Alert: Change affecting the foreign investment regime and sector restrictions in Uzbekistan under the Law on Subsoil Effective: upon entry into force of the relevant amendments — confirm the operative date with counsel
Uzbekistan's Law on Subsoil has been amended to tighten the conditions under which foreign investors may access, hold, and exercise rights in respect of subsoil use licences. Under the revised framework — as understood at the date of this alert — foreign participation in subsoil use activities is subject to enhanced regulatory scrutiny, including conditions that restrict or qualify the categories of foreign entities eligible to hold subsoil licences directly or through locally incorporated vehicles.
Foreign companies with existing subsoil use arrangements in Uzbekistan, or those currently structuring market entry in the extractive, mining, or natural resources sectors, are most directly affected. In-house counsel and senior management should assess whether existing holding structures, joint venture agreements, or licence applications remain compliant with the amended foreign investment regime. The change may also affect companies in adjacent sectors — such as construction, infrastructure, and processing — whose operations depend contractually or operationally on subsoil-linked activity.
Recommended steps:
- Obtain confirmed advice on the specific amendments from local Uzbek counsel with subsoil sector expertise — the precise scope of the restrictions, their entry-into-force date, and any transitional provisions are matters requiring jurisdiction-specific analysis.
- Review current licence holdings, joint venture structures, and proposed acquisition terms against the amended eligibility criteria.
- Where a cross-border structure involves Russian or CIS-incorporated intermediate entities, assess whether any consequential changes to those holding layers are required — Vetrov & Partners can advise on the Russian-law dimension of the structure.
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For matters governed by Uzbek law or requiring local admission in Uzbekistan, we collaborate with trusted counsel in the relevant jurisdiction. Vetrov & Partners advises on the Russian-law and cross-border structuring dimensions of matters with a CIS or Russian nexus. For the Uzbekistan-specific regulatory analysis referenced in this alert, we coordinate directly with qualified Uzbek counsel on your behalf.
For further information on our broader Uzbekistan and Central Asia capability, see Uzbekistan: Market Entry & Company Formation at /jurisdictions/uzbekistan/.
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/