Uzbekistan Sets December Deadline for Foreign Marketplace VAT and New Buyer Protections

Foreign sellers and platforms face new duties from 12 December

Foreign companies selling goods through online platforms to people in Uzbekistan will become liable for value added tax under Law No. ZRU-1173, signed by President Shavkat Mirziyoyev on 10 September 2026. The law takes effect on 12 December and also gives buyers a route to pursue platforms when sellers fail to meet lawful claims over defective goods.

The amendments change both the Tax Code and the 2022 Law on Electronic Commerce. They require separate accounts for platform transactions, introduce duties covering payment security and customer complaints, and bring electronic trading platforms, order aggregators and digital streaming services into a more detailed regulatory framework.

An institutional tax summary confirms two conditions for treating Uzbekistan as the place where goods are supplied: the buyer must reside in Uzbekistan, and the goods must be delivered there. It also confirms that national platforms and intermediaries processing payments for foreign sellers can become tax agents, meaning they must calculate and pay the tax to the authorities.

For shoppers, the most immediate change concerns responsibility when an order goes wrong. Sellers remain the first party responsible for defective goods, while platforms take on subsidiary liability, a backup obligation when the seller fails to satisfy a legitimate claim.

For businesses, the December deadline brings several tasks together: updating contracts and published terms, arranging compliant payment accounts, identifying who handles VAT, and preparing systems for complaints, seller checks and electronic filings.

A market that grew twentyfold

Figures presented during the Senate debate show why lawmakers have focused on online trade. Uzbekistan's e-commerce volume grew twentyfold over the preceding eight years to $1.3 billion. More than 90 platforms were operating, including more than 70 domestic platforms.

The market includes international businesses such as Yandex, Ozon and Wildberries, alongside domestic platforms including Uzum, Sello and Zood Mall. The changes therefore affect an established network of retailers, payment intermediaries and service providers.

International courier deliveries brought $167.5 million worth of goods into Uzbekistan in 2024. About 400,000 individuals placed 3.23 million orders, equivalent to roughly eight orders per person when those two figures are divided.

Within that group, 1,994 people placed more than 100 orders each, with purchases worth nearly $2 million in total. Those frequent purchasers represented about 0.5% of the 400,000 individuals recorded, illustrating the range of buying activity that tax authorities must administer.

Senator Erkin Gadoyev, chairman of the Senate committee on budget and economic affairs, said the legislation aimed to prevent tax revenue losses from commerce across borders, improve VAT administration and give domestic and foreign sellers equal conditions for competition.

Wildberries already had an Uzbek company, WB INT EXPORT, which paid 51.2 billion soums in taxes during 2022–2024. VAT accounted for 42.8 billion soums, or about 84% of that total. The new rules extend explicit responsibilities across foreign selling arrangements, including businesses that deal directly with Uzbek buyers.

Who must collect and pay VAT?

Foreign companies selling physical goods through electronic platforms will be VAT taxpayers when the residence and delivery conditions place the sale in Uzbekistan. VAT is a tax on consumption that businesses calculate and remit through the tax system.

An Uzbek platform that settles payments for a foreign seller will act as a tax agent. Where other intermediaries participate, the intermediary settling with the buyer generally takes that role. This puts the collection duty with the business handling the customer payment.

Foreign companies can also operate through local residents, representative offices or dealership agreements. Local partners acting as sales or tax agents will carry the obligations and responsibilities assigned to them by tax law.

Electronic services are covered too. Uzbek legal entities purchasing such services from foreign companies generally act as tax agents. Foreign providers of electronic services to individuals already fall within the Tax Code's VAT rules when Uzbekistan is recognised as the place of supply.

For goods sold through platforms, the tax base is the actual sales price, including VAT. A price that includes VAT already contains the tax component, which must be accounted for within that amount. Foreign companies making direct sales are responsible for registration and electronic reporting rather than relying on an Uzbek platform to remit the tax.

Thirty days for registration and official notices

Foreign businesses selling directly to individuals must submit VAT registration applications electronically within 30 calendar days of starting the relevant activities. Intermediaries acting as tax agents must also register where required.

Applications for deregistration must be submitted electronically within 30 calendar days of ending the relevant activities. Tax returns and other official filings must likewise be electronic, making registration, reporting and withdrawal from the tax register part of a digital process.

Tax authority documents sent to foreign companies will be deemed officially received 30 days after they are sent. Businesses therefore need a reliable way to monitor communications from Uzbekistan's tax authorities, alongside their sales and payment records.

The legislation does not introduce new fines. Undeclared revenue can still lead to tax assessments and penalties under existing rules. Separating sales receipts from other money movements will be important for explaining turnover and meeting those existing obligations.

Buyers must approach the seller first

A shopper with defective goods should first submit a claim to the seller. Sellers must disclose their return and refund terms, giving customers information they can use when deciding what to buy and when seeking a remedy.

If the seller refuses the claim, fails to respond or cannot provide a refund, the buyer may turn to the platform. Subsidiary liability gives the customer another party to pursue after the seller has failed to meet the lawful claim.

A platform that satisfies the buyer's claim can later seek reimbursement from the seller. The financial responsibility can therefore move from the platform back to the business that supplied the goods, while the buyer gains an additional route to resolution.

Platforms using escrow can return payments under their agreements with sellers. Escrow means money is held until agreed conditions are met, rather than being released immediately to the seller. The platform's agreement governs how those held funds can be returned.

Senator Malika Qodirxonova told the Senate that gaps had existed in resolving disputes between online businesses and consumers. The new complaint duties and backup liability address that practical problem: a buyer needs a workable route to a refund when the first business responsible does not deliver one.

Platforms must check sellers and explain their rules

Marketplaces and order aggregators must verify relevant licences and permits and take measures to prevent prohibited or restricted goods and services from being offered. An order aggregator brings together customer requests and service providers, extending these duties beyond conventional online shops.

Operators must protect personal data, satisfy payment security and cybersecurity requirements, and handle complaints. They must also check the reliability of information supplied through their services.

Recommendation and ranking algorithms must be disclosed. These are the automated systems that decide which products or services a customer is shown and in what order. Their role matters because placement can influence both shoppers' choices and sellers' access to customers.

Platforms must preserve customer reviews and allow customers to publish unedited reviews. Published terms must explain the conditions under which the service operates, while operators must generally give sellers at least 30 days' notice before changing service rules or suspending operations.

Digital streaming operators have duties concerning copyright and unauthorised distribution of content. The law expressly recognises streaming services and their operators, bringing businesses distributing online content into the framework alongside marketplaces and aggregators.

Separate accounts and a developing data system

E-commerce operators, businesses selling through platforms and certain self-employed sellers and service providers must use separate bank accounts for their transactions. The requirements also cover couriers and taxi drivers working through digital platforms. Individual entrepreneurs and self-employed people may use electronic wallets as permitted.

Separate accounts make it easier to identify payments connected with platform work. They also address transactions conducted outside the banking system, one of the concerns behind the amendments.

Yigitali Narziyev, adviser to the chairman of the Tax Committee, told senators on 18 May that the committee had developed a procedure for transmitting turnover and transaction information without identifying individuals. He said it was undergoing coordination at the Cabinet of Ministers under instructions in presidential decree PF-246.

Narziyev explained why the tax authority wanted the information. In an English translation of his remarks, he said:

Because if we do not have information about turnover and transactions, we cannot determine the object of taxation and the tax base, and taxes will not be calculated correctly.

A separate draft Cabinet decision covered obtaining information from banks and other financial institutions about transfers to foreign companies, registering those businesses for tax, and restricting their internet activities if they failed to meet tax obligations.

An earlier enforcement plan envisaged restrictions from 1 January 2026 for foreign online companies operating without tax registration, with 30 days allowed for registration. The final adoption and implementation status of those proposed data exchange and restriction procedures was not specified when the law was described.

The Tax Committee had also requested information without personal identifiers about payments to 83 foreign electronic service companies during 2023–2025, to check VAT calculations and payments. According to the committee, 23 foreign electronic service companies registered as VAT taxpayers in 2025, followed by another six in 2026.

Digital products and physical deliveries follow different routes

The law defines e-commerce across borders and assigns the Cabinet of Ministers responsibility for its procedures. The rules apply to transactions involving participants or operators in different jurisdictions.

Digital products imported or exported through online distribution will be exempt from customs declaration. Goods supplied on physical media follow customs procedures. The delivery method therefore matters: a product transmitted online is handled differently from a physical item crossing the border.

For digital exports through platforms, proceeds will be credited to the exporter's account after platform commissions are deducted. This recognises that the amount reaching the exporter may be lower than the customer's payment because the platform retains its fee.

The customs provisions sit alongside the VAT and reporting duties. Businesses dealing in both physical goods and digital products will need to organise their operations around the rules for each form of delivery.

The timetable and the December preparations

The legislation moved from Senate approval to presidential signature over several months. Its main dates are:

• 18 May 2026: The Oliy Majlis Senate approved the amendments and sent the law to the president.
• 10 September 2026: President Shavkat Mirziyoyev signed Law No. ZRU-1173, which was also published that day.
• 12 December 2026: The law takes effect.

Uzum, Wildberries and Ozon broadly welcomed the amendments, citing clearer rules and more equal treatment of domestic and foreign businesses. Sellers and operators have until the December start date to update their operations, contracts and public offers.

The National Agency for Perspective Projects will act as the unified e-commerce regulator. The Consumer Protection Committee will oversee buyers' rights, while tax authorities will administer the VAT and registration obligations.

Businesses need to identify which party receives customer payments, because that determines who generally acts as the tax agent. They also need to review seller permits, refund arrangements, complaint handling, privacy safeguards and the notice periods in their platform agreements.

Consumers will gain a clearer sequence for pursuing defective goods claims. Sellers remain responsible first; platforms become the backup when legitimate claims go unmet. Together with the payment and tax rules, that changes how responsibility is assigned across an online purchase from checkout to refund.

Key Points

• Law No. ZRU-1173 takes effect on 12 December 2026.
• Foreign platform sellers become liable for VAT when buyers reside in Uzbekistan and goods are delivered there.
• Uzbek platforms and payment intermediaries generally remit VAT as tax agents for foreign sellers.
• Foreign businesses making direct sales must apply electronically for registration within 30 calendar days of starting the relevant activities.
• Buyers must first approach sellers over defective goods, with platforms carrying backup liability for unmet lawful claims.
• Platform transactions must use separate accounts, with electronic wallets permitted for certain entrepreneurs and self-employed people.
• Operators face duties covering licences, security, complaints, reviews and disclosure of ranking systems.
• Digitally distributed products are exempt from customs declaration, while physical deliveries follow customs procedures.