New Uzbekistan Law Introduces VAT for Foreign E-commerce Platforms
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New Uzbekistan Law Introduces VAT for Foreign E-commerce Platforms

Uzbekistan has adopted new regulations for e-commerce that obligate online platforms to assume responsibility for consumer claims in certain cases, require sellers and service providers on platforms to use separate bank accounts, and introduce Value Added Tax (VAT) for foreign companies selling goods to Uzbek consumers.

This law, signed by President Shavkat Mirziyoyev on September 10, 2026, will come into force on December 12, 2026. It stipulates that if a consumer receives defective goods, the primary responsibility lies with the seller. However, the platform will bear additional liability if the seller fails to meet the buyer's legitimate demands, such as in cases of disappearance, business closure, or cessation of response.

The changes also mandate that sellers, couriers, and taxi drivers operating through digital platforms conduct e-commerce transactions through separate bank accounts. Foreign companies selling physical goods to residents of Uzbekistan via online platforms are also subject to VAT, falling under a tax regime similar to that of local sellers.

The document is officially titled 'On Amendments and Additions to Certain Legislative Acts of the Republic of Uzbekistan Aimed at Improving the E-commerce Sector.' The Oliy Majlis legislative chamber adopted it on February 10, and the Senate approved it on May 18. These amendments affect the Tax Code and the E-commerce Law of 2022.

Kamronbek Mukhamadiev, head of the development and regulation of e-commerce department at the National Agency for Advanced Projects (NAPP), told UzDaily that the market is developing faster than the legislation. He noted that e-commerce, like digital technologies, is a rapidly evolving sector that has always outpaced legislation in any country and will continue to do so.

According to the agency, the volume of the e-commerce market in Uzbekistan in 2024 was about 1.2 billion US dollars. The President set a goal to increase its value to 30 trillion soms by 2030.

Mukhamadiev added that the E-commerce Law of 2022 was designed for a significantly smaller and simpler market. It lacked concepts such as 'order aggregators' or 'digital streaming services,' and cross-border e-commerce was not defined. Now these terms are enshrined in the law.

The revised law distinguishes between three types of e-commerce operators: e-commerce platforms, order aggregators through which consumers book services, and digital streaming services. The previous term 'electronic trading marketplace' has been replaced by the broader concept of 'e-commerce platform.'

The law now defines e-commerce as the conclusion of sales contracts for goods, works, and services during activities using information and communication technologies.

According to Mukhamadiev, the amendments address three main issues: insufficient protection of consumer rights, unequal conditions for domestic and foreign platforms, and operations conducted outside the banking system.

A representative of NAPP explained that previously, liability for defective goods was one of the most ambiguous areas. He noted that consumers usually consider the platform to be the seller, although this is often not the case in current business models. The platform provides sellers, often called vendors or traders, the ability to offer their goods through their information systems, which may include various services from product listing to warehousing and logistics. However, the law did not explicitly state who was responsible.

Article 12 of the E-commerce Law now establishes a sequence of liability. The seller remains primarily responsible for obligations arising from contracts concluded through the platform, disputes related to the delivery of defective goods, works, or services, and for replacing non-food defective products.

If the seller cannot meet the buyer's legitimate demands, the e-commerce operator bears additional responsibility unless otherwise stipulated by contract or legislation. In practice, buyers must first file a claim with the seller, either through the platform's customer service system or directly. Sellers are obliged to display their contact details and the name of their legal entity, individual entrepreneur, or self-employed person on the platform.

Mukhamadiev specified that consumers can approach the platform if the seller denies the claim, does not respond, or cannot refund the money—for example, because the seller has disappeared, closed down, or gone bankrupt. The law does not establish a separate waiting period for a response; instead, it applies the deadlines established by consumer protection legislation and general provisions of the Civil Code.

The NAPP representative explained that if the primary respondent refuses the claim or does not respond within a reasonable time—which may be specified in the platform's contracts and public offers—the claim can be brought against the secondary respondent, i.e., the platform. Platforms compensating consumers for damages retain the right to recover funds from the seller. According to Mukhamadiev, they can file a counterclaim in accordance with civil law and the terms of their contracts with sellers.

Akmal Rakhimov, Deputy General Director of Uzum E-com, described this distinction similarly. He stated that a marketplace is not a store but an infrastructure connecting sellers, buyers, logistics providers, and pickup points. The seller is responsible for the product—its quality, safety, and accurate description. The platform is responsible for ensuring transparency and transaction security: vetting sellers, payment security, data protection, and providing a clear return process. The law formalizes this distinction.

Complaints about online purchases remain relatively limited. According to the Consumer Protection Committee, cited by the NAPP representative, 3,100 complaints related to e-commerce were registered in 2023, compared to approximately 1,200 in the first nine months of 2026. Mukhamadiev noted that these figures naturally seem insignificant against the backdrop of tens of millions of sales on platforms and tens of millions of taxi orders, but as the use of these 21st-century tools grows, the number of complaints may increase, making the clarification of each party's obligations relevant.

Under the amendment to Article 16, sellers are obliged to inform buyers in advance about the procedures and conditions for returning goods and receiving compensation. Furthermore, the list of mandatory information no longer includes the full name and patronymic of the self-employed person.

A new provision in Article 27 concerns platforms operating on an escrow model, where the buyer's payment is held until the transaction is completed. If the seller refuses to refund the money, the platform may return it to the buyer according to the procedure established in its contract with the seller.

Marketplaces and order aggregators must verify the licenses, permits, and notifications of sellers operating in sectors requiring licensing or other permits or notifications. They must also take measures to prevent the sale of prohibited or restricted goods and services.

Many requirements apply to all three categories of e-commerce operators. They must protect users' personal data, comply with information and cybersecurity requirements for payments, handle complaints, and provide information to the authorized state body.

For the first time, the law requires platforms to disclose the algorithms they use for product recommendation and ranking. Buyers must have the ability to leave reviews, and platforms must guarantee that reviews remain unchanged and preserved, except as provided by law. Platforms must also publish their terms of use and terms of public offer.

Another provision of particular importance for sellers requires operators to notify about suspension of activity or changes in service rules at least 30 days in advance, except as otherwise provided by law.

The law also establishes specific rights for each type of operator. A marketplace can sell goods on its own platform. An order aggregator can independently set final prices for services based on supply, demand, and other factors. A streaming service can set content usage rules and moderate them, but must comply with copyright and neighboring rights, control illegal content use, and ensure the quality of digital products.

Mukhamadiev noted that, according to his monitoring, less than half of all purchases and orders on aggregators and trading platforms were paid for in cash. Previously, P2P card transfers were very popular, and sales made in this way could not be accounted for or fiscalized.

New provisions of Article 23 change the rules. E-commerce operators, legal entities, and individual entrepreneurs selling through platforms, as well as self-employed persons selling goods, delivering orders, or transporting passengers in vehicles, must conduct e-commerce transactions through separate bank accounts. Individual entrepreneurs and self-employed persons can also use e-wallets.

NAPP believes that the requirement is not as complicated as it seems. Mukhamadiev explained: 'There is nothing unusual about the term

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