Economy

Uzbekistan’s new e-commerce law introduces VAT for foreign platforms

Uzbekistan’s new e-commerce law introduces VAT for foreign platforms
Uzbekistan’s new e-commerce law introduces VAT for foreign platforms / Photo: Pixabay/StockSnap.

Tashkent, Uzbekistan (UzDaily.uz) — Uzbekistan has adopted new rules for electronic commerce that will make online platforms liable for consumer claims in certain circumstances, require platform-based sellers and service providers to use separate bank accounts, and introduce value-added tax (VAT) for foreign companies selling goods to Uzbek consumers.

The law, signed by President Shavkat Mirziyoyev on 10 September 2026, will take effect on 12 December 2026. It establishes that when a consumer receives defective goods, the seller remains primarily responsible. However, the platform will bear subsidiary liability if the seller cannot meet the buyer’s lawful demands, for example, because it has disappeared, closed its business or stopped responding.

The changes also require sellers, couriers and taxi drivers working through digital platforms to process e-commerce transactions through separate bank accounts.

Foreign companies selling physical goods to Uzbekistan residents through online platforms will also become subject to VAT, bringing them under a tax regime similar to that applied to 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 Legislative Chamber of the Oliy Majlis adopted it on 10 February, and the Senate approved it on 18 May. The amendments affect the Tax Code and the 2022 Law on Electronic Commerce.

The market has outgrown the rules

“The market has grown faster than the rules. E-commerce, like digital technology, is a rapidly developing sector. Today, it is sometimes already called digital commerce. It has always moved ahead of the legislation in any country and will continue to do so,” Kamronbek Muhammadiev, head of the e-commerce development and regulation department at the National Agency for Perspective Projects (NAPP), told UzDaily.

According to the agency, Uzbekistan’s e-commerce market was worth approximately US$1.2 billion in 2024. The president has set a target of increasing its value to 30 trillion soums by 2030.

“The 2022 Law on Electronic Commerce was written for a considerably smaller and simpler market. It did not contain concepts such as ‘order aggregator’ or ‘digital streaming service’, nor did it define cross-border e-commerce. These terms are now established in law,” Muhammadiev said.

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

The law now defines e-commerce as the conclusion of contracts for the sale of goods, works and services in the course of business using information and communication technologies.

According to Muhammadiev, the amendments address three main problems: insufficient consumer protection, unequal conditions for domestic and foreign platforms, and transactions conducted outside the banking system.

Who is responsible for defective goods?

According to the NAPP representative, responsibility for defective goods was previously one of the areas of greatest uncertainty.

“Consumers generally perceive the platform as the seller, although that is often not the case under current business models. A platform enables sellers, commonly called sellers or merchants, to offer their goods through its information systems. This can include various services, from listing products to warehousing and logistics. However, the law did not explicitly specify who was responsible,” he explained.

Article 12 of the Law on Electronic Commerce now establishes a sequence of liability. The seller remains primarily responsible for obligations arising from contracts concluded through the platform, disputes involving the delivery of defective goods, works or services, and the replacement of defective non-food products.

If the seller cannot satisfy the buyer’s lawful claims, the e-commerce operator bears subsidiary liability unless otherwise provided by the contract or legislation.

In practice, buyers should first submit a claim to the seller, either through the platform’s customer service system or directly. Sellers are required to display their contact details and the name of their legal entity, individual entrepreneur or self-employed business on the platform.

“Consumers can turn to the platform when the seller has refused a claim, failed to respond or cannot refund the money—for example, because the seller has disappeared, closed down or gone bankrupt,” Muhammadiev said.

The law does not establish a separate waiting period for a response. Instead, the applicable deadlines are governed by consumer protection legislation and the general provisions of the Civil Code.

“If the primary defendant refuses the claim or fails to respond within a reasonable period—which may also be specified in the platform’s contracts and public offers—the claim can be submitted to the subsidiary defendant, meaning the platform,” the NAPP representative explained.

Platforms that compensate consumers will retain the right to recover the money from the seller. According to Muhammadiev, they can file a recourse claim under civil law and the terms of their contracts with sellers.

Akmal Rakhimov, deputy CEO of Uzum E-com, described the distinction in similar terms.

“A marketplace is not a shop but 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 that the transaction is transparent and protected: verifying sellers, securing payments, safeguarding data and providing a clear returns process. The law formalizes this distinction,” he said.

Online shopping complaints remain relatively limited. According to data from the Consumer Protection Committee cited by the NAPP representative, 3,100 complaints related to e-commerce were registered in 2023, compared with approximately 1,200 in the first nine months of 2026.

“Against tens of millions of sales on platforms and tens of millions of taxi orders, these figures naturally appear negligible. But as more people use these 21st-century tools, the number of complaints may grow. That is why the responsibilities of each party needed to be specified,” Muhammadiev said.

Returns: clear terms and refunds through escrow

Under an amendment to Article 16, sellers must inform buyers in advance about the procedures and conditions for returning goods and obtaining refunds. At the same time, the list of mandatory information will no longer include the full name and patronymic of a self-employed person.

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

What platforms must verify

Marketplaces and order aggregators will be required to check licences, permits and notifications for sellers operating in sectors subject to licensing or other authorization or notification requirements. They must also take measures to prevent the sale of goods and services that are prohibited or restricted from circulation.

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 government body.

For the first time, the law requires platforms to disclose the algorithms they use to recommend and rank products. Buyers must be able to post reviews, and platforms must ensure that reviews remain unchanged and are preserved, except in cases provided for by law. Platforms must also publish their terms of use and public offer conditions.

Another provision of particular importance to sellers requires operators to give at least 30 days’ notice before suspending operations or changing service rules, except in circumstances provided for by law.

The law also establishes specific rights for each type of operator. A marketplace may sell goods on its own platform. An order aggregator may independently set final service prices based on supply, demand and other factors. A streaming service may establish rules for using content and moderate it, but must respect copyright and related rights, monitor illegal use of content and ensure the quality of digital products.

Payments must go through separate accounts

“According to our monitoring, less than half of all purchases and orders on aggregators and trading platforms were paid for in cash. Peer-to-peer card-to-card transfers used to be very popular, and it was impossible to account for or fiscalize sales conducted through such transfers,” Muhammadiev said.

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

The NAPP says the requirement is less complicated than it may sound.

“There is nothing unusual about the term ‘separate bank account’. It is not some special or specific type of account. It is simply a separate account. When opening one at any bank operating in Uzbekistan, the account holder must specify that it is intended for e-commerce. That is all,” Muhammadiev explained.

Separate provisions apply to self-employed people. Their e-commerce income must be recorded in a separate account or electronic wallet linked to a bank card. They may accept payments on behalf of sellers and maintain funds in advance in their account or wallet for deductions by a supplier or operator.

A courier who receives cash for a delivered order may keep the money without depositing it through a cash collection service, up to the amount the courier previously transferred to the supplier electronically.

The law does not introduce new fines. “The law does not amend the Code of Administrative Liability, including provisions concerning transactions through personal bank cards. Violations will be assessed under the existing legislation,” the regulatory representative said.

He added that the issue primarily concerns tax oversight: undeclared revenue can result in additional tax assessments and penalties under the Tax Code.

VAT for foreign platforms

Muhammadiev described the unequal treatment of domestic and foreign platforms as one of the most significant problems.

“A domestic platform, as a local legal entity, pays all applicable taxes in Uzbekistan, including VAT or turnover tax, as well as other taxes. Meanwhile, a foreign platform selling physical goods to Uzbek citizens was largely in a more favourable position and paid no taxes. By analogy with the ‘Google tax’ on electronic services, the law now explicitly establishes a VAT obligation for marketplaces selling goods to Uzbek citizens,” he said.

According to Muhammadiev, the agency had examined cases in which large volumes of goods from foreign platforms entered Uzbekistan under duty-free import provisions.

“When these rules were introduced, it was not anticipated that foreign trading platforms would use such schemes. The same trend is now being observed globally: to create equal conditions for domestic and foreign platforms, countries are introducing import duties, fixed payments or VAT, as Uzbekistan has done,” he said.

Amendments to Chapter 39 of the Tax Code extend to foreign sellers of goods the tax regime already applied to providers of electronic services.

A foreign company selling goods to individuals through electronic platforms will be recognized as a taxpayer if the buyer resides in Uzbekistan and the goods are delivered to the country. The tax base will be the value of the goods at their actual selling prices, including tax.

If a foreign company sells through an Uzbek platform, the platform operator will remit the tax as a tax agent. Where transactions involve intermediaries operating under commission, agency or mandate agreements, the tax agent will be the intermediary that settles directly with the buyer.

Within a chain of intermediaries, this means the party that settles both with the buyer and with the foreign company, even if it has no direct contract with the foreign company. If goods or services are purchased by Uzbek legal entities or permanent establishments of non-residents, the buyers themselves will act as tax agents.

Companies selling directly without intermediaries must register with the tax authorities no later than 30 calendar days after beginning sales. They must submit electronic tax returns through their personal taxpayer accounts. Documents sent by the tax authorities will be deemed received 30 days after dispatch.

The existing mechanism for taxing electronic service providers offers an example of how the system works. According to Muhammadiev, data from the tax.uz website showed that approximately 111 foreign companies had registered as VAT payers by 7 October, including more than 10 since the beginning of the year.

According to the Tax Committee’s report, these companies paid approximately 182 billion soums in taxes in 2025 and 65.7 billion soums in the first quarter of 2026.

“For now, these are only providers of electronic services. After 12 December, the list will also expand to include platforms selling physical goods to the Republic of Uzbekistan,” he said.

Cross-border trade and digital exports

The law defines cross-border e-commerce for the first time. It covers trade in which participants or operators are located in different countries, with at least one of them in Uzbekistan.

The Cabinet of Ministers must approve procedures for such trade within three months of the law’s publication.

“The procedures have not yet been published, so it would be premature to identify specific simplifications,” Muhammadiev said.

A separate provision concerns digital products. Goods supplied on physical media will continue to undergo customs clearance, while digital products distributed online will not.

If a developer sells an application or another digital product through a foreign platform, foreign-currency revenue will be transferred to the developer’s account after the platform’s commission is deducted, within the time limits established by the platform’s rules.

What the market says

The largest marketplaces operating in Uzbekistan have generally welcomed the amendments, although they emphasize different aspects.

For Uzum, tax equality is the main issue.

“Over eight years, Uzbekistan’s e-commerce market has grown 20-fold to US$1.3 billion. A market of this scale cannot operate under rules written for its early stages. Foreign marketplaces will have to pay VAT on goods sold in Uzbekistan. Until now, local platforms and sellers have operated under the full tax burden, while part of cross-border trade has not. Uniform rules for everyone selling to Uzbek consumers support local businesses without protectionism,” said Akmal Rakhimov, deputy CEO of Uzum E-com.

He expects the implementing regulations to play a significant role.

“We expect these regulations to be developed in dialogue with the industry, so that the requirements reflect the actual operating models of marketplaces and do not create excessive burdens for small sellers, for whom online platforms are often their main route to market,” he said.

Wildberries highlighted the clearer definitions of market participants, their legal status, rights, obligations and areas of responsibility.

“We view the legislative update as a natural step accompanying the development of e-commerce. Requirements for foreign digital platforms and legal entities are particularly important. This helps establish more transparent and uniform operating rules for all market participants,” the company’s press service said.

According to Wildberries, the changes should provide sellers and buyers with clearer operating conditions and more transparent relationships.

Ozon said the law largely reflects the company’s existing operating model.

“Ozon operates through a legal entity registered in Uzbekistan and is already included in the register of e-commerce operators. We settle accounts with local sellers and partners in the national currency, prepare documents in accordance with local legislation and comply with consumer protection requirements. Therefore, the new regulatory framework largely formalizes Ozon’s established operating model,” the company’s press service said.

Company representatives added that clear and transparent rules help the market develop more sustainably.

Three months to prepare

Sellers and platforms have until 12 December to adjust their operations.

“Consider this the time sellers and platforms have to update their public offers, contracts and all relevant terms before 12 December,” Muhammadiev said.

Each government agency will monitor compliance within its area of responsibility. NAPP will act as the unified regulator of e-commerce, while the Consumer Protection Committee will oversee matters relating to buyers’ rights.

Under the law, NAPP must also explain the new rules to the public. The Cabinet of Ministers must bring government resolutions into line with the law and repeal departmental acts that contradict it.

Anvar Umarov
Anvar Umarov

Anvar Umarov is the founder and editor-in-chief of UzDaily, a leading business and news publication covering Uzbekistan and Central Asia. With over 20 years of experience in journalism, he has also worked as a PR manager for both state and private organizations, bringing a broad perspective on media, communications, and public affairs to his editorial leadership.