT OF CORPORATE AND CUSTOMS LEGISLATION

A Law has been adopted to improve corporate and customs regulation. It will enter into force on 28 February 2026 and will, among other things, introduce the following changes:

  • the introduction of the concept of a majority shareholder for joint-stock companies, defined as a person holding more than 50% of voting shares or otherwise able to exercise decisive influence. A majority shareholder must not act in its own interests where this would harm the company or other shareholders, nor propose agenda items that would do so;

  • the introduction of the concept of fiduciary duties for company directors, members of supervisory and management boards, and trustees of joint-stock companies, including duties to act in the best interests of the company and shareholders, avoid conflicts of interest, comply with non-compete and confidentiality obligations, and refrain from misuse of company assets or opportunities. These duties may be further specified by law, the company’s charter or internal documents;

  • instead of the application of doubled customs tariff rates to goods originating from non-most-favoured-nation countries and goods of unknown origin, additional customs fees will be applied, calculated based on the applicable ad valorem customs duty rate for such goods.

Law No. ZRU-1097 of 27 November 2025

 2.  LIBERALISATION OF BUSINESS REGULATION

The President has signed a Decree aimed at reducing the administrative burden on businesses and optimising their time resources. The Decree, among other things, provides for the following:

  • from 1 January 2026, the “Start a Business in 15 Minutes” principle will apply, under which, during the registration of a business entity, the following services may be provided simultaneously at the applicant’s discretion: issuance of an electronic digital signature; opening and activation of bank accounts; submission of applications for licences, permits, or notifications; execution of real estate lease agreements; issuance of a VAT payer certificate; purchase and registration of an online cash register with the tax authorities; and appointment of a legal entity’s director with his/her registration in the Unified National Labour System;

  • from 1 March 2026: (i) fines imposed on legal entities for licensing and permitting violations will no longer trigger administrative liability for their officials (including directors); and (ii) the “License” e-system will introduce a voluntary preliminary compliance assessment service, allowing verification of facilities, equipment, personnel, and other requirements within up to 20 days, subject to a fee equivalent to the application fee;

  • the Roadmap for Reducing State Regulation and Bureaucracy in Business (set out in the Annex to the Decree) has been approved, envisaging the abolition of 10 types of licenses and permits, adoption of a revised Law “On Company Names”, and expedited issuance of various licenses and permits.

In addition, a Law amending the licensing legislation has been adopted. Scheduled to enter into force on 28 February 2026, it will require non-resident legal entities to submit applications for licences, permits, and notifications only through their registered permanent establishments in Uzbekistan, with the exception of certain one-time licences related to foreign economic activities and transit cargo transportation.

Law No. ZRU-1099 of 27 November 2025

Presidential Decree No. UP-214 of 14 November 2025

 3.  ECOLOGICAL POLICY REFORMS

On 18 November 2025, Presidential decisions were adopted to reform the government’s environmental policy framework and to significantly strengthen the focus on ecological and climate issues. Key measures include:

  • the Ministry of Ecology, Climate Change, and Environmental Protection has been transformed into the National Committee on Ecology and Climate Change, institutionally separated from the rest of the government and directly accountable to Parliament and the President;

  • a specialised Ecological Police has been established under the Committee as a law-enforcement authority;

  • from 1 March 2026:
    • all existing legal acts and binding instructions granting exemptions from compensation for environmental harm will cease to apply;
    • public authorities will be prohibited from granting exemptions from environmental compensation payments unless expressly authorised by law (and not by subordinate legislation);
    • the issuance of documents exempting compliance with environmental legislation or granting permits without such compliance - including state environmental expertise conclusions and governmental or inter-agency acts authorising the cutting or relocation of trees and shrubs - is strictly prohibited.

A more detailed overview of these changes is available in our dedicated publication at this link.

Presidential Resolution No. PP-343 of 18 November 2025

Presidential Decree No. UP-217 of 18 November 2025


 4.  TRANSFORMATION OF INTERNATIONAL DIGITAL TECHNOLOGIES CENTRE “ENTERPRISE UZBEKISTAN”

The President has signed a Decree on the development of the International Digital Technologies Centre “Enterprise Uzbekistan” located within IT Park Uzbekistan (the Centre). The Decree is effective immediately and, among other things, provides that:

  • the Centre’s directorate will be a joint-stock company, wholly owned by LLC “Directorate of the Technology Park of Software Products and Information Technologies”;

  • Centre residents will operate under a special legal regime, covering tax and customs administration, employment, personal data protection, intellectual property, public services, and dispute resolution, as determined by the Centre’s Management Board. The Centre is recognised as a separate jurisdiction based on the principles of English common law or the standards of leading international financial centres;

  • permitted activities within the Centre include software development, digital outsourcing (including BPO), R&D, GameDev and digital content creation, online platforms and software solutions, AI technologies, data centres and cloud services, digital education, and other activities approved by the Management Board;

  • disputes involving Centre residents and other business entities (by agreement) may be resolved by a specialised independent international court, outside the national court system;

  • a specialised tax inspectorate will operate within the Centre on a one-stop-shop basis, including services in English;

  • non-resident companies may provide financial, investment, legal, and consulting services in the Centre, but without resident privileges;

  • within 3 months, the Cabinet of Ministers must develop a Constitutional Law on the International Digital Technologies Centre.

Presidential Decree No. UP-233 of 26 November 2025

 5.  DEVELOPMENT OF FINTECH INDUSTRY

The President has signed a Resolution aimed at developing the fintech industry, which, among other things, sets out the following:

  • the goals for 2026–2030 include: (i) attracting USD 1 billion in investment for start-ups; (ii) increasing the number of fintech market participants to 200; and (iii) piloting digital currency and stablecoins backed by local and foreign currencies as legal tender;

  • a venture fund will be established under the Central Bank of Uzbekistan (CBU) in the form of a limited liability company with authorised capital of USD 50 million to finance start-ups. By 1 July 2026, the CBU shall develop a proposal to engage a reputable foreign company with international experience in venture fund operations, venture capital management, and financial technologies as a fiduciary manager;

  • an innovation hub will be created under the CBU to support start-ups by: (i) implementing incubation and acceleration programmes and facilitating entry into international markets; (ii) assisting with the attraction of domestic and foreign venture investment; and (iii) administering grant programs;

  • from 1 January 2026, a special regulatory sandbox will be introduced to regulate the use of stablecoins as a means of payment, including the implementation of pilot projects for payment systems based on distributed ledger technology;

  • from 1 January 2026, resident legal entities will be permitted to issue tokenised shares and bonds, and licensed stock exchanges will establish a dedicated platform for trading such tokenised assets. The National Agency for Perspective Projects will determine the rules governing their circulation;

  • by 1 September 2026, an open banking system will be launched to ensure secure and standardised data exchange between banks, payment organisations, and other fintech market participants;

  • a Roadmap for Support of the FinTech Industry for 2025–2026 is set out in Annex 4 to the Resolution.

Presidential Resolution No. PP-359 of 27 November 2025

 6.  USE OF INTELLECTUAL PROPERTY

The President has signed a Resolution aimed at increasing the share of intellectual property in the national economy and stimulating the development of modern technologies. The Resolution is effective immediately and, among other things provides for the following:

  • targets for 2026–2027 include increasing the number of registered IP objects to 100,000 and the number of registered geographical indications to 40 through the promotion of national brands, halving IP examination timelines through the use of AI, and completing digitalisation of inter-agency workflows;

  • IP rights may be used as loan collateral, with pledge agreements to be registered with the Ministry of Justice;

  • patent attorneys are allowed to represent clients in IP-related civil, commercial, and administrative court proceedings;

  • an “Intellectual Property Protection” platform will be established under the Ministry of Justice to enable submission of applications, execution of IP contracts, and reporting of counterfeit products and infringing websites;

  • the Ministry of Healthcare must verify trademarks and industrial designs via the IP Portal before issuing permits for the import and production of biologically active substances;

  • a Roadmap for the Development of the Intellectual Property Sector is set out in Annex 1 to the Resolution.

Presidential Resolution No. PP-358 of 27 November 2025

 7.  ACCESS RULES FOR PUBLIC RAILWAY INFRASTRUCTURE

As part of the government’s broader initiative to introduce private sector participation in the railway transportation sector, the Cabinet of Ministers has adopted a Resolution establishing rules for access to public railway infrastructure, effective from 16 February 2026. Under the Resolution, railway carriers may access public railway infrastructure by entering into long-term infrastructure services agreements (for at least five years) with an operator, being a legal entity wholly owned by state-owned JSC “Uzbekistan Railways”.

To initiate such agreements, carriers must submit service orders to the operator, supported by either a bank guarantee or a cash deposit. Infrastructure services include, among others, the provision of locomotives and locomotive crews, train operations management, traffic control, and storage of empty wagons. Uniform tariffs for infrastructure services will be approved by a collegial body authorised by the Cabinet of Ministers.

Resolution of the Cabinet of Ministers No. 723 of 14 November 2025

Presidential Decree No. UP-210 of 11 November 2025

 8.  REGISTRATION OF MEDICINES AND MEDICAL DEVICES

The Cabinet of Ministers has adopted a Resolution introducing new registration procedures for medicines and medical devices, replacing the previous regulations. The Resolution enters into force on 26 February 2026 and, among other things, provides that:

  • medicines may be registered under either traditional or simplified recognition procedures; recognition applies to products previously registered by WHO Listed Authorities or regulators assessed at Maturity Level 4 under the Global Benchmarking Tool;

  • medicines subject to registration include finished medicinal products (excluding active pharmaceutical ingredients), new combinations of previously registered products, products registered in new dosage forms, strengths or by new manufacturers, and certain modified cell-based biotechnology products;

  • medical devices may also be registered under traditional or simplified recognition procedures, with recognition applying to products previously registered by the FDA (USA), CE-certifying authorities (EU), EMA (EU), PMDA (Japan), MFDS (Korea), or MHRA (UK);

  • reagents within in vitro diagnostic kits without independent diagnostic capability and custom-manufactured equipment are exempt from registration;

  • registration schemes and timelines, as well as documentation requirements for medicines, are set out in Schedules 1 and 3 of Annex 1 to the Resolution, respectively, and for medical devices in Schedules 1 and 3 of Annex 2 to the Resolution, respectively.

In addition, the Cabinet of Ministers has approved a Resolution streamlining public procurement of medical products. From 1 July 2026, all procurement will be conducted exclusively through the electronic platform “Farma.xarid.uz”, initially operating within the UzEx system. Procurement will be limited to GMP-certified pharmaceutical manufacturers, ISO 13485-certified medical device manufacturers, and GDP-certified distributors, provided that manufacturing dates fall within the validity of the relevant certificates. Within 3 months of the Resolution, the platform will also support market research for determining baseline prices for medical products.

Resolution of the Cabinet of Ministers No. 737 of 21 November 2025

Resolution of the Cabinet of Ministers No. 738 of 24 November 2025

 9.  DEVELOPMENT OF TOURISM SECTOR 

The President has signed a Resolution on the development of the tourism sector, which, among other things, provides for the following:

  • targets for 2030 include increasing tourism’s share of GDP from 3.5% to 7%, doubling the number of foreign tourists from 10 million to 20 million, increasing annual tourism service exports to USD 6 billion, improving transport connectivity between key tourist cities with at least a threefold reduction in travel time, and doubling the number of four- and five-star hotels;

  • a Tourism Strategy until 2040 will be prepared, and major projects will be implemented, including a new tourist route in Samarkand, a smart museum city in Khiva, and promotion of Tashkent’s modernist architecture;

  • the Tourism Committee will submit proposals to expand the list of countries whose nationals are eligible for visa-free entry into Uzbekistan;

  • from 1 February 2026, foreign nationals will be eligible for VAT refunds in cash on purchases made in Uzbekistan upon exit from the country;

  • from 1 May 2026, hotels may recover 50% of expenses incurred in achieving international standards;

  • until 1 January 2027, and subject to the requirements of Annex 5 to the Resolution:
    • buses, electric buses, and minibuses imported by tourism companies will be exempt from import duties; and
    • licensed tour operators registered in Karakalpakstan may pay customs duties and recycling fees for importing off-road vehicles for extreme tourism at 25% of the applicable rate, payable in instalments over 3 years;
  • the Action Plan for Further Development of the Tourism Sector (Annex 6).

Presidential Resolution No. PP-348 of 19 November 2025

 10.  DEVELOPMENT OF UZBEKISTAN-US RELATIONS

Following President Mirziyoyev’s visits to the United States in September and November 2025, a Presidential Decree has been issued establishing the Uzbek–American Business and Investment Council (the Council). Its provisions include:

  • the Council will focus on:
    • coordinating strategic business initiatives and major investment and trade projects;

    • establishing a special investment fund with the US Development Finance Corporation and an Uzbek partner as anchor investors, with potential participation from the EBRD, IFC, and ADB;

    • negotiating mutual tariff reductions;

    • promoting IT Park residents’ products and services; and diversifying Uzbekistan’s investment portfolio, including part of its foreign exchange reserves;
  • additional consulates will be opened in the United States to engage with key industry hubs and ensure broader geographic coverage;

  • within 1 month of the Decree, negotiations will commence on a bilateral investment treaty between the United States and Uzbekistan;

  • from 1 January 2026, Uzbek residents may freely transfer funds from Uzbek bank accounts to US bank accounts for investment purposes (including capital contributions and branch financing), within available account balances.

In addition, a separate Decree allows US citizens to enter Uzbekistan visa-free for up to 30 days starting from 1 January 2026.

Presidential Decree No. UP-203 of 3 November 2025



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