Uzbekistan's Law on Special Economic Zones (2020) has since its adoption served as the primary framework governing foreign investment in the country's designated zones — including the growing cluster of energy-sector projects across the Fergana Valley, Tashkent Region, and the emerging Navoi industrial corridor. The amendments that came into force in early 2027 represent the most substantive revision to that framework since its original passage: they recalibrate how foreign companies access land within free economic zones, how connection to the national electricity grid is administered, and what licensing obligations apply specifically to energy-generation and energy-distribution activities. For in-house counsel at foreign companies with existing or prospective Uzbekistan energy-sector interests, and for foreign law firms coordinating cross-border instructions into the CIS region, these changes require careful review before investment decisions are committed.
The 2027 amendments to the Law on Special Economic Zones introduced three principal changes that affect energy-sector investors directly.
First, the land-use regime inside free economic zones was revised. Previously, foreign investors in SEZs could obtain long-term land-use rights through a simplified administrative procedure administered by the relevant SEZ management company, with central government participation limited to final approval. Under the revised framework, energy-sector projects above a defined capacity threshold — encompassing both generation (renewable and conventional) and distribution infrastructure — are now subject to a mandatory preliminary assessment by the national energy regulator before the SEZ management company may issue a land-use allocation. This additional step introduces a sequencing requirement that was absent from the original 2020 text and materially affects project timelines.
Second, the grid-connection rules were restructured. The 2020 law contained general provisions on infrastructure access within SEZs, but those provisions did not differentiate between electricity infrastructure and other utility services. The 2027 amendments introduce a dedicated chapter addressing energy infrastructure access, imposing standardised technical connection protocols and establishing a defined maximum period within which the national grid operator must respond to a foreign investor's connection application. This is a notable departure from prior practice, under which connection timelines were largely informal and varied significantly by zone and by project type.
Third, the licensing regime for energy activities within SEZs was clarified. Before the amendments, there was interpretive uncertainty about whether the general SEZ operating licence was sufficient to cover energy generation or distribution activities, or whether a sector-specific licence from the energy regulatory authority was additionally required. The 2027 amendments resolve this ambiguity: energy generation and distribution within an SEZ now requires both an SEZ operating permit and a separate sector-specific licence. Investors who had structured their entry on the assumption that a single SEZ permit would suffice should review their current authorisation position.
"The 2027 amendments bring welcome procedural clarity to the SEZ energy regime, but they also add compliance layers that foreign investors and their counsel should map carefully before execution — particularly on the sequencing between land allocation and regulatory approval." — Nodira Yusupova, Contributing Regional Analyst — Uzbekistan, Vetrov & Partners
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The practical impact of the 2027 amendments varies depending on the investor's current status and the nature of their Uzbekistan energy-sector involvement.
Foreign companies at the project-development stage face the most immediate exposure. The new sequencing requirement — regulatory pre-assessment before land allocation — means that a project timeline modelled on the prior 2020 framework will underestimate the pre-construction phase. In practice, the preliminary regulatory assessment may extend the period between initial application and land allocation by several months, depending on project scale and the current capacity of the national energy regulator. Investors who have signed heads of agreement or memoranda of understanding with Uzbekistan counterparties on the basis of pre-amendment timelines should revisit those instruments.
Foreign companies already operating within an SEZ in energy-related activities face a different concern: the dual-licence requirement. If the 2027 amendments require a sector-specific energy licence in addition to the existing SEZ operating permit, operators who have not yet obtained that licence are now technically operating outside the updated framework. The amendments include a transitional provision for existing operators, with a defined grace period during which they may regularise their position, but the duration and conditions of that grace period require verification against the implementing regulations.
Foreign law firms coordinating regional instructions — particularly those advising clients on CIS-region energy exposure spanning Russia, Kazakhstan, and Uzbekistan — should note that Uzbekistan is not a member of the EAEU. The regulatory frameworks for energy and investment in Uzbekistan are distinct from those applicable in EAEU member states and do not benefit from EAEU mutual recognition or harmonisation instruments. Cross-border matters involving Uzbekistan energy assets therefore require jurisdiction-specific analysis rather than extrapolation from Russian or Kazakh regulatory experience. Vetrov & Partners coordinates cross-border matters in this corridor through its network of regional contributing analysts, including counsel qualified in Uzbekistan law.
Foreign creditors and project-finance lenders with security over Uzbekistan SEZ energy assets should note that the land-use and licensing changes may affect the validity or enforceability of existing security arrangements. Where a lender's security is premised on the borrower holding valid land-use rights and the appropriate operating licences, the effect of the 2027 amendments on the borrower's compliance position is a matter requiring legal verification.
The practical response to the 2027 amendments depends on the investor's stage of engagement, but three actions are relevant across most scenarios.
The first priority is a compliance gap analysis. Foreign companies with existing Uzbekistan SEZ energy operations should map their current authorisation position against the dual-licence requirement and the transitional provisions. This means confirming whether a sector-specific energy licence is required for their specific activity type, whether they fall within the scope of the transitional grace period, and what documentation is required to regularise their position if they do not already hold the requisite licence.
The second priority is timeline recalibration for projects in development. Investors at the structuring or heads-of-agreement stage should revise their project programmes to incorporate the new regulatory pre-assessment phase before land allocation. Engaging with the national energy regulator early — before formal SEZ application — is likely to reduce uncertainty about the scope and duration of that assessment.
The third priority is a review of transaction documents and security instruments. For projects where investment or lending documentation references specific regulatory licences or land-use rights as conditions or representations, counsel should verify whether those references remain accurate under the amended framework.
For in-house counsel managing Uzbekistan exposure alongside positions in Russia and other CIS markets, it is worth noting that the cross-border coordination model applicable to this corridor — in which a Russian-qualified lead firm coordinates with jurisdiction-specific regional analysts — is the structure through which Vetrov & Partners operates. Uzbekistan-specific regulatory questions are handled by contributing analysts qualified in Uzbekistan law, with cross-border coordination provided from the firm's Novosibirsk office.
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Q: What specifically changed for energy-sector investors under the 2027 amendments to the Uzbekistan Law on Special Economic Zones?
A: The 2027 amendments introduced three principal changes. Energy-sector projects above a defined capacity threshold must now obtain a preliminary regulatory assessment from the national energy regulator before a land-use allocation can be issued within an SEZ — a requirement that was not present in the 2020 text. Grid-connection procedures were formalised with standardised technical protocols and a defined response period for the national grid operator. And the licensing position was clarified: energy generation and distribution activities within an SEZ now require both an SEZ operating permit and a separate sector-specific licence from the energy regulatory authority. Each change affects the timeline and documentation requirements for market entry in the Uzbekistan energy sector.
Q: Which types of foreign investor are most directly affected by these changes?
A: Three categories of investor face immediate practical consequences. Companies at the project-development stage are affected by the new sequencing requirement, which extends the pre-construction phase compared to the prior framework. Companies already operating in an SEZ under an energy-related activity need to verify their licensing position against the dual-licence requirement and, if they are not yet compliant, confirm whether they fall within the transitional grace period. Foreign creditors and project-finance lenders with security over Uzbekistan SEZ energy assets should also review whether the amendments affect the validity of the underlying authorisations on which their security depends. Foreign law firms coordinating regional instructions across CIS jurisdictions should note that Uzbekistan is not an EAEU member and its regulatory framework requires independent jurisdiction-specific analysis.
Q: What should a foreign company do now if it has energy-sector operations or investments in a Uzbekistan SEZ?
A: Three steps are advisable. First, carry out a compliance gap analysis: map current operating licences and land-use rights against the dual-licence requirement, and confirm whether any transitional provisions apply. Second, for projects in development, revise project timelines to incorporate the new regulatory pre-assessment phase before land allocation. Third, review transaction documents and security instruments to verify that references to specific licences or land-use rights remain accurate under the amended framework. Engaging Uzbekistan-qualified counsel early — before formal SEZ applications are submitted — is the most effective way to manage the additional procedural requirements that the 2027 amendments introduce.
Vetrov & Partners is a Russian boutique law firm established in 2009 and recognised by Pravo-300 for eight consecutive years. The firm's Regulatory & Licensing practice advises foreign companies on market entry, licensing, and regulatory compliance across the CIS corridor — including cross-border matters involving Uzbekistan, Kazakhstan, Georgia, and Armenia — coordinated through the firm's Novosibirsk office. Substantive advice on Uzbekistan law is provided by contributing regional analysts qualified in that jurisdiction.
We are a Russian-qualified law firm. For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction.
Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom
This publication is provided for informational purposes only and does not constitute legal advice under Russian 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 foreign law or requiring local admission in another jurisdiction, 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/