In Uzbekistan, personal administrative liability may be established for officials who unjustifiably impose financial fines on business entities. The initiative, presented in the form of a draft law by the Business Ombudsman, has been submitted for public discussion and envisages significant fines for officials in cases where fines are found to be illegal by the court.
These measures are being taken in response to the increase in court cases against supervisory authorities initiated by entrepreneurs. According to data provided by the Business Ombudsman’s office, out of 6,370 complaints reviewed by courts in 2024, 5,280 (or more than 82%) were resolved in favor of entrepreneurs.
This led to the cancellation of illegal fines and the return of nearly 1.4 trillion soums. This trend continued in 2025 as well.
In the first six months of the year, 4,738 similar appeals were registered in courts. Of these, 3,755 were decided in favor of entrepreneurs, resulting in the cancellation of more than 3.1 trillion soums in fines.
Documents attached to the draft law note that the application of unjustified financial sanctions remains at a high level. The authors of the initiative emphasize that a main problem in the current legislation is the lack of direct administrative liability for such illegal actions by officials.
“The absence of liability leads representatives of supervisory, law enforcement, and other state bodies to unjustifiably impose financial sanctions on entrepreneurs and to evade personal responsibility,” states the commentary attached to the draft law. To eliminate this legal gap, it is proposed to introduce a new Article 241-11 – “Unjustified fines imposed on business entities” – into the Administrative Liability Code.
According to the proposed regulation, if a financial fine imposed on an entrepreneur by an official is found by the court to be illegal, that official personally will be fined. The amount of the fine for a civil servant is set at between 20 and 40 basic calculation units, which is equivalent to 8.24 million to 16.48 million soums.
This draft law aims to strengthen the legal protection of businesses and increase the personal liability of officials for the decisions they make. Furthermore, starting from July 1, 2025, the “first opportunity” principle will be implemented in Uzbekistan.
This principle envisages exempting small business entities from liability for the first time they violate administrative rules in the field of trade and entrepreneurship during their initial year of operation. This is considered to be one of the measures to create a favorable environment for business.
