Alert: Action required — legal due diligence on local targets in Uzbekistan under the Law on Competition (LRU-850, 2023) Effective: 2023 (ongoing compliance obligation)
Uzbekistan's Law on Competition (LRU-850, 2023) materially reshapes the legal due diligence scope for foreign investors acquiring or partnering with local Uzbek companies. The law replaced its 2012 predecessor and expanded both the substantive obligations and the supervisory powers of the Antimonopoly Committee of Uzbekistan in ways that are not yet universally reflected in standard due diligence frameworks used by cross-border acquirers.
Foreign buyers and joint-venture partners undertaking legal due diligence on local targets in Uzbekistan must now assess whether the target holds, or is presumed to hold, a dominant position under the updated criteria introduced by LRU-850. The law broadened the basis on which dominance may be established, introduced revised pre-transaction notification requirements for combinations that meet defined market-share thresholds, and expanded the range of conduct that the Antimonopoly Committee may treat as an abuse — including conduct by entities in vertically related markets. Counsel advising on Uzbekistan regulation and foreign company transactions should confirm whether competition clearance is required before closing, not after. Under LRU-850, proceeding without a required notification may expose the acquirer to post-closing unwinding risk, a consequence that standard representations and warranties provisions in share purchase agreements governed by foreign law do not adequately address.
For foreign companies with cross-border Uzbekistan–Russia supply chains or existing CIS market presence, the interaction between Uzbekistan competition law and regional regulatory frameworks adds a further layer of analysis. The Antimonopoly Committee has demonstrated increasing activity since the law came into force, and administrative practice under LRU-850 is still developing — meaning that legal advice on Uzbekistan-specific competition risk should draw on current regulatory intelligence, not solely on the statutory text.
Recommended actions:
- Review your due diligence scope to include an explicit LRU-850 competition analysis for any Uzbek target in a concentrated or regulated market sector.
- Confirm with Uzbekistan counsel whether pre-transaction notification thresholds are met before executing any binding commitment.
- If a cross-border Uzbekistan–Russia element is present, obtain coordinated advice covering both jurisdictions.
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This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.
— Nodira Yusupova Contributing Regional Analyst — Uzbekistan, Vetrov & Partners vetrovpartners.com/contributions/