PRACTICE AREA · COMPETITION & REGULATORY
Antitrust & Competition Law in Uzbekistan
Bond Stone advises on competition law in Uzbekistan — anti-competitive agreements, abuse of dominant position, merger control filings with the Committee for the Development of Competition and Protection of Consumer Rights, Uzbekistan's antimonopoly authority (the Competition Committee, formerly the Antimonopoly Committee; Law No. ZRU-850, Art. 7; Decree No. UP-108 of 6 July 2023), economic concentration notifications, unfair competition, and competition compliance programmes. Operating from Bond Stone's Tashkent office. Ranked Legal 500 EMEA and IFLR1000.
Uzbekistan's competition law framework was fundamentally reformed by the Law "On Competition" No. ZRU-850 of 3 July 2023, which entered into force on 4 October 2023. This law replaced the earlier Law "On Competition" No. ZRU-319 of 6 January 2012 and introduced a modern antimonopoly regime covering anti-competitive agreements, abuse of dominant position, economic concentrations (merger control), and unfair competition across commodity and financial markets. The Competition Committee has broad enforcement powers — including applying to court to invalidate transactions completed without required preliminary consent. For foreign investors entering Uzbekistan through M&A or joint ventures, merger control applies where one party's assets or turnover exceed 250,000 base calculated values (BCR) or the parties' combined assets or turnover exceed 500,000 BCR — UZS 110 billion and UZS 220 billion at the BCR of UZS 440,000 in force from 1 September 2026. Investors should test every merger and every acquisition of more than 25% of the voting shares of a JSC, or more than one third of an LLC, registered in Uzbekistan against these thresholds (Article 26).
Primary authority: Law of the Republic of Uzbekistan "On Competition" No. ZRU-850 dated 3 July 2023. Authority: lex.uz · Competition Committee: raqobat.gov.uz
Competition Law Services in Uzbekistan
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Merger Control — Competition Committee Filings Preliminary consent filings with the Competition Committee where economic concentration thresholds are met — threshold analysis, application preparation, documentation, and management of Competition Committee review through to consent. Bond Stone manages Competition Committee filings as part of the overall M&A or joint venture mandate. A transaction made without consent that restricts competition may be declared invalid by a court (Article 27). Full guide: Competition Law & Merger Filings in Uzbekistan → |
Anti-Competitive Agreements & Cartels Advising on prohibited horizontal agreements under the Law on Competition — price-fixing, market division, bid rigging, and output restrictions. Vertical agreement compliance — distribution arrangements, exclusive dealing, resale price maintenance, and territorial restrictions. Competition Committee investigation response and antimonopoly compliance review for companies operating in Uzbekistan's commodity and financial markets. |
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Abuse of Dominant Position Advising companies with significant market share in Uzbekistan on dominance thresholds, prohibited conduct under the Law on Competition — predatory pricing, discriminatory terms, refusal to deal, tying arrangements — and Competition Committee dominance investigation response. Market share assessment and dominance risk analysis as part of commercial strategy advisory for international investors entering Uzbekistan's commodity and financial markets. |
Economic Concentration — Pre-closing Compliance Uzbekistan requires preliminary Competition Committee consent before closing transactions that meet the economic concentration thresholds. A transaction closed without consent that restricts competition may be declared invalid by a court (Law on Competition, Article 27). Bond Stone advises on pre-closing standstill obligations, gun-jumping risk, and permissible information exchange protocols from signing through to Competition Committee consent — integrated into the transaction timetable from the outset of every M&A mandate. |
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Unfair Competition Advising on unfair competition claims and defences under the Law on Competition — misleading advertising, misappropriation of trade secrets, copying of trade dress, and abuse of comparative advertising. Competition Committee investigation response for unfair competition proceedings and coordination with intellectual property and commercial law teams where conduct spans multiple legal frameworks. |
Antimonopoly Compliance — Mandatory for Dominant Entities The Law on Competition No. ZRU-850 requires antimonopoly compliance from state executive bodies, business entities holding a dominant position in commodity or financial markets, certain large state-owned entities and associations of legal entities (Article 9). Bond Stone designs and implements compliance programmes for dominant entities — policies, training, distribution agreement review, pricing compliance, and ongoing dominance monitoring to meet the statutory compliance obligation. |
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Competition Committee Investigation Response Representing clients in Competition Committee investigations — information requests, investigation response strategy, submissions to the Competition Committee and its territorial administrations in the Republic of Karakalpakstan, the regions and Tashkent city, and appeal of Competition Committee decisions. Bond Stone advises on Competition Committee enforcement procedure and the available procedural defences at each stage of the investigation process from Bond Stone's Tashkent office. |
Competition Due Diligence — Uzbekistan M&A Competition law compliance review as part of legal due diligence on Uzbek target companies — Competition Committee register searches, prior filing history, dominance exposure in relevant product markets, distribution agreement risk, and assessment of any outstanding Competition Committee orders or investigations affecting the target. |
Antitrust Law — Detailed Guides
Key Facts — Uzbekistan Competition Law
| AREA | KEY RULE | ENFORCEMENT RISK |
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| Merger control threshold | Preliminary Competition Committee consent 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 assets or turnover exceed 250,000 BCR or the combined figure exceeds 500,000 BCR (Article 26) | A court may declare invalid a transaction made without consent that restricts competition (Article 27) |
| Competition Committee review period | Decision within 30 calendar days of registration. Extendable by up to two months if the transaction may restrict competition (Article 27). | Closing before consent — transaction invalidation |
| Dominance definition | Dominant position assessed per commodity and financial market definitions under Law No. ZRU-850 | Competition Committee investigation, fines, behavioural remedies |
| Anti-competitive agreements | Horizontal cartels and agreements restricting competition prohibited. Concerted actions also regulated. | Agreements may be declared invalid; administrative fines |
| Mandatory compliance | Antimonopoly compliance is mandatory for state bodies, entities holding a dominant position, certain large state-owned entities and associations of legal entities (Article 9) | Competition Committee enforcement for non-compliant dominant entities |
| Primary law | Law "On Competition" No. ZRU-850 of 3 July 2023, in force 4 October 2023 | Full text: lex.uz |
| Regulatory authority | Committee for the Development of Competition and Protection of Consumer Rights of the Republic of Uzbekistan — central office and territorial administrations in the Republic of Karakalpakstan, the regions and Tashkent city (Resolution No. PP-4126 of 24 January 2019, para. 2, as amended) | Broad investigative and enforcement powers |
Selected Experience — Uzbekistan Antitrust
Bond Stone's Tashkent office has managed Competition Committee merger control filings and competition advisory mandates across manufacturing, pharmaceuticals, trading, and financial services sectors — for Chinese, Indian, European, and Gulf investor groups entering Uzbekistan.
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2023 New competition law in force — Law No. ZRU-850 replacing the 2012 competition law entirely |
Regions Competition Committee territorial administrations in the Republic of Karakalpakstan, the regions and Tashkent city |
UZS 110B One-party filing threshold (250,000 BCR); UZS 220B combined (500,000 BCR) |
30 Calendar days — Competition Committee decision period, extendable by up to two months |
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AMCU merger control — pharmaceutical acquisition Antitrust · Uzbekistan · Pharmaceuticals AMCU preliminary consent filing for the acquisition of an Uzbek pharmaceutical distribution company by an Indian strategic buyer — threshold analysis under Law No. ZRU-850, application preparation, documentation package, and management of AMCU review through to consent. Part of Bond Stone's full M&A and legal due diligence mandate. Lead: Assadullah Muradov, Managing Director, Tashkent. |
Competition due diligence — manufacturing acquisition Antitrust · Uzbekistan · Manufacturing Competition law compliance review as part of legal due diligence on an Uzbek manufacturing company for a foreign acquirer — AMCU register search, prior filing history, dominance exposure in relevant product markets, distribution agreement risk assessment, and assessment of any outstanding AMCU orders. English-language report with risk matrix. Lead: Assadullah Muradov, Managing Director, Tashkent. |
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Antimonopoly compliance programme — dominant entity Antitrust · Uzbekistan · Compliance Designing an antimonopoly compliance programme for an Uzbek subsidiary of an international group holding a dominant position in its product market — mandatory compliance obligation under Law No. ZRU-850, compliance policy, staff training, distribution agreement review, pricing compliance framework, and ongoing dominance monitoring. Lead: Assadullah Muradov, Managing Director, Tashkent. |
Joint venture — economic concentration analysis Antitrust · Uzbekistan · Joint Ventures Economic concentration threshold analysis for a joint venture between a foreign strategic investor and an Uzbek partner — assessing whether the JV structure triggers AMCU preliminary consent requirements under Law No. ZRU-850, and advising on filing strategy and pre-closing standstill obligations. Part of Bond Stone's joint venture advisory practice in Uzbekistan. |
Why Bond Stone for Uzbekistan Antitrust
- Tashkent office — Bond Stone's Uzbekistan practice is led by Assadullah Muradov, Managing Director, with a qualified Uzbek lawyer team providing direct Competition Committee engagement from Tashkent
- New Law on Competition expertise — Bond Stone advises on the 2023 framework (Law No. ZRU-850) that replaced Uzbekistan's 2012 competition law entirely, including the new mandatory antimonopoly compliance obligation for dominant entities
- Integrated M&A advisory — competition clearance managed as a condition precedent within Bond Stone's overall M&A mandate, not as a separate instruction to separate counsel
- Cross-border capability — Competition Committee (Uzbekistan) and APDC (Kazakhstan) filings managed from Bond Stone's Tashkent and Almaty offices on a unified Central Asia mandate where multi-jurisdiction competition clearance is required
- Ranked Legal 500 EMEA and IFLR1000 — Tashkent office as part of Bond Stone's Central Asia platform
Primary legal authority: lex.uz · Competition Committee: raqobat.gov.uz
Lead practitioner: Assadullah Muradov — Managing Director, Bond Stone Tashkent
Bond Stone Uzbekistan office: Tashkent
Discuss your Uzbekistan competition law matter
Contact Bond Stone's Tashkent office for a confidential discussion about Competition Committee merger control filings, competition compliance, or antitrust advisory in Uzbekistan.