From 18 November 2026, Uzbek law will expressly recognise the protection of entrepreneurial trust, the stability of the legal environment and the consistent application of rules in comparable situations. Public authorities will no longer be able to rely on formal competence alone: changes in established practice must have a public-interest justification, while the most serious restrictions on business must remain subject to judicial control. The decisive question is whether these principles will become enforceable safeguards or remain statements of intent.
A law worth studying before it enters into force
On 17 August 2026, Uzbekistan adopted Law No. ZRU-1168 on strengthening guarantees of freedom of entrepreneurial activity and improving support mechanisms for business entities. The Law enters into force on 18 November 2026.
This is not a narrow package of incentives or a technical amendment to one administrative procedure. It recasts the legal relationship between the state and business by introducing principles of legitimate reliance, legal certainty, equality, protection of private property and proportionality of state intervention.
The legislation also revises the rules on inspections, financial penalties, suspension of business activity, regulatory reporting and entrepreneurial participation in rulemaking. Related changes are made to the Economic Procedural Code and privatisation law.
Law of the Republic of Uzbekistan No. ZRU-1168Although the Law is not yet in force, the period before 18 November is not merely a waiting period. Public authorities must align their procedures with the new model, while companies need to identify the documents and circumstances capable of proving their good faith and legitimate expectations.
The state must account for the trust it creates
One of the Law’s central innovations is the principle of protection of trust. Reliance by a good-faith business on an act adopted by a public authority or official is protected by law. Authorities must respect legitimate expectations arising from established administrative practice.
A departure from that practice cannot be arbitrary. It must be justified by the public interest, apply generally rather than selectively, and create a stable new approach.
A permit or approval, an official written clarification, a consistent administrative practice, confirmed compliance with regulatory requirements, or an investment made on the basis of state assurances may all become relevant evidence.
The principle does not mean that an unlawful administrative act can never be corrected. Nor does it protect a person who supplied false information, concealed material facts or knowingly relied on an unlawful advantage. Good faith is the dividing line.
In a dispute, a business will need to show more than subjective confidence. It should be able to identify the official source of its reliance and the legal or economic decisions taken on that basis.
Predictability becomes a legal value in its own right
The Law establishes stability and certainty in business legislation as governing principles. The legal environment must be coherent and predictable, while rules must be applied equally, consistently and fairly in analogous situations.
When new legislation makes business activity more difficult, imposes new duties or increases liability, unjustifiably frequent amendments should be avoided. The premise is simple: businesses must be able to plan in a legal environment that does not change without sufficient reason.
These provisions develop existing constitutional guarantees. Article 65 of the Constitution protects freedom of economic and entrepreneurial activity, equality of property forms and private property. Article 67 requires the state to ensure a favourable investment and business climate.
Constitution of the Republic of UzbekistanPredictability is not an abstract concern for investors. It affects the cost of finance, investment payback periods, long-term contracts and decisions to create jobs. Where mandatory requirements change repeatedly or identical rules are enforced differently, administrative uncertainty is ultimately priced into every product, service and investment project.
New obligations should not be imposed without consultation
The Law strengthens business participation in the preparation of legislation. Drafts creating new duties, prohibitions, restrictions or liability for businesses must be discussed with entrepreneurs and their associations, undergo regulatory impact assessment, and be published on the public consultation portal.
Such drafts must also be considered by the Public Council for Entrepreneurship Support under the President before the Ministry of Justice conducts its legal review. In principle, this moves part of business protection upstream—before a restrictive rule is adopted.
The success of consultation should be measured not by the number of published drafts, but by whether stakeholder evidence can alter the final rule. A consultation without a reasoned response risks becoming procedural theatre rather than genuine participation.
An inspection should be the last step, not the first
The new framework also reshapes state oversight. An inspection may be initiated on the basis of the electronic Risk Analysis system or information about specific facts indicating a possible violation. Risk is classified as low, medium or high.
As a general rule, preventive measures aimed at avoiding or remedying violations must precede an inspection based on risk analysis or information from another public authority. One stated exception concerns tax inspections involving concealment or understatement of the taxable base.
Only authorised bodies may conduct inspections, and only within their legally defined areas of control. Oversight outside that competence is expressly treated as unlawful. Inspecting officials must be certified and hold a special inspection authorisation.
The underlying logic is preventive rather than punitive: where a violation can be corrected promptly without endangering a public interest, the state should first provide an opportunity to remedy it.
Correcting a violation may prevent a financial penalty
If a business complies fully and on time with an inspection order and voluntarily compensates the damage caused, including payment of any applicable late-payment amount, financial sanctions will not be imposed. This rule does not extend to financial sanctions for tax offences.
Where a fine is imposed, the Law offers two routes: payment of 50 per cent within one month with release from the remainder, or payment in equal instalments over six months. The instalment plan applies automatically if at least one sixth of the fine is paid within one month after the decision is delivered.
These mechanisms encourage prompt remediation without pushing a viable company into financial distress. They should not, however, replace the right to appeal: taking advantage of a reduced payment does not necessarily mean that a business agrees with the finding of a violation.
Serious intervention requires a court
The most intrusive measures against a business remain subject to judicial procedure. These include termination of activity, suspension for more than ten working days, restrictions or bans, suspension of bank-account operations except where legislation provides otherwise, confiscatory measures, and lengthy suspension or revocation of a licence.
A supervisory authority may itself suspend activity for no more than ten working days and only where factors listed in the register of serious threats to life and health—or another express statutory basis—are present. Corresponding amendments are made to Article 217 of the Economic Procedural Code.
The Law also states that legal measures must be proportionate to the violation and to the harm caused or threatened.
Proportionality may become one of the reform’s most important tools in economic justice. A court should examine not only whether a formal violation occurred, but whether the chosen measure was necessary. Could a warning, a remediation order or a temporary restriction address the risk instead of closing the business?
Privatisation should produce a secure property right
The Law reinforces the finality of privatisation. Initiatives by public, supervisory or law-enforcement bodies to revisit, annul or invalidate privatisation results—including the valuation of the relevant property—are characterised as violations of the inviolability of private property, and such cases are not to be accepted for consideration.
This safeguard matters for investment. A buyer that has performed the contract and paid for an asset needs confidence that the transaction will not be reopened years later simply because the administrative view has changed.
At the same time, stability should not become a shield for proven fraud or corruption. Future practice will need to draw a careful line between an impermissible reconsideration of a lawfully completed privatisation and proceedings concerning property obtained through criminal conduct.
How businesses can prepare before 18 November
Companies should use the transition period to review their dealings with public authorities and preserve evidence capable of demonstrating both reliance and good faith.
Keep permits, licences, approvals, official explanations, records of established administrative practice, proof of full disclosure, evidence of investments made in reliance on a state decision, inspection orders and proof of compliance, as well as material showing unequal treatment in comparable cases.
In a dispute, it will not be enough to say that the business “trusted the state.” The claimant will need to identify the source of that trust, demonstrate its own good faith and show the concrete consequences of the changed administrative position.
The real test begins after 18 November
Law No. ZRU-1168 creates a more modern model of relations between the state and entrepreneurs. Public power not only supervises legal compliance; it also becomes accountable for the consistency of its own conduct.
The reform’s practical meaning will nevertheless be determined by administrative and judicial practice. Courts will need to define what constitutes established practice, which expectations are legitimate, who must justify the public interest, when a policy change is sufficiently reasoned, and what remedy follows from a breach of trust or legal certainty.
If authorities begin to explain departures from previous practice and courts examine good faith, consistency and proportionality—not merely formal competence—the new principles can become real legal safeguards. If they are treated as introductory declarations, the relationship between business and the state will change only on paper.
Predictability is part of entrepreneurial freedom
Freedom of enterprise does not mean freedom from all regulation. It means that regulation must have intelligible limits. Business must comply with the law; the state, in turn, must act consistently, apply rules equally, respect the legitimate expectations it has created and explain why an established practice is changing.
The right of an entrepreneur to rely on an official decision is not a privilege. It is a condition for investment, long-term planning and respect for law itself.