Uzbek FlagCivic Freedom Monitor: Uzbekistan

Introduction | At a Glance | Key Indicators | International Rankings
Legal Snapshot | Legal Analysis | Reports | News and Additional Resources
Last updated 27 August 2018


After Uzbekistan became an independent republic in 1991, civil society slowly began to develop. As with other countries of the former Soviet Union the legal framework is based on the civil law tradition, and legislation governing NGOs generally includes statements of support and protection for NGOs. Nonetheless, more than 25 years since independence, civil society does not yet play a vibrant role in the country. The government has tended to view the civic sector with suspicion. Indeed, most foreign and international NGOs which had operated in the country during the 1990s and early 2000s have since been closed and expelled from the country. In 2005, the government mandated a process of re-registration for NGOs, which led to a significant reduction in the number of NGOs in the country. In 2013 a number of organizations were also reportedly subject to "a new wave of inspections" by the Ministry of Justice (MoJ) and the country's tax authorities. Legislative trends under former President Islam Karimov were generally restrictive.

The country's first president after the Karimov era, Shavkat Mirziyoev, who assumed power after Karimov’s death in September 2016, has shown a "softer" hand than that of his predecessor, and some of the laws he has signed will be enabling for civil society if implemented properly. For example:

1. On September 14, 2016, Mirziyoev signed a new Law on Youth Policy. Notably, the law contains a provision that recognizes the participation of NGOs in the implementation of the state youth policy, but at the same time it does not provide any tools for NGOs to implement these activities.

2. On October 5, 2016, Mirziyoev issued a Decree on Additional Measures to Ensure Rapid Development of Entrepreneurial Activity, Protection of Private Property and High-Quality Improvement of the Business Climate. This decree contains several measures aimed at protecting entrepreneurs from unscheduled inspections while supporting the creation of favorable conditions for the development of businesses. Although this decree is designed for businesses, it will indirectly affect NGOs in a positive way. In the past, NGOs were often subjected to counter-check audits if, during general audits of commercial organizations, the auditors found issues in their contract relations with NGOs.

3. On October 21, 2016, Mirziyoev signed the Decree on Measures to Further Reform Judicial and Legal System, and Enhance Guarantees for Sound Protection of Rights and Freedoms of Citizens. The decree contains an action plan defined as the Program of Comprehensive Measures to Further Reform Judicial and Legal System, and Enhance Guarantees for Sound Protection of Rights and Freedoms of Citizens (the "Program"). NGOs consider this initiative as a positive step forward, since it provides for further liberalization of criminal procedure legislation, such as reduced terms for detention and the establishment of administrative courts. Potentially, this decree may also improve the effectiveness of the Law on Openness due to its focus on ensuring the openness and transparency of government bodies in their interactions with NGOs, mass media, and the general population.

4. On December 26, 2016, Mirziyoev signed the Law on Social Services for the Elderly, Disabled and Other Socially Vulnerable Categories of the Population (the Law on Social Services). The law was developed within the framework of the implementation of the State Program "Year of attention and care for the older generation". The main purpose of the law is to improve the legal framework for the provision of social services to the needy and to increase the role and responsibility of government, NGOs and business entities in this area.

5. On February 7, 2017, President Mirziyoev issued a decree to approve the Action Strategy on Five Priority Areas of the Country's Development for 2017-2021 (the "Action Strategy") (Russian) (Uzbek). In general, the Action Strategy emphasizes improvement to state management and services, comprehensive judicial and legal system reforms, economic liberalization and financial reforms, optimizing and improving social service provision, among other issues. NGOs are specifically mentioned in the Action Strategy, where it notes the “necessity of further development of civil society institutions and improvement of their social and political activism” (Paragraph 1.3 of the Action Strategy). The Action Strategy also refers to NGO engagement with government bodies to assist in “countering crime and the prevention of offenses” (Paragraph 2.4 of the Action Strategy.) 

6. On September 8, 2017, Mirziyoev signed the Decree on Approval of the Concept of Administrative Reform in the Republic of Uzbekistan ("The Concept"). The Concept specifically mentions that existing public-private partnerships do not function properly and limit the involvement of NGOs and businesses in resolving social problems. Further, the Concept identifies six main areas for reform of the public administration system, some of which contain components referring to NGO-related issues, such as improvement of:

  • regulatory tools through the transfer of certain government functions to the subjects of social control; and
  • the legal and institutional framework for social and public-private partnerships aimed at ensuring broad participation of NGOs and businesses in addressing issues of social and economic development.

7. On September 8, 2017, President Mirziyoyev also signed the Law on Distribution and Ensuring Access to Legal Information, which was developed by the MoJ and provides guarantees for free access to legal information and clarifies the authority of the Parliament, Cabinet of Ministries, and other government bodies on distribution of legal information. It also envisions the involvement of local self-governing bodies and NGOs in rendering assistance to government bodies in this process.

8. On September 11, 2017, President Mirziyoyev signed the Law on the Introduction of Amendments to the Law on Citizens’ Appeals. The most important amendment relates to the elimination of the requirement to provide electronic signatures while submitting appeals via the Unified Portal.

9. The amendments to the Law on Guarantees of the Activities of NNOs and the Law on Social Partnerships were adopted and entered in force on September 14, 2017. They empower government bodies to provide state social contracts to NGOs and clarify that these contracts will be funded from non-budgetary (non-governmental) sources.

10. On April 12, 2018, President Mirziyoyev signed the new Law on Public Control (effective as of April 13, 2018). The purpose of the law is to establish a legal framework for public oversight over the activities of government bodies and government officials. In accordance with the law, citizens, citizens’ self-government bodies, non-commercial organizations (NNOs), and mass media have the right to exercise oversight over activities of government bodies and officials.

11. In the wake of the Implementing Decree on Measures to Fundamentally Enhance the Role of Civil Society Institutions in the Process of Democratic Renewal of the Country of May 4, 2018, the Ministry of Justice issued Order #3020 of June 1, 2018, which establishes the Regulation on the Procedure for Informing about Planned Activities of Non-governmental Non-commercial Organizations. It replaces the Regulation on Procedure of Coordination of NNOs’ Activities of June 4, 2015. According to a summary posted on, starting from June 1, 2018:

  • NGOs will no longer be required to obtain approval from the MoJ in order to conduct events, but still need to notify the MoJ of plans to conduct such events;
  • The minimum period for informing the justice body of planned activities will be reduced to:
    • 10 days before the start of event without the participation of foreign citizens;
    • 20 days before the start of event with the participation of foreign citizens; and
  • Justice bodies will only provide NGOs with written notice in case of a refusal to conduct the event.

12. On June 27, 2018, the Ministry of Justice issued Order #3027, which establishes a new form of annual reporting on the activities of NNOs for submission to the justice bodies. The new form will serve as uniform reporting form for NNOs, their structural divisions, as well as for branches and representative offices of foreign non-profit organizations. By contrast, there were previously three separate forms of reporting for each of the types of organizations listed.

13. Most recently, on August 8, 2018, the Ministry of Justice adopted the new Regulation on Monitoring and Studying Activities of Non-governmental Noncommercial Organizations by Justice Bodies. In accordance with President Mirziyoyev’s Decree of May 4, 2018, the Regulation establishes a separate procedure on monitoring and studying NGOs’ activities.

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At a Glance

Organizational Forms Non-Governmental Non-commercial Organizations (NGOs), which include public associations, public funds, institutions and associations of NGOs
Registration Body Ministry of Justice
Approximate Number

Number of registered NGOs is unknown. According to the Uzbek government reports, there were over 6,000 NGOs in Uzbekistan as of November 2013. This number includes multiple branches of such groups as Kamolot Public Youth Movement, Uzbekistan’s Women Committee, Independent Institute of Monitoring of Establishment of Civil Society (NIMFAGO), Makhalla Fund, and National Association of Non-governmental Non-commercial Organizations (NANNOUz), among others, which are subsidized and controlled by the government.

Barriers to Entry

(1) Mandatory registration; unregistered group activities prohibited;
(2) Detailed documentation requirements, and potentially burdensome registration fee;
(3) Vague grounds for denial of registration;
(4) Implementing regulations allow the registration body “to leave the registration application without consideration,” contrary to the law.  Such action does not allow the group to either appeal the denial to court, or to re-submit the registration application, leaving it in legal limbo;
(5) The registration application, at the discretion of registration bodies, can be sent for “expertise” to other government bodies, which prolongs the registration process beyond the 1 month allowed for by law for consideration of the registration  application; and
(6) Excessive time delays in government review of registration applications.

Barriers to Activities (1) Burdensome and vague reporting requirements;
(2) NGO obligation to ensure governmental access to all activities;
(3) Advance governmental approval required for particular NGO activities;
(4) Harsh sanctions for violation of law.
Barriers to Speech and/or Advocacy In practice, the Government may act against NGOs that engage in certain kinds of advocacy activity.
Barriers to International Contact (1) Advance governmental approval required for conferences, international participants, etc.;
(2) Limited access to certain websites.
Barriers to Resources Limits on foreign funding
Barriers to Assembly Regulations vague or nonexistent; severe punishments and the threat of use of force deter protests.

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Key Indicators

Population 29,473,614 (July 2016 est.)
Capital Tashkent
Type of Government Republic; authoritarian presidential rule, with little power outside the executive branch
Life Expectancy at Birth Male: 70.7 years
Female: 77 years (July 2016 est.)
Literacy Rate Male: 99.7%
Female: 97.5% (July 2016 est.)
Religious Groups Muslim: 88% (mostly Sunnis); Eastern Orthodox: 9%; other: 3%
Ethnic Groups Uzbek 80%, Russian 5.5%, Tajik 5%, Kazakh 3%, Karakalpak 2.5%, Tatar 1.5%, other 2.5% (1996 est.)
GDP per capita $6,100 (2015 est.)

Source: The World Factbook. Washington, DC: Central Intelligence Agency, 2009.

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International Rankings

Ranking Body Rank Ranking Scale 
(best – worst possible)
UN Human Development Index 105 (2016) 1 – 182
World Bank Rule of Law Index 11 (2016) 100 – 0
World Bank Voice & Accountability Index 21 (2016) 100 – 0
Transparency International 105 (2017) 1 – 168
Freedom House: Freedom in the World

Status: "Worst of the Worst"
Political Rights: 7

Civil Liberties: 7 

1 – 7
1 – 7
Foreign Policy: Fragile States Index
67 (2018) 177 – 1 

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Legal Snapshot

International and Regional Human Rights Agreements

Key International Agreements Ratification* Year
International Covenant on Civil and Political Rights (ICCPR) Yes 1995
Optional Protocol to ICCPR (ICCPR-OP1) Yes 1995
International Covenant on Economic, Social, and Cultural Rights (ICESCR) Yes 1995
Optional Protocol to ICESCR (OP-ICESCR) No  --
International Convention on the Elimination of All Forms of Racial Discrimination (ICERD) Yes 1995
Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW) Yes 1995
Optional Protocol to the Convention on the Elimination of Discrimination Against Women No  --
Convention on the Rights of the Child (CRC) Yes 1994
International Convention on the Protection of the Rights of All Migrant Workers and Members of their Families (ICRMW) No  --
Convention on the Rights of Persons with Disabilities (CRPD) No  --
International Labor Organization’s The Freedom of Association and Protection of the Right to Organise Convention  Yes 2016
Regional Treaties    
CIS Agreement on joint activity in relation to foreign humanitarian aid Yes 1993

* Category includes ratification, accession, or succession to the treaty

Constitutional Framework

The Constitution of the Republic of Uzbekistan [1] was adopted by the Supreme Council of the Republic of Uzbekistan on December 8, 1992.

Relevant constitutional provisions include: 

  • Article 30. All state bodies, public associations and officials in the Republic of Uzbekistan shall allow any citizen access to documents, resolutions and other materials, relating to their rights and interests.
  • Article 32. All citizens of the Republic of Uzbekistan shall have the right to participate in the management and administration of public and state affairs, both directly and through representation. They may exercise this right by way of self-government, referendums and democratic formation of state bodies as well as through development and improvement of public control over the activities of state authorities. The procedure for exercising public control over the activity of state bodies is determined by law.
  • Article 33. All citizens shall have the right to engage in public life by holding rallies, meetings and demonstrations in accordance with the legislation of the Republic of Uzbekistan. The bodies of authority shall have the right to suspend or ban such undertakings exclusively on the grounds of security.
  • Article 34. All citizens of the Republic of Uzbekistan shall have the right to form trade unions, political parties and any other public associations, and to participate in mass movements. No one may infringe on the rights, freedoms and dignity of the individuals, constituting the minority opposition in political parties, public associations and mass movements, as well as in representative bodies of authority.
  • Article 56. Trade unions, political parties, and scientific societies, as well as women's, veterans' and youth leagues, professional associations, mass movements and other organizations registered in accordance with the procedure prescribed by law, shall have the status of public associations in the Republic of Uzbekistan.
  • Article 57. The formation and functioning of political parties and public associations aiming to do the following shall be prohibited: changing the existing constitutional system by force: coming out against the sovereignty, territorial integrity and security of the Republic, as well as the constitutional rights and freedoms of its citizens; advocating war and social, national, racial and religious hostility, and encroaching on the health and morality of the people, as well as of any armed associations and political parties based on the national or religious principles.  All secret societies and associations shall be banned.
  • Article 58. The state shall safeguard the rights and lawful interests of public associations and provide them with equal legal possibilities for participating in public life.  Interference by state bodies and officials in the activity of public associations, as well as interference by public associations in the activity of state bodies and officials is impermissible.
  • Article 59. Trade unions shall express and protect the socio-economic rights and interests of the working people. Membership in trade unions is optional.
  • Article 60. Political parties shall express the political will of various sections and groups of the population, and through their democratically elected representatives shall participate in the formation of state authority. Political parties shall submit public reports on their financial sources to the Oliy Majlis or their plenipotentiary body in a prescribed manner.
  • Article 61. Religious organizations and associations shall be separated from the state and equal before law. The state shall not interfere with the activity of religious associations.
  • Article 62. Public associations may be dissolved or banned, or subject to restricted activity solely by the sentence of a court.

[1] English text of Constitution.

National Laws and Regulations Affecting Sector

Relevant national-level laws and regulations affecting civil society include:

Pending NGO Legislative / Regulatory Initiatives

1. On May 4, 2018, the President of Uzbekistan adopted a decree On Measures to Fundamentally Enhance the Role of Civil Society Institutions in the Process of Democratic Renewal of the Country (“the Decree”). The Decree substantially improves the regulatory environment for civil society organizations (CSOs) in Uzbekistan. Specifically, starting from June 1, 2019:

- CSOs will no longer be required to obtain approval from the Ministry of Justice (MoJ) in order to conduct events. They will only be required to notify the MoJ of plans to conduct such events.

- CSOs will be permitted to receive grants from foreign sources to accounts opened with any bank. Previously, CSOs were permitted to receive grants only to accounts opened with the state-owned banks “Asaka” and the National Bank on External Economic Activity.

- CSOs will be able to use funds and assets received from foreign sources for statutory purposes after receiving approval from the MoJ. Therefore, the previous procedure, which was excessively complex and burdensome, will be abolished.

- The rate for social tax for CSOs that generate income from non-entrepreneurial activities will be limited to 15%.

The Decree also requires the MoJ to work jointly with the Ministry of Development of Informational Technology and Communication to develop and introduce an electronic system for the submission of documents by CSOs by January 1, 2019. The system will include:

- documents relating to state registration of CSOs, their re-registration, and registration of brand marks;

- notifications about planned events;

- annual reports on activities of CSOs; and

- requests for approval for the receipt of funds from foreign sources.

Local governments will be required to establish public funds to support CSOs and to provide financing to such public funds starting from the beginning of 2019. The MoJ, jointly with the Prosecutor General’s office and the Supreme Court, is also required to introduce proposals on the revision and substantial reduction of administrative penalties for violations of legislation related to CSO activities. In addition, an Advisory Council on the Development of Civil Society will be established with the President of Uzbekistan. Its main goals, among others, include:

- establishing comprehensive and effective dialogue between the state and the civil society institutions at the highest level;

- developing proposals to define strategic directions and establish a national civil society development model in the medium-to-long term; and

- establishing indicators for evaluation of civil society, based on its level of cooperation with state bodies.

Independent Institute to Monitor the Formation of Civil Society (NIMFOGO) will be responsible for organizing the work of the Advisory Council.

By January 1, 2019, all regions and Tashkent city will establish “Houses of Non-Governmental Non-Commercial Organizations.” Public benefit CSOs will have the opportunity to use office space in such houses free of charge.

The Decree takes into consideration many recommendations proposed to the Uzbek government by CSOs. CSOs will work to assist with implementation of these notable reforms, which have the potential to greatly improve the operating environment for CSOs in Uzbekistan.

2. On February 13, 2018, the President of Uzbekistan issued Decree #5214 on Organizational Measures to Radically Improve Tax Legislation, which ordered the creation of a commission responsible for the development of a draft concept for Tax Reform by April 1, 2018 and a draft of a new Tax Code by July 1, 2018. The Decree notes that “there is a need to further improve the activities of the tax authorities, including their interaction with taxpayers and other government agencies, timely and full levying of tax debts, and introduction of effective modern forms and methods of tax control.” On March 27, 2018, the Government published the draft Concept of Tax Reform for public discussion. The draft Concept was developed by the National Project Management Agency under the President of the Republic of Uzbekistan in accordance with the Presidential Decree #5214 and envisages reducing the tax burden, the VAT rate, unification and cancellation of a number of taxes and mandatory payments, as well as measures to improve tax administration. There is hope that Decree #5214 will lead to positive tax reforms to improve and simplify the overall tax situation for NNOs in Uzbekistan.
While we aim to maintain information that is as current as possible, we realize that situations can rapidly change. If you are aware of any additional information, please keep us informed; write to ICNL at

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Legal Analysis

Organizational Forms

The Civil Code defines a legal entity to include both commercial and non-commercial organizations and contains a list of permissible legal forms, including, among others, the public association, public fund, institution, legal entities’ associations (societies and unions), and citizens’ self-governance body.  Mirroring the language of the Civil Code, the Law on NGOs states that non-governmental, non-profit organizations may be established in the following forms: public association, public fund, institution, and other lawful forms provided by legal acts.  The Law on Public Associations is the primary law under which NGOs are established and operate.   In addition, NGOs may form associations or unions, with the purpose of coordination of their activities, and in order to represent and advocate common interests.  NGOs can be established for protecting the rights and lawful interests of natural persons and legal entities; for achieving social, cultural and educational aims; to satisfy spiritual and other non-material needs; and for realizing other public benefit purposes.  Founders of an NGO must detail the organizational purposes in the charter of the NGO. 

public association is a voluntary association of citizens (natural persons only) who have joined together for the realization of their common interests in the areas of politics, economics, social development, science, culture, ecology, and other aspects of life (Article 1, the Law “On public associations” and Article 11, the Law “On NGOs”). 

public fund is recognized as a non-membership organization, founded by natural and/or legal persons on the basis of voluntary property contributions, pursuing charitable, social, cultural, educational, or other public benefit purposes (Article 12, the Law “On NGOs” and Article 3, the Law “On Public funds”).

An institution is recognized as an organization established by natural and/or legal persons in order to realize social, cultural and other functions of non-profit nature (Article 13, the Law “On NGOs”).  Notably, the legal form of “institution” is a legacy of the Soviet legal system.  There are no existing procedural rules in place to establish and register an institution; in practice, therefore, this form is essentially non-existent. 

The association (union) of NGOs is a legal entity whose founding members are legal persons (NGOs).  It is not possible to establish an association made up of both natural and legal entities simultaneously.  Members of associations (unions) have secondary (vicarious) liability on obligations of the overarching association (union); the degree of liability is based on the charter of the association (union). 

citizens’ self-governance body (more commonly known as “mahalla”) is a traditional form of neighborhood organization. The activities of the “mahalla” are governed by the Law "On self-governance bodies".

Uzbek law also categorizes NGOs according to the territorial scope of their activity: international NGOs, which can operate not only in Uzbekistan, but in other countries; republican or inter-regional NGOs, which can operate in several regions of Uzbekistan or throughout the country; and local NGOs, which can operate only in one region or in Tashkent city. 

Public Benefit Status

Uzbek law provides for a “charitable organization” status, but it is not linked to fiscal benefits.  Instead, all registered NGOs are exempt under tax law from certain taxes and financial obligations.  Details follow.

(1) A charitable organization is a non-governmental, non-commercial organization established for the purpose of implementing philanthropic activities in the interest of the public at large as well as in the interest of specific categories of legal entities and physical persons (Article 3 of the Law “On charity”). Charitable organizations may be created in the form of a public association, foundation or in any other form stipulated by legislative acts (Article 6 of the Law “On charity”).  Significantly, however, there are no tax or fiscal benefits linked to charitable organization status. Article 14 of the Law “On Charity” declares that government can provide support (e.g., discount on rent, if the accommodation or other property is owned by government; transfer government property to charitable organizations, and so on) to charitable organizations. But there is no legal obligation to provide concrete benefits to charitable organizations.  

(2) According to Article 17 of the Tax Code, the term non-commercial organization includes all legal entities that do not seek to gain profit as the main purpose of their activities and do not distribute income (profits) among their members.  Through registration, NGOs accrue rights as a legal entity and the status of a non-commercial organization. All non-commercial organizations, irrespective of their organizational legal form, are exempt from the following taxes: 

  • corporate income (profit) tax, except where NGOs carry out commercial activities (Article 126 of the Tax Code);
  • value-added tax, with some exceptions (Article 197 of the Tax Code);
  • corporate property tax (Article 265 of the Tax Code);
  • land tax (Article 279 of the Tax Code);
  • tax on use of water resources (Article 257 of the Tax Code); and
  • tax on improvement and development of social infrastructure (Article 295 of the Tax Code). 
In addition, non-commercial organizations are exempt from the following compulsory payments:

  • compulsory payments to non-budget pension fund (Article 312 of the Tax Code);
  • compulsory payments to Republican Road fund (Article 316 of the Tax Code); and
  • compulsory payments for school education development (Item 5 of Regulation “On order of calculating and payment of compulsory payments for school education development"). 

The foregoing fiscal privileges do not generally apply to income generated through the commercial activity of NGOs. Certain categories of NGOs are exempt from several compulsory payments and taxes, even where the NGO carries out economic activity through a corporate subsidiary.  For example, enterprises owned by public associations of disabled persons, the Fund “Nuroniy (Нуроний)” and associations of “Chernobolci of Uzbekistan (Чернобольцы Узбекистана)” – if disabled persons make up at least 50% of the total amount of enterprise staff – are exempt from VAT and corporate income (profit) tax (Article 158 of the Tax Code). 

Barriers to Entry

There are multiple legal barriers affecting the formation and registration of NGOs in Uzbekistan.

First, registration is mandatory and unregistered group activities are prohibited.  An NGO is established only when officially registered (Article 15 of the Law “On NGOs”).  Available sanctions for carrying out activities through an unregistered include a fine 50-100 times the minimum wage (Article 239 of the Administrative Code).  Active participation in unregistered (i.e., illegal) organizations exposes offenders to a fine 50-100 times the minimum wage or detention of up to six months or imprisonment of up to five years (Article 216 of the Criminal Code).

Second, the registration requirements, which vary according to the organizational form, are more demanding than the registration requirements for commercial organizations.  Required documentation is quite detailed. As of January 1, 2014, the registration fee for NGOs is reduced 5 times. This means that the current fees are four minimal monthly incomes for national associations and two minimal monthly incomes for local associations. In contrast, prior to January 1, 2014, in order to register a national level public association it was necessary to pay 20 minimal monthly incomes (1,900,000 som, approximately $863), and in order to register a local public association 10 minimal monthly incomes (950,000 sum, approximately $430) were required. The registration fee for registration of symbols of NGOs has also been reduced 2.5 times the prior amount.  No fee is required for registration of branches of NGOs. Organizations of disabled persons, veterans, women’s and youth organizations will only pay half of the registration fee.

Third, the implementing regulations (Rules on Consideration of Applications on Registration of By-laws of Public Associations) allow the registration body “to leave the registration application without consideration,” contrary to the law.  Such action does not allow initiative groups to either appeal the denial to court or to re-submit the registration application, leaving them in legal limbo.

Fourth, the registration application, at the discretion of registration bodies, can be sent for “expertise” to other government bodies, which prolongs the registration procedure beyond 2 months allowed for by law for consideration of the registration  application (1 month starting from January 1, 2014),

Fifth, the grounds for denial of registration may invite the exercise of excessive government discretion.  Specifically, the law allows for denial where the name or symbols of an NGO encroaches on “morality, national or religious feelings of citizens”.  

Arguably the most serious barrier to registration is the excessive time delays for government review of applications. The law does define a fixed time period within which the Ministry of Justice must consider and decide on registration applications: one month from the receipt of the application for a public association; not more than one month for a social fund; and ten days for an association of NGOs. According to the “Rules of processing the applications for charter registration of public associations acting on territory of Republic of Uzbekistan,” the period of registration review can be extended by an additional month; this extended period is often missed by the registration body.

The problem of unprocessed applications is aggravated by the inability to appeal. Notably, the refusal of registration can be appealed in a court by law. But where the application is simply unprocessed, the NGO applicant has no ability to appeal and no alternative recourse. 

In September 2011, the UN Human Rights Committee held in the case of Kungurov v. Uzbekistan that the procedure in Uzbekistan for registering the non-governmental organization “Democracy and Rights” violated both the right to freedom of expression and the right to freedom of association, under Articles 19 and 22 of the International Covenant on Civil and Political Rights, respectively.

For more information, please see the statement from Article 19.

Barriers to Operational Activity

NGOs are subject to burdensome reporting requirements.  According to Article 33 of the Law on NGOs, NGOs must maintain records of the results of their activities, and must submit reports to the registration authorities (Ministry of Justice and its departments), to the statistical authorities, and to the tax authorities.  All NGOs are subject to the same detailed reporting standard; there is no simplified reporting form available for small and medium-sized NGOs.  The frequency of reporting varies with the category of report; some are required on a monthly basis, some on a quarterly basis, and others on an annual basis.  

While clear standards have been set for reporting to the statistical authorities, there is no regulation or legal guideline that defines the reporting procedure to the Ministry of Justice and its departments.  In practice, NGOs provide reports to registry bodies every quarter.  The required content of the reports may change; In January 2010, for example, NGOs in Tashkent were notified by the Ministry of a new reporting form, which contains 58 questions.  Moreover, the tax authorities, as of January 2010, are requiring NGOs that previously used a simplified tax and reporting system to re-calculate their tax obligation and prepare new reports, based on the requirements of the generally established tax system.  To complicate matters, NGOs are being given only 10-15 days to accomplish the task.

According to Article 8 of the Law on NGOs, NGOs are obliged to provide access to information on the use of organizational property and financial assets.  In addition, NGOs must ensure that the Ministry of Justice has access to all their activities. This provision is problematic in large measure because of its ambiguity; should NGOs notify the registry bodies about all their activities, including internal meetings, or only about public events?  The answer is unclear. In practice, NGOs provide information about public events.

The law requires that NGOs seek and secure approval from the Ministry of Justice for particular activities.  But the law does not define what particular activities require Ministry approval.  This ambiguity in the law obviously creates confusion among NGOs, and gives the Government excessive discretionary power.

This problem is exacerbated by the harsh sanctions available in case of violation of the rule.  Specifically, conducting events without the approval of the Ministry of Justice could subject NGOs – that is, the staff members of the NGO – to a fine amounting to 100-150 times the minimum wage. 

Severe sanctions are also available for the failure to submit reports, for the late submission of reports, and for the submission of reports in the wrong form.  Article 239 of the Administrative Code, applicable to NGOs, provides for a fine amounting to 50-100 times the minimum wage.  For-profit companies, by contrast, face a far lighter penalty for the same violation; Article 215, applicable to for-profits, envisions a fine amounting only to 7-10 times the minimum wage.

On April 25, 2016, the government adopted a Law on Introduction of Amendments to Some Legislative Acts, which introduced amendments to the Law on Non-Governmental Non-Commercial Organizations (Law on NNOs), the Law on Public Foundations, the Law on Bank Secrecy, the Law on Charity, and the Code of Administrative Liability. This new legislation represented a significant deterioration in the NGO legal environment because it introduced additional restrictions on activities, such as the requirement to notify the Ministry of Justiceabout upcoming trips of NGO representatives to foreign countries, and to obtain approval for the receipt of all funds and assets from foreign states, organizations, and citizens.

Government-organized NGOs (GONGOs) may pose a potential threat to independent civil society in Uzbekistan, but it is not clear if GONGOs have actually had a negative impact on the NGO sector.  There have been positive examples of cooperation between GONGOs and NGOs.  In 2005, the National Association of NGOs of RUz (NANNOUz in Russian) was established.  While clearly controlled by the Government, NANNOUz has done some good things for the NGO sector, by creating informational centers throughout the country for NGOs, and by providing small grants to NGOs.  Admittedly, these small grants were awarded to the members of NANNOUz, but nonetheless this marked the first instance of government providing financial support to NGOs from the state budget.  The small grants program and budgetary assistance for NGOs is now being extended on an annual basis. 

Barriers to Speech / Advocacy

According to Uzbek law as written, there are no barriers restricting speech or advocacy activity in Uzbekistan; NGOs and individuals are both free, in theory, to criticize the Government, for example. In practice, however, there are constraints on speech and advocacy.  NGOs engaging in human rights activity or government monitoring, for example, may be subject to harassment or even termination.  Because these measure are extra-legal (i.e., outside the law), they are unpredictable.

NGOs are affirmatively granted the right to participate in legislative activities, and “to exercise lawmaking initiative.” For example, some NGOs make seek engagement with Parliament and/or governmental bodies by preparing analyses of legislation or through conducting a conference to facilitate cross-sectoral dialogue on draft legislation.  In practice, however, few NGOs take advantage of this right. 

Barriers to International Contact

NGOs seeking to conduct a conference, to invite international participants to these conferences, etc. must secure advance approval from the Ministry of Justice.  In practice, NGOs submit a letter to the Ministry of Justice, describing a proposed conference (goals, date, participants, etc.).  If the Ministry grants permission for the conference, the NGO can move forward with planning; if the Ministry refuses permission, then there will be no conference.

In addition, all citizens seeking to work abroad must receive permission from the Ministry of Labor.

Access to certain websites is banned for all citizens.  Indeed, on August 5, 2011, the Cabinet of Ministries passed a Resolution no.228 “On additional measures on development system of monitoring in sphere of mass communications”. According to this Resolution, an “expert commission” will be created to identify information that is exerting a negative social impact on the citizens of Uzbekistan and the source of that information. The “expert commission” can recommend to close any mass media outlet or prohibit the dissemination of any informational resource in Uzbekistan.

Barriers to Resources

The process of receiving foreign funding is burdened by a number of legal barriers.  First, in order to receive a foreign grant, an NGO must receive a special conclusion from the Commission under the Cabinet of Ministers that the project to be supported by the grant is indeed worthy of support.  Second, the grant funding must be sent to “Asaka” or “NBU” bank (one of two state-owned banks).  In practice, the state-owned banks determine whether to release the money to the NGO and often block the release of funding, thus interfering with the ability to receive financial support.  Third, after receiving the grant funding, the NGO must provide several reports to a special government body operating under the Ministry of Finance.  The reports can be divided into two groups: (a) monthly reports; and (b) transactional reports, which are required following each financial transaction relating to the use of the grant funding. For example, if an NGO buys a pen or a desk with grant funding, then it needs to submit a report on the next business day.   

On June 23, 2010, the Cabinet of Ministers issued Resolution №123 “On adoption of the Regulation on order of realization of technical assistance projects and programs in sphere of narcomania (drug abuse) prevention and struggle against illegal turnover of drugs, which funded by foreign, international organizations or foreign states, and also other legal entities.” The new order complicates the process of securing governmental approval for projects relating to the prevention of drug abuse and the illegal turnover of drugs. For international organizations, securing official approval involves a six-step process, with five governmental organs involved in the review of the proposed project. For national organizations, the approval process is a similarly bureaucratic five-step process.

According to the Law "On Introducing Amendments and Addenda to Some Legislative Acts of the Republic of Uzbekistan", which was introduced in 2016, the MoJ may receive information about an NGO's bank account in cases where the information is deemed necessary to monitor compliance with the law.

On June 15, 2016, the MoJ approved a new implementing "Regulation on the Procedure of Coordination of Receipt of Monetary and Other Assets by Non-governmental Non-commercial Organizations (NNOs) When Such Assets are Received from Foreign States, International and Foreign Organizations, Citizens of Foreign States, or From Other Persons, Authorized by the Mentioned Above Persons (Regulation)". The Regulation came into effect on June 20, 2016 and establishes a procedure of obtaining approval from the MoJ for assets received by NNOs from foreign sources. The Regulation was adopted to implement Article 8 of the Law on Non-governmental Non-commercial Organizations (Law on NNOs).

According to the Regulation, all NNOs, including foreign NNOs (FNNOs), with registered offices in Uzbekistan are required to obtain the MoJ’s approval in order to receive assets from any foreign source. This new procedure provided in the Regulation is not a replacement, but an addition to, the already-existing extremely burdensome procedure of obtaining permission to receive foreign aid involving obtaining approvals from the Ministry of Foreign Affairs and the Banking Commission. The Regulation further complicates the receipt of funds by NNOs from foreign sources.

Barriers to Assembly

Article 33 of the Constitution of Republic of Uzbekistan establishes that "All citizens shall have the right to take part in civic activities by way of participating in rallies, meetings and demonstrations in accordance with the legislation of the Republic of Uzbekistan. Government agencies shall only have the right to suspend or ban such events on the grounds of substantiated security considerations."

Article 12 of Law #1051-XII "On the Guarantees of the Citizens' Electoral Rights" of May 5, 1994 confirms that the "electorate shall be guaranteed the right to take part in civic activities in the form of rallies, assemblies and demonstrations" in compliance with the legislation of the Republic of Uzbekistan."

On July 29, 2014, the Cabinet of Ministers passed Decree #205 "On measures of Further Improvement of the Procedures for Organizing and Holding Public Events," which established the rules for holding "mass events" (Addendum #1 to the Cabinet's Decree #205 of July 29, 2014). A "mass event" is defined as "the presence of citizens, organized at the venue of a public happening for the purpose of holding social and political programs (i.e. symposia, conferences, congresses, etc.); cultural and entertainment programs and performances (music, literature and other festivals, concerts, theatrical, sports and promotional events, folk festivals, circus and folkloric shows, games, displays and competitions, etc.); and also national religious and professional celebrations, with the attendance of 100 people or more."

Excessive Penalties
Penalties contained in the "The Code of the Republic of Uzbekistan on Administrative Responsibility" may deter organizers from planning and conducting public assemblies. For example, fines in the amount of 60-80 times the minimum allowable monthly wages and an administrative detention period of up to 15 days may result from violating the established procedure of organizing or carrying out public gatherings, rallies, marches and demonstrations (Article 201). In addition, any provision of premises or other property (means of communications, copiers or other technologies, equipment or vehicles) or facilitating conditions for carrying out [public gatherings, rallies, marches and demonstrations] may result in the imposition of fines in the amount of 50-100 times the minimum allowable monthly wages on regular citizens, and 70-150 minimum times the monthly wages on government officials (Article 202).

Threat of Use of Force
Since 2005, when hundreds of protesters were killed in confrontations with the Uzbek security forces in Andijon, there have been few public protests.

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UN Universal Periodic Review Reports

Uzbekistan (April 24, 2013)

Reports of UN Special Rapporteurs Uzbekistan
USIG (United States International Grantmaking) Country Notes Not available
Human Rights Watch World Report 2018: Uzbekistan
U.S. State Department 2016 Country Reports on Human Rights Practices: Uzbekistan
Fragile States Index Reports Foreign Policy: Fragile States Index
IMF Country Reports Uzbekistan and the IMF
International Commission of Jurists Not available
International Center for Not-for-Profit Law Online Library Uzbekistan

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News and Additional Resources

While we aim to maintain information that is as current as possible, we realize that situations can rapidly change.  If you are aware of any additional information or inaccuracies on this page, please keep us informed; write to ICNL at

General News

Ministry of Justice of Uzbekistan and USAID signed a Memorandum of Understanding (June 2018)
On June 8 this year, a ceremony of signing a Memorandum of Understanding between the Ministry of Justice of the Republic of Uzbekistan and the US Agency for International Development USAID in the field of supporting the strengthening of the rule of law in Uzbekistan.

Law on public control enters into force in Uzbekistan (March 2018)
President Shavkat Mirziyoyev signed the Law "On public control" on April 12, 2018. The law was passed by the Legislative Chamber on November 15 and approved by the Senate on March 29, 2018. The act aims at regulating relations in the field of organization and implementation of public control over the activities of state bodies and institutions.

Concept of tax reform for 2018-2020 published for public discussion (March 2018)
The National Project Management Agency under the President of the Republic of Uzbekistan prepared a draft concept on radical reform of the tax system. The document envisages reducing the tax burden, the VAT rate, unification and cancellation of a number of taxes and mandatory payments, as well as measures to improve tax administration.

Shavkat Mirziyoyev orders drafting of new tax code (February 2018)
President Shavkat Mirziyoyev on February 13 signed an Organizational Measures to Radically Improve Tax Legislation Decree. The document notes that "the state of affairs in terms of finding additional reserves for increasing the incomes of the central and local budgets, introduction of modern ICTs in the process of tax administration, implementation of the best proven methods of tax legislation and administration" remains unsatisfactory in Uzbekistan.

UN High Commissioner for Human Rights in historic Uzbekistan visit (May 2017)
Uzbekistan has taken the unprecedented step of agreeing to work closely with the Office of the United Nations High Commissioner for Human Rights (OHCHR) bringing it into line with the other four Central Asian republics. On May 10, United Nations High Commissioner for Human Rights Zeid Ra'ad Al Hussein became the first such commissioner to visit Uzbekistan, a historic moment that never seemed likely to occur under the iron-fisted rule of long-time Uzbek leader Islam Karimov who died last September. At the invitation of the Uzbek government, now under President Shavkat Mirziyoyev who took office last December, Zeid arrived in the country where he received assurances that Uzbekistan intends to engage with the OHCHR's Regional Office in Bishkek.

Uzbekistan adopts law on social services for population (December 2016)
The President of the Republic of Uzbekistan Shavkat Mirziyoev on December 26 signed the :Law on social services for the elderly, disabled and other socially vulnerable categories of the population". The law was adopted in order to further improve the legal framework for the provision of social services to the needy categories of the population, determining the general requirements and the main areas of their provision, increasing the role and responsibility of government, non-government organizations and business entities in this field.

Uzbekistan elects Shavkat Mirziyoyev as president (December 2016)
Uzbekistan's interim leader, Shavkat Mirziyoyev, has won a crushing presidential election victory to succeed the late Islam Karimov, official results show. The central election commission said Mirziyoyev secured 88.6% of Sunday's vote, according to a preliminary count, while western monitors reported signs of fraud. One election monitor, the Office for Democratic Institutions and Human Rights (ODIHR), said the election underscored "the need for comprehensive reforms" in Uzbekistan, where Karimov had extended his power for years in a series of votes denounced as undemocratic by western governments and international observers.

Ministry of Justice receives right to check CSOs’ bank accounts (April 2016) (Russian)
According to the Law "On Introducing Amendments and Addenda to Some Legislative Acts of the Republic of Uzbekistan", the MoJ may receive information about an NGO's bank account in cases where the information is deemed necessary to monitor compliance with the law.

Government significantly decreases sizes of administrative penalties for CSOs (April 2016) (Russian)
In the implementation of the activities of NGOs (except religious organizations), their representative offices and branches without state registration is now punishable by a fine of 15 to 30 time the minumum wage; previously it was 50 to 100 times the minimum wage.

Law of Uzbekistan on Appeals of Individuals and Legal Entities discussed (February 2015)
The Ministry of Justice of the Republic of Uzbekistan held a conference devoted to discussing the essence, meaning and application in practice of the Law of the Republic of Uzbekistan on Appeals of Individuals and Legal Entities.

Uzbekistan Gears Up to Vote for "Rubberstamp" Parliament (December 2014)
Uzbekistan's parliamentary elections on December 21 will offer voters a choice, but no hope for change. No opposition parties are permitted to legally exist in Uzbekistan, and independent candidates are barred from standing in elections.

HRW Documents Plight Of Political Prisoners
(October 2014)
Based on court documents and extensive interviews, a new report by Human Rights Watch (HRW) found that those jailed in Uzbekistan on politically motivated charges are subjected to torture and abysmal prison conditions. HRW says Uzbekistan has unlawfully imprisoned thousands of people for the peaceful exercise of their freedom of expression. HRW spoke with more than 150 people, including 10 recently released prisoners.


News Archive
Situation Dire for NGOs in Uzbekistan
(August 2013)

Free political prisoners on Constitution Day (December 2012)

EU representative visits Uzbekistan (December 2012)

CIVICUS intervention in the UPR for Uzbekistan (October 2012)

Uzbekistan "not free" according to internet freedom report  (October 2012)

Uzbek rights activist Muhitdinov dies (August 2012)

Watchdog urges EU action over human rights (June 2012)

Uzbekistan: allow independent experts access to prevent persecution, say CIVICUS and Expert Working Group (June 2012)

Activist free but crackdown widening (April 2012)

Uzbekistan touts own civil society model in round table meeting in Tashkent (March 2012)

HRW report highlights concerns that the plight of civil society activists in Uzbekistan is worsening(January 2012)

Release of Mr. Norboy Kholjigitov, ongoing arbitrary detention of eight other HRSU members (October 2011)

AIDS activist released, but other human rights defenders harassed (September 2011) 

Internet censorship in Uzbekistan (August 2011) 

Employee of British Embassy in Tashkent loses appeal against fine (August 2011)

British Embassy staffer fined by court for contact with activists (July 2011)

Tashkent journalist lost her job because of the trip abroad (July 2011)

Uzbekistan Supreme Court approves closure of Human Rights Watch office (June 2011) 

Activists harassed after TV broadcast (April 2011) 

Uzbekistan can't muzzle the messenger (April 2011) 

Links between journalists and foreign embassies placed under control (March 2011) 

Government shuts down Human Rights Watch office (March 2011)

Uzbek human rights group facing criminal libel suit (March 2011) 

No journalist is immune from slander, defamation charges (February 2011) 

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The foregoing information was collected by the ICNL NGO Law Monitor partner in Uzbekistan, Mr. Gayrat Usmanov.