Client alert: change affecting real estate acquisition and land rights in Uzbekistan under the Law on Subsoil

Alert: Change affecting real estate acquisition and land rights in Uzbekistan under the Law on Subsoil Effective: January 2027

Uzbekistan's Law on Subsoil has been amended in a way that directly affects the land tenure and surface-use rights available to foreign investors acquiring or leasing real estate over subsoil-designated areas. Under the amended framework, sites classified as overlying subsoil use zones are subject to additional regulatory clearance requirements before title or long-term lease rights can be confirmed in favour of a foreign-owned entity.

Foreign companies holding, acquiring, or structuring tenure over land in Uzbekistan – including those operating through local subsidiaries, joint ventures, or project companies – should assess whether any of their sites fall within a subsoil-designated zone. Where they do, existing contractual rights and pending acquisitions may require re-examination against the new clearance conditions. The change is relevant both to greenfield entries and to portfolio reviews by investors already active in the Uzbekistan market.

Recommended steps:

• Map your existing and pipeline real estate interests in Uzbekistan against the current subsoil zoning register to identify any overlap.
• Review acquisition documentation, lease agreements, and corporate structure for sites that may be affected, with particular attention to conditions precedent and representations relating to regulatory approvals.
• Obtain updated local legal advice on whether any pending transaction requires re-structuring or supplemental regulatory filings before completion.

[CTA: Speak to our team — info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76]

For broader context on doing business and structuring investments in Uzbekistan, see our Uzbekistan practice overview: /jurisdictions/uzbekistan/

This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. For matters governed by Uzbekistan law or requiring local admission, we collaborate with trusted counsel in Uzbekistan. Contact info@vetrovpartners.com for advice on your specific situation.

— Nodira Yusupova Contributing Regional Analyst – Uzbekistan, Vetrov & Partners vetrovpartners.com/contributions/