Uzbekistan has introduced a significantly updated regulatory regime for digital services, creating binding new obligations for technology companies operating in or into the country. The reforms take effect in stages through 2025 and 2026. International businesses that delay assessment risk administrative penalties, forced suspension of digital services, and exclusion from the Uzbek market.
Uzbekistan's updated digital services legislation imposes registration, localisation, and algorithmic accountability requirements on technology companies providing digital services to Uzbek users. Companies meeting defined user or revenue thresholds must complete initial compliance steps within 90 days of the relevant provisions entering into force. Failure to act before the applicable deadline exposes operators to suspension orders and financial penalties under Uzbek information technology legislation.
This alert explains what changed, which businesses are affected, and the five immediate actions international companies should take now.
What changed and when it takes effect
Uzbekistan's information technology legislation has been amended to extend regulatory obligations well beyond domestic operators. The revised rules introduce a tiered approach to digital services regulation. Obligations attach based on user volume, revenue generated from Uzbek users, and the nature of the digital service provided.
Key changes introduced by the updated regime include the following:
- Mandatory registration of foreign digital service providers with the Axborot texnologiyalari va kommunikatsiyalarini rivojlantirish vazirligi (Ministry of Information Technology and Communications Development of Uzbekistan).
- Data localisation requirements compelling companies to store personal data of Uzbek users on servers physically located within Uzbekistan.
- Technology licensing obligations for operators deploying automated decision-making tools or algorithmic content recommendation systems directed at Uzbek users.
- Software liability disclosures requiring operators to publish clear terms governing the behaviour and limitations of software products available to Uzbek consumers.
- Local representative designation for companies exceeding the relevant user or revenue threshold, mirroring approaches adopted in comparable CIS jurisdictions.
The registration and local representative requirements entered into force on 1 January 2026. Data localisation obligations apply from 1 July 2026 for large operators and from 1 January 2027 for mid-sized operators. Technology licensing rules for algorithmic systems are effective from 1 July 2026.
Practitioners in Uzbekistan note that enforcement began promptly after the January 2026 effective date. Several foreign platforms received formal notices within weeks of the deadline passing.
Who is affected and what triggers the obligations
The reforms apply to any legal entity – regardless of where it is incorporated – that provides digital services accessible to users in Uzbekistan. "Digital services" is defined broadly under Uzbek technology legislation to include online platforms, application marketplaces, streaming services, cloud computing products, and software-as-a-service offerings.
Threshold criteria that trigger the full suite of obligations include:
- More than 100,000 monthly active Uzbek users in any rolling 12-month period.
- Revenue attributable to Uzbek users or Uzbek-resident customers exceeding a defined annual threshold under Uzbek tax legislation.
- Operation of an algorithmic content recommendation or automated decision-making system that materially influences Uzbek users' access to goods, services, or information.
Smaller operators fall within a lighter-touch regime. They must still register and designate a local contact point, but face reduced data localisation timelines and simplified software liability disclosure requirements. Companies providing exclusively business-to-business services to Uzbek corporate clients also face a modified set of obligations – though registration remains mandatory across all categories.
The AI Act compliance benchmarks familiar to European operators do not directly apply in Uzbekistan. However, Uzbek regulators have drawn on international approaches to algorithmic accountability when drafting the new provisions. Companies that have already mapped their AI systems for EU purposes will find that mapping substantially useful when assessing Uzbek technology licensing obligations.
For companies operating across CIS markets, comparable developments in neighbouring jurisdictions are relevant to strategy. Our analysis of digital services regulation developments in Russia sets out how the CIS regulatory trend is evolving, and where Uzbekistan's approach both aligns with and diverges from that of larger regional markets.
To receive an expert assessment of your company's exposure under Uzbekistan's digital services legislation, contact us at info@ferrazwhitmore.com.
Immediate actions for international companies
Companies providing digital services in Uzbekistan should treat the following five steps as priority actions.
1. Assess threshold exposure now. Determine whether your Uzbek monthly active user count or Uzbek-attributable revenue crosses the trigger thresholds. Do not rely solely on publicly available user estimates. Pull server-side data segmented by user location or billing address.
2. Register with the Ministry of Information Technology. Registration is required regardless of size for operators offering digital services to Uzbek users. The registration process requires submission of corporate documents, a description of the services provided, and identification of a local representative. Allow four to six weeks for processing.
3. Designate a local representative. The representative must be a natural person or legal entity physically present in Uzbekistan. This person receives regulatory notices and bears responsibility for ensuring the operator's compliance. Appointing a representative without assessing their actual capacity to perform these functions is a common mistake – and one with serious consequences if notices go unacknowledged.
4. Begin data infrastructure planning for localisation. Companies in the large operator category have until 1 July 2026 to bring personal data storage into compliance. That timeline is shorter than it appears. Procuring server capacity, executing agreements with local data centre operators, and migrating data architecture takes several months. Start scoping now.
5. Audit algorithmic systems for technology licensing requirements. Any system performing automated content ranking, personalised recommendation, or automated decision-making affecting Uzbek users must be assessed against the technology licensing criteria. Companies that have completed EU-facing algorithmic accountability reviews should extend that audit to cover Uzbek regulatory requirements. See our service overview for AI and technology law in Uzbekistan for a structured framework.
Companies whose digital services involve software products distributed to Uzbek users should also review software liability disclosure obligations. Inadequate disclosures – particularly for products with automated or AI-driven features – are among the most frequently cited deficiencies in early enforcement actions.
Intellectual property protections for software and digital content distributed in Uzbekistan require parallel attention. Registration strategies under Uzbek intellectual property legislation should be aligned with the new digital services regime. Our team's work on intellectual property matters in Uzbekistan covers this intersection in detail.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our team supports technology companies, platform operators, and institutional investors navigating digital services regulation, AI and technology law, and algorithmic accountability requirements across CIS and high-growth markets including Uzbekistan. We combine Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions for clients managing regulatory compliance across multiple legal systems. As a law firm advising on Uzbekistan matters, we work with international companies that need a lawyer with Uzbekistan experience and a clear understanding of how local rules interact with EU and international standards. For a preliminary review of your company's digital services compliance position in Uzbekistan, email info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.