Uzbekistan

Uzbekistan’s approach to personal data protection is rapidly evolving in response to the increasing digitalization of its economy. With the expansion of e-commerce platforms, fintech solutions, telecom services, and digital public services, the volume and sensitivity of collected personal data have surged, intensifying the need for robust safeguards. The country has developed a structured regulatory system that now reflects many aspects found in advanced jurisdictions. Legal norms governing the collection, processing, and storage of personal data are no longer perceived as abstract formalities but as enforceable compliance obligations, particularly for entities in regulated sectors. Recent legislative initiatives, including Presidential Decree No. PP-153 dated 30 April 2025, mark a turning point in regulatory enforcement. New requirements for the financial sector, such as compulsory breach notifications and legal liability for data incidents, signal a shift from declarative norms to practical accountability. These measures are designed to embed cybersecurity and data governance into the operational fabric of financial institutions. Local businesses are beginning to adapt, with a noticeable increase in compliance awareness and internal policy development. However, challenges remain, especially in aligning internal processes with localization rules, obtaining valid consent, and managing cross-border data transfers within the constraints of the law. For foreign companies, navigating Uzbekistan’s personal data framework is becoming a non-negotiable element of market entry strategy. Compliance is not only a legal requirement but a critical factor in maintaining consumer confidence and mitigating reputational risk in a data-conscious environment. Data Privacy Rules in Uzbekistan / Legal framework Personal data compliance in Uzbekistan extends beyond a mere meeting of formal legal obligations to avoid fines and penalties. Companies that establish comprehensive compliance programs showcase their dedication to responsible and transparent handling of personal data. This strengthens brand integrity, cultivates trust among consumers and partners, and supports long-term resilience in a rapidly evolving digital landscape. The cornerstone of Uzbekistan’s data protection regime is the Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 dated 2 July 2019. This law establishes the legal framework for processing personal data in Uzbekistan. It defines key terms, outlines data subjects' rights, sets requirements for data controllers and processors, mandates data localization, and introduces consent, security, and registration obligations to ensure lawful and transparent data use. A number of regulations further clarify the obligations: Resolution No. 71 of the Cabinet of Ministers of the Republic of Uzbekistan dated 08 February 2020 «On approval of the Regulation on the State Register of Personal Data Bases» outlines the procedure for registering databases containing personal data, establishes the responsible authority, sets timelines for registration decisions, and defines exceptions. The goal is transparency and regulatory oversight in data processing. Resolution No. 570 of the Cabinet of Ministers of the Republic of Uzbekistan dated 5 October 2022 “On the Approval of Certain Regulatory Legal Acts in the Field of Personal Data Processing” establishes two regulations, governing the protection levels of personal data, and material carriers located outside the personal data databases. Orders No. 3477 and No. 3478 issued by chairman of the Ministry of Justice of the Republic of Uzbekistan “On the Approval of the Standard Procedure for Processing Personal Data”, registered on 15 November 2023, define the rules for processing and protecting personal data, including key principles, purposes, and the rights and duties of the database owner and operator. Furthermore, matters related to personal data regulation in Uzbekistan are supported by the Law of the Republic of Uzbekistan “On Informatization” No. 560-II dated 11 December 2003 and “On Cybersecurity” No. ZRU-764 dated 15 April 2022. International Standards In Uzbekistan, several key standards from the ISO/IEC 27000 series have been officially adopted at the national level. These as well include O‘zDSt ISO/IEC 27002:2024 [1], offering guidance on security controls, and O‘zDSt ISO/IEC 27005:2024 [2], which focuses on risk assessment and management. Their adoption demonstrates Uzbekistan’s commitment to aligning domestic cybersecurity practices with global frameworks. In addition, while not directly applicable in Uzbekistan, EU General Data Protection Regulation (GDPR) remains a globally recognized benchmark for data protection and continues to shape best practices worldwide. Therefore, GDPR may often serve as a model for shaping internal compliance programs and contractual documentation, particularly among companies engaged in cross-border activities or cooperating with EU-based partners. Key Requirements for Handling Personal Data in Uzbekistan The legislation sets out the circumstances under which the processing of personal data by the data owner or operator is considered lawful. These include: processing based on the data subject’s consent; processing for the performance of a contract with the data subject or in the data subject’s legitimate interests; processing by the data operator to fulfill obligations established by law; processing for statistical or other research purposes after data anonymization; processing of personal data that is publicly available.[3] Uzbek legislation does not mandate a rigid structure as to the order and data collection practices. However, it requires that the collection of data be proportionate to the stated purposes.[4] In this context, consent becomes the central legal ground for most forms of data processing. Notably, data collection, provision to third parties, dissemination through publicly accessible sources, and cross-border transfers to countries with inadequate protection levels may only be carried out with the explicit consent of the data subject. Where such actions fall outside the originally declared purposes for which consent was obtained, an additional, separate consent must be secured before proceeding.[5] While Uzbekistan’s legal framework provides operators with a degree of flexibility in how they structure their data collection practices, this flexibility is counterbalanced by clear legal obligations that safeguard the rights of data subjects. Therefore, companies must adopt clear internal policies and ensure that each data collection activity is aligned with the purposes communicated to data subjects and documented through valid consent. Consent Requirements One of the primary legal bases for the processing of personal data under Uzbek law is the explicit consent of the data subject.[6] Uzbek law places particular emphasis on consent not only as a general basis for data processing, but also as a mandatory prerequisite for the transfer, dissemination, or cross-border transmission of personal data. If such activities exceed the originally declared processing purposes, renewed and specific consent must be obtained from the data subject.[7] Under Uzbek law, valid consent must contain the following essential elements: The full legal name of the data operator and its Taxpayer Identification Number (TIN); for individuals, the full name and Personal Identification Number of an Individual (PINFL); The full name of the data subject and the details of the identification document; The clearly defined purposes for data processing; A list of personal data to be processed, explicitly specified in the consent; The term or duration for consent validity; Whether the data is permitted to be transferred to third parties and/or across borders; Whether the data may be distributed in publicly accessible sources; Any other relevant information necessary to ensure informed consent.[8] Consent form Consent must be obtained in a manner that allows for confirmation of its receipt by the operator, regardless of the form used.[9] With respect to special categories of personal data such as biometric, genetic, or health-related information, the law requires that consent be provided in written form.[10] State Registration of Personal Data Databases Prior to commencing the processing of personal data, database owner/operator, must register their databases in the State Register of Personal Data Databases.[11] Applications for registration of database must be submitted to the authorized body – State Personalization Center under the Cabinet of Ministers of Republic of Uzbekistan.[12] The process of database registration takes up to 15 days.[13] Within that period, the State Personalization Center decides on granting registration. In the event of approval, the Centre issues Certificate of Registration of the personal data database in the State Register. In the event of a refusal, a formal decision denying registration is provided. Under Uzbek law, certain personal data databases are exempt from registration. These include data used internally by organizations, public data, basic identity details, access logs, non-automated processing, data in state systems, or data processed under labor laws provided they are not disclosed to third parties or used for broader processing purposes.[14] Personal Data Localization and Storage Requirements in Uzbekistan Uzbek law requires that personal data of Uzbek citizens be stored on servers physically located within the country.[15] This data localization rule applies to both local and foreign businesses operating in Uzbekistan. Although the requirement has raised concerns, especially among foreign companies regarding cost and technical feasibility, it remains a legal obligation. A high-profile example of enforcement is TikTok, which was blocked in Uzbekistan in 2021, partly due to non-compliance with these localization rules. This case demonstrated the government’s serious approach to data sovereignty, even in relation to global platforms.   Compliance Options: Using certified local data centers. Adopting hybrid cloud solutions that ensure primary hosting is based in Uzbekistan. Planning infrastructure early to avoid costly restructuring later. Biometric and genetic data carriers must be labeled as “confidential” or “for official use”[16] and stored securely in fireproof, flood-resistant environments with surveillance and access control.[17] Encryption is required for digital protection.[18] Companies must track carriers, meet fire and sanitary standards, and follow formal procedures for reuse or destruction after use.[19] Safeguarding Personal Data The Cabinet of Ministers is authorized to determine the level of protection applicable to various categories of personal data and establish technical and organizational safeguards.[20] This is operationalized through two key regulations: The regulation on determining levels of personal data protection in their processing, approved by the Cabinet of Ministers on October 5, 2022; The regulation on requirements for material carriers and storage technologies for biometric and genetic data outside of databases of personal data, approved by the Cabinet of Ministers on October 5, 2022. According to these regulations, personal data must be classified into different protection levels based on the types of threats they face. The higher the threat level, the stricter the data protection requirements. This includes physical security, role-based access control, encryption, use of certified information protection systems, and internal audits. Cross-border transfers Transfers of personal data outside Uzbekistan are restricted to jurisdictions that ensure adequate protection.[21] If a country is not recognized as providing such protection, transfers may still take place, but only with the explicit consent of the data subject or where required by law or international treaty.[22] Uzbekistan does not yet publish a definitive list of adequate countries, placing the burden on businesses to evaluate the legal environment of the recipient jurisdiction. Data Subject Rights: Legal Guarantees and Emerging Challenges Uzbekistan’s data protection framework grants individuals a set of core rights aimed at giving them control over their personal data. These include the right to access their data, request corrections of outdated or inaccurate information[23], demand deletion when processing becomes unlawful[24], and object to the provision of their data[25]. One of the most impactful rights is the ability to withdraw consent at any time. Once this happens, the operator must immediately cease the relevant processing and delete the data, unless another legal basis (such as contractual or legal obligation) justifies retention.[26] While the law formally mirrors international standards such as the GDPR, practical enforcement and user awareness remain limited. In most cases, businesses still lack automated or clear procedures for fulfilling data subject requests. Furthermore, the lack of digital tools for individuals to exercise these rights weakens their practical effect.   That said, enforcement trends, especially in regulated sectors like finance and telecom, suggest that ignoring these rights may result in reputational risks and administrative liability. Businesses operating in Uzbekistan should proactively implement internal protocols for handling access, correction, and deletion requests, even in the absence of widespread enforcement. Enforcement and Liability In Uzbekistan, enforcement of personal data regulations is overseen by the State Center for Personalization under the Cabinet of Ministers. Legal entities, as well as their responsible officers, may face administrative fines for non-compliance.[27] In more serious instances, such as unlawful collection, dissemination, or acquisition of personal data, criminal liability may also be imposed.[28] Recent developments suggest a clear trend toward stricter enforcement. As Uzbekistan continues aligning its legal framework with global data protection standards, authorities are becoming more proactive in monitoring compliance and imposing sanctions. Notably, enforcement is no longer limited to formal violations; it now includes practical implementation such as failure to ensure data localization or mishandling user consent.[29] Practical Recommendations for Ensuring Compliance in Uzbekistan To operate effectively and minimize legal and reputational risks in Uzbekistan, companies, particularly foreign entities should adopt a proactive and structured approach to personal data compliance. Key steps include: Begin with a thorough review of data flows to identify what categories of personal data are collected, processed, stored, and transferred. Clear documentation of processing purposes and legal bases is essential. Prior to commencing data processing, ensure that all relevant databases are registered with the authorized state body in accordance with national legislation. Consent mechanisms must be aligned with Uzbek legal standards. This includes language clarity, scope of use, and withdrawal procedures. Where applicable, implement technical solutions to meet data localization requirements. This may involve collaboration with certified local hosting providers or the adoption of hybrid cloud models with primary storage based in Uzbekistan. Appoint a data protection officer or designate a local compliance representative to oversee ongoing compliance and interface with regulators. Develop and maintain internal policies and procedures for data incident response, rights requests handling, and regular audits. Ensure that privacy and data protection obligations are incorporated into contracts with third-party service providers and partners, especially where data access or transfer is involved. Publish a comprehensive privacy policy reflecting actual practices. This enhances both regulatory defensibility and consumer trust, demonstrating a firm’s commitment to lawful and ethical data handling. Authors: - Jamshid Agzamkhadjaev (Managing Partner, Settle Law Firm) - Saida Junaydullaeva (Paralegal, Settle Law Firm) References: [1] National Standard of Uzbekistan OʻzMSt ISO/IEC 27002:2024 (ISO/IEC 27002:2022, IDT), Information security, cybersecurity and privacy protection — Information security controls, approved by the Uzbek Agency for Standardization, Metrology and Certification. [2] National Standard of Uzbekistan OʻzMSt ISO/IEC 27005:2024 (ISO/IEC 27005:2022, IDT), Information security, cybersecurity and privacy protection — Guidelines for information security risk management, approved by the Uzbek Agency for Standardization, Metrology and Certification. [3] Order of the Minister of Justice of the Republic of Uzbekistan “On the Approval of the Standard Procedure for Processing Personal Data”, registered on 15 November 2023, reg. No. 3478, para.4. [4] Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 dated 2 July 2019, Art. 10 (2). [5] Ibid, Art. 14 (2), 15 (3)(1). [6] Ibid, Art. 10 (2)(1). [7] Ibid, Art. 14 (2), 15 (3)(1). [8] Order of the Minister of Justice of the Republic of Uzbekistan “On the Approval of the Standard Procedure for Processing Personal Data”, registered on 15 November 2023, reg. No. 3478, para.11. [9] Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 dated 2 July 2019, Art. 21 (1). [10] Ibid, Art. 21 (2). [11] Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 71 of 8 February 2020 “On the Approval of the Regulation on the State Register of Personal Data Databases”, para.4. [12] Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 dated 2 July 2019, Art.20 (1). [13] Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 71 of 8 February 2020 “On the Approval of the Regulation on the State Register of Personal Data Databases”, para.15. [14] Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 dated 2 July 2019, Art.20 (3). [15] Ibid, Art. 271. [16] Regulation on the Requirements for Material Carriers of Biometric and Genetic Data and Technologies for Storing Such Data Outside Personal Data Databases, Annex No. 2 to the Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 570 of 5 October 2022, para.3. [17] Ibid, para.6 (2). [18] Ibid, para.4. [19] Ibid, para.7. [20] Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 dated 2 July 2019, Art. 7 (2). [21] Ibid, Art. 15 (2). [22] Ibid, Art. 15 (3). [23] Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 dated 2 July 2019, Art. 11. [24] Ibid, Art. 1. [25] Ibid, Art. 13 (1). [26] Ibid, Art. 17(2)(2). [27] Code of Administrative Liability of the Republic of Uzbekistan, entered into force on 1 April 1995, Art. 462. [28] Criminal Code of the Republic of Uzbekistan, entered into force on 1 April 1995, Art.1412. [29] Law of the Republic of Uzbekistan “On Amendments and Additions to Certain Legislative Acts of the Republic of Uzbekistan” No. ZRU-726 dated 29 October 2021

Introduction The collection of registered trademarks constitutes an integral part of brand identity. It supports the consistent promotion of products and services, helping create strong, lasting associations in the minds of consumers. Securing trademark protection is therefore essential not only to maintain legal exclusivity, but also to preserve consumer trust and protect the brand’s market reputation. As commercial activity continues to expand in actively developing markets such as Uzbekistan, building a strong protection for brand identity becomes a necessity for maintaining competitive market positioning. One of the ways of building such a protection is by structuring a comprehensive trademark portfolio. In this article, we explore the key stages and practical considerations involved in developing a trademark portfolio in Uzbekistan. Understanding the Trademark Portfolio The concept of trademark portfolio extends beyond a mere collection of trademarks. It reflects a deliberate, long-term strategy for managing the legal and commercial dimensions of brand protection. This includes identifying valuable brand assets, securing registrations across relevant classes and jurisdictions, monitoring use, and enforcing rights where necessary. Trademark registration by itself is often presumed to alone grant exclusive rights and solid protection under the law, while it only serves a basis for enforcement. A well-devised portfolio strategy allows businesses to maximize the utility of their trademarks, avoid costly disputes, and create avenues for licensing, franchising, and market expansion. Trademark Registration in Uzbekistan Uzbekistan’s trademark environment has evolved in recent years, signifying a deliberate shift towards modernization and accessibility in intellectual property services. Since 2019, all applications have been filed and published online through a Unified Portal of Interactive Public Services.[1] Notably, the trademark registration process has been further formalized through the Administrative Regulation on the Provision of State Services for the Registration of Trademarks and Service Marks.[2] These changes have improved procedural transparency and legal certainty for applicants, especially foreign businesses. Risk Identification Before filing a trademark application in Uzbekistan, it is highly advisable to conduct a comprehensive trademark search to assess potential conflicts with existing registrations or applications. As a best practice, a full and comprehensive trademark clearance search should be conducted prior to filing by a professional trademark attorney. The search generally includes: Identification of visually, phonetically or semantically similar marks in the same classes; Review of unregistered but well-known marks (where relevant); Analysis of whether potential objections may arise during examination. We recommend that businesses adopt a forward-looking filing strategy that takes into account their anticipated growth and market expansion. In this context, conducting a preliminary clearance search becomes particularly important, as its outcome directly influences the filing approach. Having a reasonable degree of confidence that a trademark is likely to proceed to registration enables more strategic and timely commercial decision-making. Trademark Types Under Uzbek legislation, trademark protection is available for two primary types of marks: individual and collective.[3] An individual trademark is registered in the name of a single rightsholder, either a legal entity or individual. A collective trademark, by contrast, is intended for use by multiple entities belonging to an association or other form of union. Uzbek law does not place strict restrictions on the form a trademark may take.[4] In accordance with legislative provisions, protection may be granted to a broad range of designations. These include word marks, figurative marks, combined marks, and three-dimensional marks, as well as non-traditional trademarks such as sound marks, motion marks, light marks, holograms, and even olfactory (scent) marks.[5] Selecting the appropriate type of trademark is a critical step in defining the scope and strength of protection. When configuring trademark protection Applicants should weigh the scope of protection offered by each trademark form against practical considerations, including business needs, enforcement priorities, anticipated expansion and budget constraints. National vs International Filing Routes Trademark registration in Uzbekistan may be secured through two primary routes: the national filing system and the international registration under the Madrid System. National trademark registration The registration of trademarks at the national level is carried out by the State Institution "Intellectual Property Center" under the Ministry of Justice of the Republic of Uzbekistan.[6] The application undergoes formal and substantive examination.[7] On average, the examination of a designation takes between 7 to 9 months. Once examined and approved, the trademark is registered for a period of ten years with a possibility of renewal in ten-year increments.[8] International trademark registration Being a party to the Protocol Relating to the Madrid Agreement Concerning the International Registration of Marks, Uzbekistan offers a route of international registration. Applicants with a basic application or registration in any member state may file a single international application via the World Intellectual Property Organization (WIPO), designating Uzbekistan among other jurisdictions.[9] It is important to note that an applicant may benefit from the priority date of the original filing when submitting an international trademark application, provided that the international application is filed within six months of the initial national or regional filing.[10] This centralized system is especially favorable for businesses seeking protection in multiple countries. It may be cost-effective not only in terms of pricing but also by avoiding the additional expenses of engaging a patent attorney in each jurisdiction. Strategic Class Selection Filing strategies must account for existing brand fields and planned developments. For example, product extensions, rebranding, and market segmentation often require advance filings to secure new variants or sub-brands under the same umbrella. Therefore, in practice, businesses often choose to file trademark applications in classes they plan to use in the near future. In some cases, they may even register entire trademarks in advance of actual use to secure protection ahead of market entry. While this forward-looking approach can secure protection in advance, it also carries a risk: under Uzbek law, trademarks become vulnerable to cancellation for non-use if they are not used continuously for three years following registration.[11] Accordingly, anticipatory filings should be approached strategically. Businesses must balance the benefits of early protection against the need to maintain active use or develop clear plans for use within the applicable timeframe. Inappropriate or overly broad filings may lead not only to cancellation but also to unnecessary registration costs and administrative burdens. First-to-file or first-to-use? Generally, Uzbek legislation does not expressly codify either the first-to-file or first-to-use principle. However, it is our expert opinion based on the wording of relevant legislative provisions [12], the prevailing interpretation is that Uzbekistan operates under a first-to-file system. This means that priority is granted to the party who first files the application, regardless of prior commercial use. Nonetheless, enforcement bodies such as the Antimonopoly Committee, have, in certain instances, taken prior use into consideration, particularly, in disputes involving unfair competition or deceptive practices. Legal Implications of a Weak Trademark Portfolio While structuring a trademark portfolio is not a mandatory legal requirement, failing to adopt a strategic approach may expose a business to significant legal and commercial vulnerabilities. Increased risk of infringement Failure to secure key trademarks on time increases the likelihood that competitors or unrelated third parties may register identical or confusingly similar marks. Such conflicts create serious barriers to market entry, dilute brand identity, and trigger protracted and costly legal disputes. Loss of enforcement opportunities A poorly maintained trademark portfolio may restrict the practical ability to exploit the commercial value of registered rights. Trademarks that are not adequately protected are significantly more exposed to infringement, counterfeiting, and unlawful appropriation by third parties. Only the owner of a validly registered trademark is entitled to initiate legal action against infringing parties under Uzbek law.[13] Unregistered marks, or those with expired or revoked registrations, do not afford the same enforceable rights and may severely limit a brand owner's ability to protect their assets through administrative or judicial channels. Loss of exclusive rights In Uzbekistan, trademark registrations become vulnerable to cancellation if the mark has not been used continuously for a period of three years.[14] An inactive trademark portfolio may lead to revocation actions initiated by competitors or interested parties. Thus, without regular monitoring and commercial use of registered marks, businesses risk losing formal protection. Monitoring and Enforcement Mechanisms Trademark protection does not end at registration. To effectively protect your trademark against unfair competitors, we would advise conducting continuous monitoring and enforcement to maintain the integrity and exclusivity of the brand. Watch Services and Opposition By monitoring the official Uzbek trademark bulletin, rights holders can identify newly published applications that are identical or confusingly similar to their registered marks. If such an application is detected, a formal opposition may be filed during the publication stage. Timely opposition prevents the registration of infringing marks before they enter the market, saving time, cost, and legal complexity associated with post-registration disputes. Customs Recordal To reinforce protection against counterfeit imports, trademark owners may record their registered marks in the Customs Register maintained by the State Customs Committee of Uzbekistan. Under Uzbek law, customs authorities possess “ex officio” powers, allowing them to independently suspend the release of goods that exhibit signs of trademark or other IP infringement. When a trademark is recorded and a suspected infringement arises, the customs authority is obliged to notify the rights holder within one business day, enabling the proprietor to take prompt legal action if necessary.[15] In the absence of any response, the authorities may act accordingly even without a prior request from the rights holder.[16] Customs enforcement is particularly effective in industries that are highly susceptible to counterfeiting, such as apparel, electronics, pharmaceuticals, cosmetics, and consumer goods. Renewals and Portfolio Maintenance Trademark registrations in Uzbekistan remain valid for 10 years and may be renewed for subsequent 10-year periods. To maintain effective protection, businesses are suggested to implement a structured renewal and maintenance process, which includes: Monitoring upcoming expiration dates and ensuring timely extensions; Keeping records of actual use to comply with the three-year non-use rule to avoid vulnerability to cancellation; Updating key information, such as ownership details, registered addresses, and licensing arrangements, across the portfolio; Periodically reviewing the trademark portfolio to identify obsolete registrations or potential gaps that may require strategic action. Conclusion For international businesses in Uzbekistan, a thoughtfully constructed trademark portfolio operates not only as a shield against legal risk, but also strengthens market position, supports brand development, and enhances commercial opportunities. By integrating early-stage filing strategies with vigilant enforcement and long-term maintenance, companies can transform their trademark portfolios into resilient legal assets that support reputation, generate value, and underpin sustained market presence.   [1] Law of the Republic of Uzbekistan “On Trademarks, Service Marks and Appellations of Origin” No. 267-II of 30 August 2001, Art. 8 (1). [2] Administrative Regulation on the Provision of State Services for the Registration of Trademarks and Service Marks, approved by Resolution No. 480 of the Cabinet of Ministers of the Republic of Uzbekistan, 19 September 2023. [3] Law of the Republic of Uzbekistan “On Trademarks, Service Marks and Appellations of Origin” No. 267-II of 30 August 2001, Art. 3 (3) (4). [4] Ibid, Art. 3 (5). [5] Administrative Regulation on the Provision of State Services for the Registration of Trademarks and Service Marks, approved by Resolution No. 480 of the Cabinet of Ministers of the Republic of Uzbekistan, 19 September 2023, para. 6. [6] Law of the Republic of Uzbekistan “On Trademarks, Service Marks and Appellations of Origin” No. 267-II of 30 August 2001, Art. 7 (3). [7] Ibid, Art. 13 (1). [8] Ibid, Art. 21, 22 (1). [9] Protocol relating to the Madrid Agreement concerning the international registration of marks, adopted at Madrid on 27 June 1989 (as amended on November 12, 2007), Art. 2. [10] Ibid, Art. 4 (2). [11] Law of the Republic of Uzbekistan “On Trademarks, Service Marks and Appellations of Origin” No. 267-II of 30 August 2001, Art. 25 (1)(4). [12] Civil Code of the Republic of Uzbekistan, Part Two, adopted on 1 March 1997, Art. 1032 (1), 1002 (1). [13] Law of the Republic of Uzbekistan “On Trademarks, Service Marks and Appellations of Origin” No. 267-II of 30 August 2001, Art. 26. [14] Ibid, Art. 25 (1)(4). [15] Law of the Republic of Uzbekistan “On Amendments and Additions to the Customs Code of the Republic of Uzbekistan Aimed at Further Improvement of Customs Procedures” No. ЗРУ-913 of 27 February 2024, Art. 3821 (1). [16] Ibid, Art. 3822 (1).   Authors: - Jamshid Agzamkhadjaev (Managing Partner, Settle Law Firm) - Saida Junaydullaeva (Paralegal, Settle Law Firm)

Overview Uzbekistan’s legal environment is undergoing a phase of active modernization. Over the past years, the country has introduced wide-ranging reforms aimed at liberalizing the economy, improving transparency, and aligning local rules with international standards. At the same time, the legal framework remains complex, with sector-specific regulations and compliance obligations that demand careful navigation. For foreign investors, understanding these dynamics is crucial to avoid risks and secure long-term success. This article outlines the main aspects of market entry, including business establishment options, intellectual property protection, personal data rules, sectoral regimes, and dispute resolution mechanisms in Uzbekistan. Business set-up Choosing the right legal form of business presence in Uzbekistan depends on the project’s objectives, the scale of investment, and the level of involvement desired in day-to-day management. The most widely used and flexible structure is the limited liability company (LLC). Other available options include a private enterprise (PE), a joint-stock company (JSC), and an individual entrepreneur (IE). In addition, foreign investors may establish a permanent establishment or a representative office, depending on the intended scope of activity. In this section, we briefly outline the main forms of business organization available in Uzbekistan and their key features. Limited Liability Company (LLC) A limited liability company (LLC) is the most common and flexible form of business entity in Uzbekistan. It can be established by one or several founders, with charter capital divided into shares as determined by the company’s charter. The participants are not personally liable for the company’s obligations and bear risks only within the scope of their contributions.[1] LLCs are open for establishment by both local and foreign individuals or legal entities. When foreign investment is involved, companies may obtain additional benefits and incentives, making this structure particularly attractive for international businesses. These advantages may include tax preferences, customs reliefs[2], and simplified administrative procedures, especially for large-scale or strategically important projects[3]. Foreign investors generally enjoy the same rights as local entrepreneurs, with certain supportive measures introduced to encourage international participation, particularly in innovative and technology-related sectors. Thanks to these features, the LLC remains the preferred vehicle for market entry in Uzbekistan. Joint-Stock Company (JSC) Joint-Stock Companies (JSCs) are better suited for large-scale projects and raising capital through the issuance of shares. The shareholder liability in this case is limited to the value of one’s shareholdings.[4] However, they are subject to more complex and rigorous corporate governance requirements, including mandatory disclosure and reporting obligations. While this form offers access to broader financing opportunities, it also entails higher compliance costs compared to LLC structures. Representative offices Foreign companies may establish representative offices in Uzbekistan. However, such offices do not have the status of a legal entity and cannot engage in commercial, entrepreneurial, or other economic activity.[5] Their primary function is therefore limited to representing and protecting the interests of the parent company in Uzbekistan. Permanent establishments A permanent establishment (PE) arises when a foreign company carries out business activity in Uzbekistan without creating a separate legal entity. While a PE is not considered an independent company, it allows foreign businesses to conduct commercial operations, hire staff, open bank accounts, and maintain a local presence. This model can be a practical alternative to setting up a subsidiary for companies seeking a long-term footprint. PE status may result from having a management office, branch, construction site, service provision beyond certain time limits, or activities in resource extraction.[6] Registration with the State Tax Committee is mandatory, after which the PE is treated as a local taxpayer with the same obligations as domestic entities.[7] Intellectual Property (IP) Protecting intellectual property (IP) is a cornerstone of safeguarding brand identity and securing the long-term commercial value of a business. In Uzbekistan, the local market continues to face challenges in the form of counterfeit goods and the activities of “trademark squatters” – applicants seeking to register well-known brands without authorization to exploit their reputation. In the following sections, we will briefly outline the core elements of IP protection in Uzbekistan, including the first-to-file principle, issues surrounding parallel imports, and available remedies for infringement of intellectual property rights. First-to-File System Uzbek legislation does not expressly codify either the first-to-file or first-to-use principle. However, prevailing interpretation suggests that Uzbekistan effectively operates under a first-to-file system. This means that trademark priority is granted to the applicant who first files an application, regardless of prior commercial use. Businesses are therefore strongly advised to make timely filings to secure protection. At the same time, if the rights holder acts in bad faith against a party that can demonstrate earlier use of a brand, such conduct may be treated as an act of unfair competition. In these cases, the law provides a basis for challenging registrations and protecting the interests of the genuine user. Parallel import In 2017, Uzbekistan formally recognized the principle of international exhaustion of trademark rights, thereby legalizing parallel imports.[8] However, the legislation does not explicitly define whether the exhaustion of trademark rights in Uzbekistan is national or international. As a result, the rule remains open to interpretation. In practice, courts have occasionally accepted arguments in favor of international exhaustion, while competition authorities have tended to apply a national exhaustion approach. While this approach has facilitated market access, reduced barriers to trade, and lowered consumer prices, it has also limited the ability of trademark owners to fully control distribution channels within Uzbekistan. Liability for breach of rights Uzbek law imposes civil, administrative liability for intellectual property infringements. Rights holders may seek remedies such as injunctions, damages, and seizure of counterfeit goods. Administrative sanctions may also include fines and confiscation of unlawfully marked products.[9] In addition, the legislation provides for compensation as a separate form of liability, particularly in cases involving trademark and copyright infringements.[10] This mechanism enables rights holders to recover monetary amounts without the need to prove actual damages, offering a more efficient route to enforcement. Recent legislative reforms have further strengthened the framework, introducing criminal liability in severe cases of repeated infringement across a wide range of IP rights. These amendments, entering into force in late 2025, mark a clear step towards alignment with international standards.[11] Personal Data Uzbekistan is undergoing a profound transformation in the sphere of personal data protection, driven by the rapid digitalization of e-commerce, finance, communications, and public services. In recent years, the government has introduced a series of reforms aimed at strengthening the enforcement of data protection rules, tightening requirements for financial institutions, and embedding cybersecurity standards into everyday business practices. Businesses entering the Uzbek market must be prepared to navigate a legal environment that imposes robust personal data compliance obligations, including mandatory database registration and localization of personal data. Key requirements Uzbek law establishes several legal grounds for the processing of personal data, including contractual necessity, statutory obligations, legitimate interest, and use of data for research purposes. Nevertheless, consent remains the central basis for most processing activities, including transfer, dissemination, or cross-border transmission of personal data. Consent must be informed, explicit, and tied to a specific purpose, with separate approval required where processing goes beyond the originally declared scope.[12] In addition, all personal data databases are subject to mandatory registration in the State Register of Personal Data Databases, a requirement that forms an integral part of Uzbekistan’s compliance framework.[13] Data localization requirements One of the central features of Uzbekistan’s personal data regime is the obligation to store the data of Uzbek citizens on servers physically located within the country.[14] This rule applies equally to local and foreign companies operating in the market and has become a significant compliance challenge, particularly for digital service providers and businesses relying on cross-border data flows. Non-compliance can expose companies to regulatory risks and hinder their ability to operate effectively. To meet these requirements, businesses are encouraged to explore practical solutions that balance legal certainty with operational efficiency. Common approaches include working with certified local data centers, implementing hybrid cloud models that ensure primary hosting in Uzbekistan, and planning infrastructure in advance to avoid costly adjustments in the future. Licenses and Permits In Uzbekistan, business activities are regulated through three main formats of authorization: licenses, permits, and the notification procedure. Depending on the sector, companies may be required to obtain one of these forms of approval before starting operations. These mechanisms apply primarily to strategically important or sensitive industries, such as banking, healthcare, education, construction, and natural resource extraction. At the same time, all business activities that do not fall under these categories may be carried out freely and without any special authorization. In such cases, companies are entitled to commence operations immediately upon state registration, which significantly simplifies market entry and reduces administrative barriers for most entrepreneurs.   IT Park In Uzbekistan, a special technology hub – IT Park – has been established in Tashkent, offering its residents substantial tax and administrative incentives. The initiative was created by the government to attract investment, boost the export of IT services, and foster a favorable ecosystem for technological development. Residents benefit from wide-ranging advantages, including exemptions from key taxes and mandatory contributions[15], reduced personal income tax rates, the ability to hire foreign specialists without work permits, and the option to operate through a virtual office. Companies can also pay salaries and dividends in foreign currency and export services with minimal barriers. These measures position IT Park as one of the most attractive entry points for international companies seeking to enter Uzbekistan’s technology sector. PPP (Public–Private Partnership) In Uzbekistan, the PPP framework is actively functioning and has become an important tool for attracting private investment into large-scale projects. It is regulated by the Law “On Public–Private Partnership”, along with concessions, production sharing agreements (PSAs), and rules on natural monopolies. Concessions grant private companies long-term rights to use and manage state-owned assets such as land, infrastructure, or natural resources, while ownership remains with the state.[16] PSAs are widely applied in the oil, gas, and mining sectors, giving investors the ability to recover costs and share production in return for assuming development risks.[17] To further stimulate investment, Uzbekistan offers a system of legal guarantees and sector-specific incentives, ensuring stability and creating a secure platform for long-term cooperation between the state and private investors.[18] Advertisement & Unfair competition Advertising legislation and competition rules in Uzbekistan are of significant importance, as they affect almost every area of business. Since trade and commerce are closely tied to advertising, companies must pay careful attention to compliance in this field. The specific rules governing advertising are set out in a separate Law “On Advertisement”. A key requirement is that advertisements must be distributed in the state language – Uzbek.[19] An exception applies to registered trademarks, which may be used in the form in which they are officially registered. In addition, there are product-specific restrictions, for example in relation to pharmaceuticals, alcohol, tobacco, and financial services. Competition is governed by a separate law, recently adopted in a completely new edition. This law and its associated regulations cover multiple aspects of business activity, including restrictions on mergers and acquisitions, regulation of monopolies, and rules on dominant market positions. These provisions are especially relevant for investors and large companies, as they set the boundaries for fair competition and ensure a level playing field in Uzbekistan’s market. E-commerce E-commerce in Uzbekistan has expanded rapidly in recent years, driven by state support for the IT sector, the growth of fintech solutions, and the increasing role of telecom services and digital public platforms. With the expansion of e-commerce platforms, fintech solutions, telecom services, and digital public services, the volume and sensitivity of collected personal data have surged, intensifying the need for robust safeguards. Notably, in December 2024, the Cabinet of Ministers adopted a resolution further refining the regulatory landscape for e-commerce. Under this act, only resident legal entities are permitted to operate e-commerce platforms in Uzbekistan.[20] The requirement for local incorporation applies not only to online marketplaces, but also to order aggregators and digital streaming services, marking a significant step in strengthening state oversight over the sector. Dispute Resolution Uzbek legislation allows contracting parties to choose both the applicable law and the forum for resolving disputes. This flexibility provides foreign investors with greater certainty when structuring agreements and helps ensure enforceability of contractual rights within the local legal framework. In addition to state courts, parties may resort to arbitration. Both domestic arbitration institutions and international arbitration mechanisms are available, provided that such clauses are expressly included in contracts. The Tashkent International Arbitration Centre (TIAC) has become a recognized forum for cross-border disputes. Mediation and other pre-trial procedures are also actively promoted in Uzbekistan as cost-effective alternatives to litigation. These mechanisms aim to encourage amicable settlements, reduce judicial backlog, and provide businesses with faster, less adversarial ways of resolving conflicts. Conclusion To sum up, Uzbekistan offers substantial opportunities for international investors, combining a growing market with a regulatory environment that is gradually becoming more transparent and investor-friendly. The government continues to introduce reforms aimed at improving the business climate, simplifying procedures, and encouraging foreign participation in key sectors of the economy.   At the same time, success in this market requires more than enthusiasm or capital investment. A carefully structured legal and strategic approach is essential to ensure compliance with local requirements while also taking full advantage of the incentives available. Businesses that pay attention to the nuances of regulation are far better positioned to avoid risks and secure sustainable growth. It is also important to note that not every aspect of the law will be equally relevant for every investor. However, sector-specific rules, whether related to licensing, competition, intellectual property, or data protection, can be decisive in shaping the success of a project. For this reason, companies should approach Uzbekistan’s market with both flexibility and legal awareness, tailoring their strategy to the particular industry in which they operate.   References [1] Law of the Republic of Uzbekistan “On Limited Liability Companies” № 310-II dated 06 December 2001, Art. 3 (1). [2] Law of the Republic of Uzbekistan “On Guarantees and Measures for the Protection of Rights of Foreign Investors” № 611-I dated 30 April 1998. [3] Presidential Decree No. UP-4434 of 10 April 2012 “On Additional Measures to Stimulate the Attraction of Foreign Direct Investment”. [4] Law of the Republic of Uzbekistan “On Joint-Stock Companies and Protection of Shareholders’ Rights”, Art. 4 (2). [5] Resolution of the Cabinet of Ministers of the Republic of Uzbekistan “On Approval of the Regulation on Accreditation of Representative Offices of Foreign Commercial Organizations in the Territory of the Republic of Uzbekistan and the Procedure for Their Activities” dated February 7, 2024, No. 76, para. 7. [6] Tax Code of the Republic of Uzbekistan, Art. 36 (2). [7] Tax Code of the Republic of Uzbekistan, Art. 36 (14). [8] Civil Code of the Republic of Uzbekistan, Part Two, adopted on 1 March 1997, Art. 11071. [9] Code of the Republic of Uzbekistan on Administrative Liability adopted by the Law of the Republic of Uzbekistan dated September 22, 1994, No. 2015-XII, Art. 177, 1771, 1772. [10] Law of the Republic of Uzbekistan “On Amendments to Certain Legislative Acts of the Republic of Uzbekistan in Connection with the Further Improvement of the System of Legal Protection of Intellectual Property Objects” No. ZRU-959 dated 10 September 2024. [11] Law of the Republic of Uzbekistan “On Amendments and Additions to Certain Legislative Acts of the Republic of Uzbekistan” dated August 8, 2025, No. ZRU-1080. [12] Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 dated 2 July 2019, Art. 14 (2), 15 (3)(1). [13] Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 71 of 8 February 2020 “On the Approval of the Regulation on the State Register of Personal Data Databases”, para.4. [14] Law of the Republic of Uzbekistan “On Personal Data” No. ZRU-547 dated 2 July 2019, Art. 271. [15] Regulation on the Procedure for Organizing the Activities of the Technological Park of Software Products and Information Technologies, Annex to the Resolution of the Cabinet of Ministers of the Republic of Uzbekistan, 15 July 2019, No. 589, para. 25 (а) (b). [16] Law of the Republic of Uzbekistan “On Concessions”, 30 August 1995, No. 110-I, Art. 1, 6 (1). [17] Law of the Republic of Uzbekistan “On Production Sharing Agreements”, 7 December 2001, No. 312-II, Art. 3 (1). [18] Law of the Republic of Uzbekistan “On Guarantees and Measures to Protect the Rights of Foreign Investors” No. 611-I of 30 April 1998. [19] Law of the Republic of Uzbekistan “On Advertising”, 7 June 2022, No. ZRU-776, Art. 6 (1). [20] Resolution of the Cabinet of Ministers of the Republic of Uzbekistan “On Measures for the Further Development of E-Commerce in the Republic of Uzbekistan”, 26 December 2024, No. 885, para. 2.

    Legislative Updates in E-Commerce Uzbekistan – January 2025   New Initiatives for the Advancement of E-Commerce in Uzbekistan On December 26, 2024, the Cabinet of Ministers of the Republic of Uzbekistan (“Uzbekistan”) adopted Resolution No. 885 "On Measures for the Further Development with the sphere E-Commerce in the Republic of Uzbekistan" (the "Regulation No. 885"). Below is an overview of the key regulatory innovations in e-commerce introduced by the Regulation No. 885. Conditions for Recognizing E-Commerce Operators in Uzbekistan have been established According to the Regulation No. 885, only legal entities that are residents of Uzbekistan can qualify as e-commerce operators (including electronic trading platforms, order aggregators, and digital streaming service providers). Meanwhile, legal entities and/or individual entrepreneurs who do not assume obligations under electronic contracts or transactions and are limited to providing information about goods (works, services) and digital products through their informational resources or platforms are not considered e-commerce operators. New Conditions and Requirements for E-Commerce Operators will be Introduced starting from July 1, 2025 According to the Regulation No. 885, starting from July 1, 2025, e-commerce operators must adhere to a notification-based regulatory framework, which includes the following conditions and requirements: Register as a legal entity within Uzbekistan, Comply with the applicable legislation of Uzbekistan in the fields of e-commerce, personal data protection, copyright, consumer rights, advertising, and other regulatory legal acts, Provide information related to their activities in the field of e-commerce to the authorized body upon request and free of charge, Comply with the retail trade regulations in force within Uzbekistan, Ensure the availability of an information system that guarantees the required level of functionality for providing services to e-commerce participants, Ensure the accuracy of the information contained in the notification of the commencement of activities, Ensure mandatory registration of information regarding new employment contracts, amendments to existing contracts, terminations, and details of active employment contracts in the interdepartmental software and hardware complex “Unified National Labor System,” if required for performing relevant employee-related actions. Comply with other requirements and conditions, considering the specific nature of the activities carried out under the notification procedure. In addition, according to the Regulation No. 885, starting from July 1, 2025, legal entities, individual entrepreneurs, and self-employed individuals engaged in e-commerce will be subject to the following requirements: Legal entities, individual entrepreneurs, and self-employed individuals engaged in the sale of goods, provision of services, or passenger transportation through electronic platforms are now required to use separate bank accounts for all financial transactions, The income generated by self-employed individuals in the field of e-commerce must be credited to a specially designated bank account. A bank card linked to this account shall be used to track incoming funds. Funds credited to this account will be included in the calculation of revenue for goods and services sold. Based on this data, self-employed individuals will be recognized as turnover taxpayers. Special Conditions for Legal Entities, Entrepreneurs, and Self-Employed Individuals As an exception, the Regulation No. 885 permits self-employed individuals engaged in the delivery of goods (works, services) or passenger transportation by light motor vehicles to: Pre-deposit funds into specially designated bank accounts of self-employed individuals, with subsequent debiting in favor of suppliers of goods (works, services) or e-commerce entities, Accept cash payments for delivered goods (works, services). In this case, it is permissible for self-employed individuals to retain cash in an amount equivalent to the amount transferred to the supplier of goods (services) from the separate bank account, without mandatory cash collection. When exporting goods via electronic trading platforms, legal entities, individual entrepreneurs, and self-employed individuals are allowed to send goods sold online to foreign buyers through courier and postal services, including without registering contracts in the Unified Electronic Information System for Foreign Trade Operations. Note: Additionally, electronic trading platforms are required to ensure the integration of their systems with the information resources of the State Tax Committee of Uzbekistan and the Customs Committee under the Ministry of Economy and Finance of Uzbekistan. Instructions on Improving E-Commerce Regulation and Implementing Control Mechanisms In accordance with the Regulation No. 885, the Statistics Agency of Uzbekistan, in collaboration with the National Agency for Perspective Projects (the “NAPP”) and with the support of foreign experts, has been tasked with introducing reporting forms for e-commerce entities by July 1, 2025, based on international best practices. In addition, within the context of fulfilling the requirements of the Regulation No. 885, the NAPP is required to undertake the following actions within three months: Develop and approve the procedure for conducting courier activities in the field of e-commerce, In collaboration with the Committee for Competition Development and Consumer Rights Protection develop mechanisms for online dispute resolution within the realm of electronic commerce in Uzbekistan and present the corresponding proposals to the Cabinet of Ministers. In collaboration with other authorized ministries and agencies, develop and submit draft regulatory legal acts to the Cabinet of Ministers. These proposals should introduce new concepts and terms into e-commerce legislation and provide for the implementation of the notification procedure for e-commerce operators in accordance with the conditions and requirements mentioned above. Additionally, the establishment of a register of e-commerce entities is planned.