Competition Law & Merger Filings in Uzbekistan

Competition Committee of Uzbekistan

The Committee for the Development of Competition and Protection of Consumer Rights of the Republic of Uzbekistan is the national competition authority responsible for reviewing M&A transactions that meet notification thresholds under the Law on Competition No. ZRU-850 of 3 July 2023. Preliminary consent is mandatory for notifiable transactions. A court may declare invalid a transaction made without consent that restricts competition (Law No. ZRU-850, Article 27).

Notification thresholds

Consent is required for mergers and for acquiring more than 25% of a JSC's voting shares or more than one third of an LLC, where one party's book assets or last-year revenue exceed 250,000 BCR, or the combined figure exceeds 500,000 BCR: UZS 110 billion and UZS 220 billion at the BCR of UZS 440,000 from 1 September 2026 (Article 26). Exemptions are listed in the same Article. The Law covers acts done in Uzbekistan or abroad that restrict, or may restrict, competition on a market in Uzbekistan (Article 3), so an acquirer with no Uzbek presence is not outside the rule. The share test refers to a JSC or LLC registered in Uzbekistan (Article 26). The Law does not say whether buying the foreign parent of an Uzbek company is caught, or whether the asset and revenue figures are counted worldwide or in Uzbekistan only, so a transaction between foreign parties should be tested before signing.

Filing process and timeline

The application goes to the Competition Committee before the transaction, with details of the parties, their group, activities, accounts for two years and beneficial owners. The applicant is told the decision within 30 calendar days of registration; if the transaction may restrict competition, review can be extended by up to two months (Article 27). The SPA timetable and conditions should allow for this.

Uzbek vs Kazakhstani competition law

Uzbekistan and Kazakhstan have separate and distinct competition law regimes — the Uzbek Competition Committee and Kazakhstan's Agency for Protection and Development of Competition (APDC) operate independently. Transactions with assets or turnover in both countries may require parallel filings in both jurisdictions. Unlike Kazakhstan, Uzbekistan is not a member of the EAEU — there is no Eurasian Economic Commission filing obligation for Uzbek-only targets.