Uzbekistan's insolvency legislation has undergone significant revision, with a package of amendments now in effect as of early 2025. The changes alter the procedural and substantive rights of creditors operating in insolvency proceedings against Uzbek debtors. International companies with trade receivables, loan exposures, or joint-venture interests in Uzbekistan face materially different conditions from those that prevailed before the reform.
Uzbekistan's revised insolvency legislation, effective from the first quarter of 2025, introduces amended thresholds for initiating insolvency proceedings, restructured priority rules at the creditors meeting, and tighter deadlines for submitting a proof of debt. Foreign creditors must act promptly: failure to file within the prescribed window risks exclusion from the creditor register entirely, forfeiting any recovery from the debtor's estate.
This alert summarises what changed, identifies which business categories are most affected, and sets out immediate actions international companies should take now.
What the amendments change – and when they took effect
Uzbekistan's insolvency legislation (the body of law governing bankrotlik – insolvency proceedings – in Uzbekistan) was amended through a legislative package that entered into force in the first quarter of 2025. The core changes affect four areas.
Initiation thresholds. The minimum debt amount required to petition for insolvency proceedings has been raised. Creditors holding smaller exposures must now consider whether aggregating claims or coordinating with co-creditors is necessary to meet the new threshold before filing.
Proof of debt deadlines. The window for submitting a proof of debt to the appointed administrator has been shortened. Under the amended rules, creditors must file their claims within a compressed timeline from the date of the public notice of insolvency proceedings. Missing this deadline removes the creditor from the register of creditors. There is no routine reinstatement mechanism.
Administrator and liquidator powers. The administrator and liquidator now hold expanded powers to challenge pre-insolvency transactions. The look-back period for voidable transactions has been extended. Transfers made in the two years preceding the opening of insolvency proceedings are potentially reviewable. This directly affects counterparties who received payments or security from the debtor during that window.
Restructuring plan approval. The majority threshold required to approve a restructuring plan at the creditors meeting has been adjusted. The revised rules give secured creditors a stronger blocking position, while unsecured creditors face a higher bar to reject a plan proposed by the debtor's management. International creditors holding unsecured trade claims should reassess their leverage in any consensual restructuring.
For context on how analogous reforms in a neighbouring CIS jurisdiction affect cross-border enforcement strategy, see our alert on insolvency law amendments in Russia and their creditor implications.
Who is affected – thresholds and business categories
The amendments affect any creditor – domestic or foreign – participating in insolvency proceedings before Uzbek courts. However, several categories of international business face the most acute exposure.
Trade creditors. Companies that supply goods or services to Uzbek counterparties on credit terms are directly affected by the shortened proof-of-debt window. Many foreign suppliers are unaware that insolvency proceedings have been opened until weeks after the public notice is published. By that point, the filing deadline may have passed.
Lenders and financial institutions. Banks and non-bank lenders with loan facilities extended to Uzbek borrowers must reassess their security packages. The extended look-back period for voidable transactions means that security taken close to a borrower's financial distress is at heightened risk of challenge by the liquidator.
Joint-venture partners and shareholders. Foreign investors in Uzbek companies with shareholder loan positions need to distinguish their creditor claims from equity interests. The amended priority rules affect recovery order at the creditors meeting, and shareholder loans remain subordinated to third-party debt.
Construction and infrastructure contractors. Companies with long-term project contracts in Uzbekistan are exposed to debtor insolvency mid-performance. The amendments affect termination rights and the treatment of advance payments in insolvency proceedings.
The threshold for concern is straightforward: any company that holds a receivable, a loan, or a contractual claim against an Uzbek entity should treat this alert as directly relevant.
To receive an expert assessment of your creditor position in Uzbek insolvency proceedings, contact us at info@ferrazwhitmore.com.
Immediate actions for international companies
Five steps should be taken without delay.
- Audit your Uzbek exposures. Identify all receivables, loans, and contractual claims against Uzbek counterparties. Confirm whether any debtor is subject to current or imminent insolvency proceedings.
- Monitor public insolvency notices. Uzbekistan publishes notices of opened insolvency proceedings through official state channels. Establish a monitoring process so that the proof-of-debt filing window is not missed.
- Review pre-insolvency transactions. Any payment, security, or asset transfer received from an Uzbek counterparty in the past two years should be reviewed for vulnerability to a liquidator's challenge under the extended look-back provisions.
- Assess your position at the creditors meeting. Understand whether your claims are secured or unsecured, and how the revised majority thresholds at the creditors meeting affect your ability to influence a restructuring plan or vote for liquidation.
- Engage local counsel immediately. The amended procedural rules require prompt action. A lawyer in Uzbekistan with insolvency experience can file the proof of debt, represent you at creditors meetings, and monitor administrator decisions on your behalf.
Companies with exposures across multiple CIS jurisdictions should also review their insolvency and restructuring strategy in Uzbekistan in light of these changes. Cross-border creditors may find that coordinating claims across jurisdictions requires parallel action in Uzbek courts and in the courts of the debtor's home country simultaneously.
For matters involving disputed claims or contested creditor rankings, international companies should also consider whether corporate disputes mechanisms in Uzbekistan can be deployed in parallel to protect their position before a restructuring plan is confirmed.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our team combines Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions in insolvency, restructuring, and creditor rights enforcement. We advise international trade creditors, financial institutions, and investors on insolvency proceedings, proof-of-debt filings, and restructuring plan negotiations in Uzbekistan and across CIS markets. Engaging a lawyer in Uzbekistan through our network means direct access to local procedure combined with internationally coordinated strategy. As a law firm in Uzbekistan matters, our Senior Associate for Asia-Pacific, Middle East & CIS oversees creditor representation and debtor exposure reviews for foreign clients. To discuss your situation and receive a preliminary review of your creditor position, contact us at 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.