- within Transport, Immigration, Government and Public Sector topic(s)
November 2025 – Starting from 1 January 2025, any Uzbek resident (or a group), public or private, deemed as systemically important and with an outstanding debt that exceeds USD 50 million, potentially falls under the new CoM Regulation No. 670 "[O]n further improvement of the system of attracting bank loans and foreign debts by large enterprises of systemic importance for the economy of Uzbekistan" ("Regulation 670").
- Whether an entity is deemed systemically important to the national economy is decided by the by the Coordination Commission on Risk Management for Systemically Important Enterprises (the "Coordination Commission") on an annual basis;
- If an entity falls under Regulation 670, it must get the Commission's clearance on all future financings. The Commission will closely monitor this via the servicing banks;
- Such entities will also need to become a joint-stock company (if they are currently organised as limited liability companies).
Effective 1 January 2026, large enterprises, both state and privately owned, may be subject to stricter rules for external debt financing, covering both loan facilities and debt capital market instruments. The criteria of what enterprises shall be qualified as systemically important to the national economy will be determined by the newly established Coordination Commission together with the Central Bank of Uzbekistan and the Ministry of Economy and Finance ("Working Bodies for the Coordination Commission"). The Coordination Commission will include nine representatives from various state bodies, including the Ministry of Finance, the Central Bank, the Tax Committee, and the State Assets Management Agency.
To be qualified as large obligors, enterprises must meet two major criteria:
1. be qualified as entities systemically important to the national economy, and
2. hold directly or indirectly (including through a group of related companies with a 20% control threshold) financial obligations equivalent to USD 50 million or more. The term "financial obligations" extends to various instruments, including bank loans, leasing, bank guarantees, factoring, borrowing attracted from foreign financial institutions, and bonds and other financial liabilities.
The new regime introduces for large obligors:
- a clearance requirement for attracting new financing; and
- ongoing monitoring obligations, including the submission of quarterly reports and disclosure of information on the use of borrowed funds.
From 1 January 2026, any entity qualifying as a large obligor must operate as a joint-stock company. Accordingly, large obligors currently organised as limited liability companies must be converted into joint-stock companies by the second quarter of 2026.
The list of large obligors will be maintained by the Coordination Commission and updated annually.
All large obligors will be classified as low-risk, medium-risk, or high-risk based on their financial statements and other statistical and financial data submitted to the various state authorities.
Depending on the risk level, large obligors may attract financing either with the prior authorisation of the Coordination Commission or by simple notification.
Click on the image below or use the following link to download our article
in Russian.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
