UZBEKISTAN · PUBLIC PROCUREMENT
Public Procurement in Uzbekistan
Public procurement in Uzbekistan is governed by Law No. ZRU-684 of 22 April 2021 on Public Procurement, as amended to July 2026. It covers state bodies and budget organisations. It also covers companies in which the state holds 50% or more, and their subsidiaries. Residents and non-residents may bid, and the Law prohibits discrimination between bidders, subject to possible preferences for domestic producers. Selection of best offers and tenders must be run electronically, and every procedure is published on the special information portal kept by the Ministry of Economy and Finance. Complaints go to a standing Complaints Commission, which must decide within seven working days, or to a court. Projects funded by international lenders follow the lender's rules where the loan terms say so.
This guide is for foreign suppliers, contractors and consultants bidding for Uzbek public contracts and contracts of state-owned enterprises. It covers who buys under the Law, the procurement methods and their thresholds, bidder requirements, preferences, complaints and anti-corruption rules. It also explains how procurement differs from public-private partnerships.
Legal Framework
- Law No. ZRU-684 of 22 April 2021 on Public Procurement, amended most recently by Laws No. ZRU-1126, ZRU-1141, ZRU-1155 and ZRU-1157 and Constitutional Law No. ZRU-1158 in 2026.
- Ministry of Economy and Finance, the authorised body. It regulates the system, issues the permits for operators of electronic procurement systems, sets the rules for the register of contracts and the register of unfair suppliers, and approves model documents (Article 18).
- Cabinet of Ministers resolutions on complaints, prequalification, framework agreements and centralised purchasing, to which the Law refers. These include Resolution No. 480 of 8 September 2026 on a transparent system for assessing the cost of public procurement.
- Law No. ZRU-537 of 10 May 2019 on Public-Private Partnership, a separate regime. It does not apply to public procurement (Article 1).
Who Buys Under the Law
| Type of customer | Who is included |
|---|---|
| Budget customers | State bodies and institutions, budget organisations, recipients of budget funds for procurement, state target funds and other funds in budget organisations |
| Corporate customers | Legal entities with a state share of 50% or more; entities in which such companies together hold 50% or more; and entities in which companies of that second tier together hold 50% or more |
The State Assets Management Agency keeps the list of corporate customers on the special information portal. Corporate customers report their purchases to the authorised body every quarter (Article 19). The Law applies to purchases under the Investment Programme and other state programmes, to customers' ordinary business, and to purchases funded from budgets, grants and foreign loans (Article 2).
The Law gives way in several situations. Where a foreign loan, grant or donor programme sets its own procurement rules, those rules apply, but the results must still be published on the portal (Article 2). Defence, security, state secrets and elections are governed by separate rules. The Law does not apply to bank resolution and liquidation, or to certain Islamic finance purchases by state-owned banks. Since July 2026, a territory with a special legal regime under a constitutional law, such as the Tashkent International Financial Centre, may have its own procurement rules (Article 2).
Procurement Methods and Thresholds
Thresholds are set in base calculation amounts (BCA), which have been UZS 440,000 since 1 September 2026. Amounts are per contract. The lower figure in brackets applies to budget customers.
| Method | When it is used | Threshold | Article |
|---|---|---|---|
| Electronic shop | Goods, and small works and services | Goods up to 25,000 BCA (2,500); works and services up to 100 BCA (50) | 49 |
| Simplified small-value procedure | Price comparison or quotes from at least three suppliers, without a procurement commission | Up to 50 BCA (25), and no more than 1,000 BCA a year | 51-1 |
| Reverse auction | Standard goods only, lowest price wins | Up to 25,000 BCA (6,000) | 52 |
| Selection of best offers | Price and quality criteria | Up to 25,000 BCA (6,000) | 56 |
| Tender | Price and quality criteria | Above 25,000 BCA (6,000), about UZS 11 billion (2.64 billion) | 64 |
| Two-stage procurement | Technically complex items whose specification cannot be fixed in advance | Above 25,000 BCA (6,000) | 70-2 |
| Direct contract | Only the cases listed in the Law | Any value | 71, 72 |
A tender notice is published through the portal at least 12 and at most 30 working days before the bid deadline (Article 66). A notice for selection of best offers runs for at least five working days (Article 58). Selection and tenders must be held electronically, a rule in force since 1 January 2022 (Articles 56, 64 and 85). In a tender, the electronic system generates the contract on the terms of the documentation and the winning bid. A winner that refuses to sign loses its deposit, and the reserve winner may take the contract (Article 70). Customers may also use framework agreements of one to three years with several winners (Article 38-2), centralised purchasing (Article 38-1) and tenders among prequalified suppliers (Articles 37 and 70-1).
Direct contracts
Direct contracts are allowed only in the cases listed in Article 71. These include purchases from a single supplier on the register of single suppliers, purchases authorised by a presidential or Cabinet act, emergencies, regulated-price goods, and purchases from the holder of exclusive intellectual property rights where no one else can supply. Additional work of up to 10% of the original contract price is also allowed. A single supplier may be used for unique technically complex goods, cultural property, natural monopolies and named suppliers (Article 72). The customer must publish a direct contract on the portal within five working days. If it does not, the contract is not paid (Article 71).
Who Can Bid: Foreign Suppliers
A bidder may be an individual or a legal entity, resident or non-resident (Article 23). A foreign company can therefore bid directly. It does not need an Uzbek subsidiary to take part, although the contract, tax position and local delivery may make one advisable. The register of contracts records a foreign supplier's home-country equivalent of the taxpayer number, together with the country of origin and the manufacturer (Article 47). Procurement information is published in the state language, and may also be published in other languages, whose content must match the state-language text (Article 35). Foreign bidders should budget for translation and check the Uzbek text.
Every bidder must (Article 36):
- have the technical, financial, material and staff resources to perform
- have legal capacity to contract
- have no overdue taxes or unpaid court judgments
- not be in insolvency
- not be on the register of unfair suppliers
Bidders must disclose their beneficial owner. A bidder and its affiliate may not bid for the same lot (Article 23). The commission may require bid security as a pledge, guarantee, deposit or other permitted means. The customer must confirm within two working days whether a proposed form of security is acceptable, and must return it within one working day of the triggering event (Article 39). Additional qualification requirements must be announced with the procurement and assessed through prequalification (Article 37).
Local Preferences
The Law prohibits discrimination and preferences for some bidders over others, with one exception. Where at least three domestic producers take part alongside foreign suppliers, presidential decrees and resolutions may grant the domestic producers benefits and preferences in bid evaluation, unless an international treaty of Uzbekistan provides otherwise (Articles 16 and 46). The size and conditions of any preference come from those presidential acts, not from the Law, so each procurement's documentation must be checked. Some direct-contract cases also favour local supply. One example is new vehicles and specialised and agricultural machinery bought from Uzbek manufacturers or their official dealers (Article 71, item 13).
Procurement by State-Owned Enterprises
State-owned companies and their majority-owned subsidiaries buy as corporate customers under the same Law. For goods, a corporate customer has a higher electronic shop ceiling than a budget customer (25,000 BCA against 2,500). Auction, selection and tender thresholds are likewise 25,000 BCA against 6,000. Corporate customers must still plan purchases, publish notices only when financing is confirmed, and report every quarter (Article 19). For a foreign supplier, the first check is whether the buyer is on the list of corporate customers. If it is, the Law's methods, publication and complaint rules apply to the contract.
Public-Private Partnerships
PPP projects are not procurement. Law No. ZRU-537 does not apply to public procurement or to production sharing agreements, and concessions follow the PPP rules (Article 1). The private partner is chosen by tender or, in limited cases, by direct negotiations (Articles 21 and 25). Projects up to the equivalent of USD 1 million use a one-stage tender, with at least 30 calendar days to bid. Larger projects use a two-stage tender with prequalification. Prequalification runs for at least 30 calendar days, and bidders then have at least 45 calendar days to submit (Article 21). Direct negotiations are allowed for defence and security, where a particular person holds exclusive rights or property essential to the project, or where a presidential or Cabinet act provides (Article 25). For structuring, risk allocation and state support, see Privatisation and State Partnership in Uzbekistan.
Challenges and Appeals
- Forum. A bidder may challenge acts or omissions of the customer, the procurement commission, its members or the platform operator, either in court or before the Complaints Commission. The Commission is a standing body made up of state, operator and public representatives, and the Ministry of Economy and Finance is its working body (Article 78).
- Suspension. Within three working days of receiving a complaint, the Commission notifies the customer and suspends the procedure for up to ten working days in total (Article 79).
- Decision. The Commission decides within seven working days, with both sides heard, and publishes the decision on the portal. It may prohibit unlawful acts, cancel unlawful decisions in whole or in part, order the procedure to be completed, or put the supplier on the register of unfair suppliers. Its decisions bind all parties. A supplier may challenge them in court (Article 79).
- Conflicts. A Commission member with a conflict of interest or an affiliation must step aside (Article 79-1).
The deadline for filing a complaint and the form it takes are set by the Cabinet of Ministers' complaints procedure, not by the Law, so the procurement documentation and the current procedure should be checked as soon as a result is announced. Contract disputes go to the courts under general rules (Article 80). For arbitration clauses in contracts with state-owned companies, see International Arbitration in Uzbekistan.
Anti-Corruption Rules
- Conflict of interest. Officials of the customer, the operator and specialised and expert organisations, commission members and experts may not take any personal benefit from a procurement. They must disclose actual or possible conflicts to their manager and to the authorised body (Article 14).
- Exclusion. A bidder is excluded if it offers or gives any reward, job offer or other value to a current or former official to influence the procedure, acts anti-competitively, or has an undisclosed conflict or affiliation (Article 42).
- Prohibited practices. These include participation where a close relative decides on the award, collusion on prices, splitting purchases to avoid competition, abnormally low bids followed by refusal to sign, false information, and procurement without confirmed funding (Article 46).
- No negotiations. The customer, the operator and bidders may not negotiate during the procedure (Article 40).
- Register of unfair suppliers. A supplier that refuses to sign, fails to perform, submits false documents, hides affiliation or is convicted of fraud or corruption is barred for two years. Inclusion may be challenged in court (Article 48).
Foreign bidders should apply their own anti-bribery controls to local agents and consortium partners. A breach by an affiliate can exclude the whole bid. Competition aspects, including bid rigging, are covered under Competition Law and Merger Filings in Uzbekistan.
Common Mistakes Foreign Bidders Make
- Assuming a state-owned company buys freely. If the state holds 50% or more, directly or through up to two tiers of majority-owned companies, the Law applies.
- Bidding alongside an affiliate for the same lot, which is prohibited.
- Missing the short windows. Selection notices can run for only five working days, and Commission review is quick.
- Relying on a translation without checking it against the state-language text.
- Treating a PPP opportunity as a tender under the Procurement Law. It runs under Law No. ZRU-537.
- Not checking whether a lender's rules replace the Law on a project funded by an international lender.
Frequently Asked Questions
Can a foreign company bid in Uzbek public procurement without a local entity?
Yes. The Law defines a bidder as a resident or non-resident individual or legal entity (Article 23). It must meet the general requirements in Article 36 and disclose its beneficial owner. Whether to perform through a local branch or subsidiary is a tax and practical question for each contract.
Do state-owned enterprises follow the procurement law?
Yes. Companies with a state share of 50% or more, and companies majority-owned by them, are corporate customers under Article 19. The State Assets Management Agency keeps their list on the special information portal.
Are there preferences for local producers?
The Law allows them only where at least three domestic producers compete with foreign suppliers. Presidential acts then set the preference, subject to Uzbekistan's international treaties (Article 16). Otherwise discrimination between bidders is prohibited (Article 46).
Above what value must a tender be held?
Above 25,000 BCA per contract for corporate customers and 6,000 BCA for budget customers, where the award is judged on quality as well as price (Article 64). At UZS 440,000 per BCA, that is about UZS 11 billion and UZS 2.64 billion.
How do I challenge a procurement result?
Complain to the Complaints Commission or go to court (Article 78). The Commission suspends the procedure for up to ten working days and must decide within seven working days. Its decisions are binding, and a supplier may take them to court (Article 79).
Do the rules apply to projects financed by the World Bank or ADB?
Where the loan or grant terms set their own procurement rules, those rules apply instead of the Law, but the results must be published on the special information portal (Article 2). Contract and FIDIC points for such projects are covered in Construction Licensing in Uzbekistan.
Bond Stone advises foreign bidders on Uzbek procurement documentation, bids, complaints and contracts from its Tashkent office. Contact info@bondstonelaw.com.
Related Pages
Privatisation and State Partnership in Uzbekistan · Construction Licensing in Uzbekistan · Commercial Contracts in Uzbekistan · Branch and Representative Office Registration · Competition Law and Merger Filings · International Arbitration in Uzbekistan · Regulatory Licensing in Uzbekistan
Primary sources (lex.uz, current editions read on 6 November 2026): Law No. ZRU-684 of 22 April 2021, Articles 2, 13, 14, 16, 18, 19, 23, 27, 35 to 37, 38-1, 38-2, 39, 40, 42, 46 to 49, 51-1, 52, 56, 58, 64, 66, 70, 70-1, 70-2, 71, 72, 78 to 80, 85; Law No. ZRU-537 of 10 May 2019, Articles 1, 21, 25; Cabinet of Ministers Resolution No. 480 of 8 September 2026 (title).