Work permits and expatriate migration in Uzbekistan under the Law on Subsoil — practitioner checklist

Foreign companies that hold or operate under a subsoil use right in Uzbekistan face a compliance layer that goes beyond standard employment formalities. The Law on Subsoil imposes specific obligations on licence holders and their contractors with respect to foreign specialists — including quota requirements, mandatory localisation ratios, and sequential permit approvals that must be completed before an expatriate can lawfully begin work. For in-house counsel and HR teams managing inbound assignments to Uzbekistani subsoil projects, a missed step at any stage can halt the deployment of key personnel and expose the employer to administrative penalties under Uzbekistani employment and migration legislation.

This checklist sets out the six sequential compliance steps that apply to work permits and expatriate migration for foreign specialists engaged under the Law on Subsoil framework. Each item identifies the relevant regulatory requirement, the responsible body, and the practical risk if the step is not completed on time.

Every subsoil use right in Uzbekistan is issued subject to conditions that include, among other matters, limits on the proportion of foreign nationals that the right-holder or its contractors may employ. The applicable quota is typically set out in the subsoil use agreement itself or in a supplementary regulatory document issued by the competent subsoil authority at the time of licence grant. Before initiating any expatriate deployment to a subsoil project, the right-holder must identify the precise quota figure, the scope of roles to which it applies, and whether the quota covers direct employees only or extends to contractor and subcontractor personnel.

In practice, quota conditions vary significantly between agreements negotiated at different periods. Companies that have acquired a subsoil use right through an assignment or corporate restructuring should obtain the original licence documents and verify whether any quota amendments were agreed as a condition of transfer approval.

Note: Deploying a foreign specialist in excess of the approved quota constitutes a violation of both the subsoil use conditions and the general rules on foreign labour in Uzbekistan. The regulatory consequence includes a fine calculated per unlawfully employed worker, potential suspension of the right to employ foreign nationals under the relevant permit, and — in repeated cases — grounds for the competent authority to review the subsoil use agreement. Quota compliance should be verified before any offer letter is issued to a foreign candidate.

Under Uzbekistani law, an employer must hold a current accreditation (or equivalent registration status, depending on the entity form) issued by the Ministry of Employment and Labour Relations before it may apply for individual work permits for foreign nationals. For subsoil sector employers, this accreditation is issued with reference to the project scope and the approved quota. The accreditation is not a one-time formality: it requires periodic renewal and must be updated when the employer's corporate details, permitted activities, or quota entitlements change.

Foreign subsidiaries, branches, and representative offices engaged on subsoil projects should confirm that their Uzbekistani legal entity holds current accreditation status. Where operations are carried out through a contractor rather than directly by the licence holder, the contractor entity must hold its own separate accreditation — the right-holder's accreditation does not extend to its service contractors.

Note: An application for an individual work permit submitted by an employer without valid accreditation will be rejected without substantive review. Obtaining accreditation from scratch typically requires several weeks of processing. A gap in accreditation status can block the entire deployment pipeline for a project mid-execution, a risk that is acute where the subsoil right contains a commencement-of-operations timetable.

[CTA: If you are assessing the accreditation status of a Uzbekistani entity ahead of a new expatriate deployment — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76]

An individual work permit must be obtained for each foreign national who will perform work in Uzbekistan, including specialists deployed to subsoil projects. The application is submitted by the accredited employer to the Ministry of Employment and Labour Relations, and the permit is role-specific and tied to the employer: a foreign specialist who changes employer or role category must obtain a new permit. The application requires, at minimum, documentary evidence of the specialist's qualifications, confirmation that the role falls within the approved quota, an employment contract or offer in the approved form, and a health certificate meeting Uzbekistani requirements.

For subsoil project deployments, the application package typically also requires a document from the competent subsoil authority confirming that the relevant quota allocation has been reserved for the specific position. Permit processing times vary but commonly extend to several weeks from the date a complete package is accepted. Employers should build this timeline into project mobilisation schedules and not treat the work permit as a formality to be resolved after the specialist has arrived in the country.

Note: Working in Uzbekistan without a valid work permit — even for a brief initial period pending permit issuance — is a violation of Uzbekistani employment law that can attract administrative fines against both the employer and the foreign national. Immigration authorities conduct inspections at active subsoil project sites. The existence of a submitted but not yet approved application does not provide a lawful basis for the specialist to begin work.

Once the work permit has been issued, the employer must execute a written employment contract that complies with Uzbekistani labour law requirements and register it with the relevant authority. For foreign nationals, the employment contract registration is a precondition for the specialist to obtain a temporary residency permit for longer assignments or to extend their migration registration beyond the short-term period permitted on a standard entry stamp. Both the residency documentation process and the migration registration must be completed within the timeframes set by Uzbekistani migration law, which are calculated from the date of the foreign national's entry into the country.

In practice, companies should appoint a dedicated HR contact within the Uzbekistani entity to manage migration registration deadlines for each specialist individually, since deadlines run from the individual's entry date rather than from a unified project start date. Collective management of these timelines across a multi-person team is a common source of inadvertent violations.

Note: Failure to register a foreign national's place of residence and employment within the statutory period — even where a valid work permit exists — constitutes a separate immigration violation with its own penalty. Residency and migration registration obligations are not automatically discharged by holding a valid work permit. Both tracks must be managed in parallel.

The Law on Subsoil and associated implementing regulations require subsoil right-holders to meet a defined ratio of Uzbekistani citizens in their workforce. This localisation obligation applies at the level of the project entity and is monitored by both the competent subsoil authority and the Ministry of Employment and Labour Relations. The ratio is typically expressed as a minimum percentage of total headcount that must be Uzbekistani nationals, and in some agreements it is set on a project-phase basis, with the required local proportion increasing as the project moves from the exploration phase into development and production.

Employers should maintain a documented localisation compliance record that tracks headcount by nationality across all entities engaged on the project, including contractors and subcontractors where the subsoil agreement extends the obligation beyond the right-holder. Where the localisation ratio is not met, the employer may be required to present a remediation plan to the competent authority as a condition of processing further work permit applications.

Note: The localisation obligation is a quota in the opposite direction — it sets a floor on local hires rather than a ceiling on foreign hires. Non-compliance does not simply prevent the grant of further work permits; it can constitute a condition breach under the subsoil use agreement itself, which carries consequences that extend beyond employment law into the continuity of the subsoil right. Legal counsel should review localisation compliance before any corporate restructuring that changes the workforce composition of a project entity.

[CTA: For in-house counsel reviewing localisation compliance before a workforce restructuring on a Uzbekistani subsoil project — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76]

Work permits are issued for a fixed period and must be renewed before expiry if the specialist is to continue working lawfully. The renewal application follows the same procedural path as the initial application and requires an updated quota confirmation if the employer's quota position has changed. Where a foreign specialist leaves the project before the end of the permit period — whether through resignation, transfer, or termination — the employer has an obligation to notify the Ministry of Employment and Labour Relations of the cessation of employment within the timeframe prescribed by regulation. Failure to notify has consequences not only for the departing specialist's migration registration but also for the employer's quota accounting and its standing with the competent subsoil authority.

For project assignments that involve a rotation of specialists over time, the employer should establish a permit management protocol that tracks expiry dates, initiates renewals at least four to six weeks before expiry, and records departure notifications as a standard HR exit step rather than a discretionary one.

Note: An expired work permit that was not renewed — even where the employer and specialist intended to renew it and simply missed the deadline — places the specialist in an unlawful status immediately upon expiry. There is no grace period under Uzbekistani migration law. Employers managing large expatriate cohorts on subsoil projects should use a compliance calendar that triggers renewal processes automatically, rather than relying on individual managers to track expiry dates.

• [Employing foreign nationals in Uzbekistan: general compliance framework](/insights/uz-gd-001-employing-foreign-nationals-in-uzbekistan/)
• [Company formation and employer registration in Uzbekistan for foreign investors](/insights/uz-gd-002-company-formation-employer-registration-uzbekistan/)
• [Uzbekistan Employment & Migration practice overview](/jurisdictions/uzbekistan/employment-migration/)

Q: Does the Law on Subsoil impose work permit obligations directly, or do those obligations arise under general employment and migration law?

A: Both frameworks apply in parallel. The Law on Subsoil establishes the obligation to observe foreign specialist quotas as a condition of the subsoil use right itself — breach of the quota condition is a matter of subsoil law, with consequences that include review of the licence. The procedural mechanics of obtaining work permits, registering employment contracts, and managing migration documentation are governed by Uzbekistani employment and migration legislation, which applies generally to all foreign nationals working in the country. Subsoil sector employers must comply with both frameworks simultaneously; compliance with one does not discharge obligations under the other.

Q: Can a foreign specialist begin work on a subsoil project while the work permit application is being processed?

A: Under Uzbekistani employment law as generally applicable, a foreign national may not lawfully perform work in the country until the individual work permit has been issued and the employment relationship has been formally registered. The fact that an application has been submitted and is under review does not create a provisional right to work. Employers who deploy specialists ahead of permit issuance — even for preparatory, supervisory, or advisory activities on-site — risk administrative liability. If a project mobilisation timeline is critical, the employer should explore whether the specialist can perform preparatory work remotely, from outside Uzbekistan, during the permit processing period.

Q: Who is responsible for work permit compliance where a foreign specialist is employed by a subcontractor rather than by the subsoil right-holder directly?

A: The work permit obligation attaches to the direct employer — that is, the entity with which the foreign specialist has an employment contract. The subcontractor entity must itself hold valid accreditation and obtain the individual work permit for its own employees. The subsoil right-holder is not a party to those employment arrangements and does not bear the work permit compliance obligation for subcontractor staff. However, the right-holder may be accountable under the subsoil use agreement for ensuring that the overall foreign specialist quota applicable to the project — which typically covers the entire project workforce, including contractors — is not exceeded. Right-holders should include contractual audit rights and compliance warranties in subcontractor agreements to manage this exposure.

Vetrov & Partners is a Russian boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years and listed as a trusted adviser by the German Consulate General in Novosibirsk.

The firm's regional coverage of Central Asia — including Uzbekistan — is delivered through contributing regional analysts with in-country expertise, coordinated from the firm's Novosibirsk base. For foreign companies entering or operating in Uzbekistan under the Law on Subsoil or related investment frameworks, the firm provides practice-area analysis, cross-border coordination, and referral to accredited Uzbekistani counsel where local admission is required. Across more than 1,000 matters handled since inception, the team maintains direct partner involvement on every engagement.

Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

[CTA: To discuss work permit compliance or expatriate migration on a Uzbekistani subsoil project — make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76]

This publication is provided for informational purposes only and does not constitute legal advice under Uzbekistani or any other applicable law. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Vetrov & Partners is a Russian-qualified law firm. For matters governed by Uzbekistani law or requiring local admission in Uzbekistan, we collaborate with trusted counsel in the relevant jurisdiction. For advice regarding your particular situation, please contact info@vetrovpartners.com.

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