Uzbekistan at a Glance
Uzbekistan runs a codified four-licence crypto regime with a 0% tax window on crypto operations until 1 January 2028, supervised by the National Agency of Perspective Projects (NAPP) under Presidential Resolution PP-3832 of 3 July 2018. It serves a domestic market closed to foreign exchanges, which makes it a regional Central Asia play rather than a route into the EU.
The charter-capital bank reservation required at the date of filing—3,000 BCV held in a separate Uzbek commercial-bank account for crypto-exchange applicants—often proves the decisive constraint, and must be in place before submitting the dossier, not after. Missing this detail surfaces costly delays once capital is committed and the licensing clock has started.
A Codified Perimeter Since 2018
Uzbekistan placed crypto-asset activities inside a formal legal perimeter in July 2018, well ahead of most emerging-market peers. The regime defines four discrete licence categories, each with its own scope, fee schedule, and monthly operational levy. Unlike Kazakhstan, which channels crypto into the Astana International Financial Centre’s bespoke jurisdiction, Uzbekistan applies its rules across the whole country through NAPP, a presidential agency with direct enforcement reach.
A Protected Domestic Market
From 1 January 2023, Uzbek residents may buy, sell, or exchange crypto-assets only through nationally licensed providers, and access to foreign exchanges has been blocked at the network level since August 2022. Law ZRU-899 of 19 January 2024 added criminal penalties of up to five years’ imprisonment for unlicensed crypto activity under Criminal Code Articles 278⁸ and 278⁹. By early 2026 the licensed providers served roughly 660,000 registered clients, with reported turnover above USD 2 billion in 2025.
PP-359: Stablecoins and Tokenisation
Presidential Resolution PP-359 of 27 November 2025 opened a joint NAPP–CBU regulatory sandbox from 1 January 2026 for stablecoin payments and tokenised securities issued by Uzbek legal entities on licensed exchanges. It also mandates open-banking infrastructure by 1 September 2026 and sets a long-run target for fintech foreign direct investment. Operators positioning for stablecoin payments have a short window to engage NAPP and the Central Bank of the Republic of Uzbekistan (CBU) before the rules settle.
The NAPP Regime
The framework rests on Presidential Resolution PP-3832 of 3 July 2018, elaborated through a series of Ministry of Justice registrations covering the licensing procedure, exchange trading rules, the regulatory sandbox, mining permits, and the fee schedule. NAPP is the sole crypto regulator. The CBU is the AML/CFT umbrella supervisor across the financial sector but does not issue crypto licences.
How the Regime Evolved
The current shape dates from 27 April 2022, when Presidential Decree DP-121 restructured the predecessor National Agency for Project Management (NAPM) into NAPP, established the Special Regulatory Sandbox, and rolled out the operative registrations across 2022. Criminal enforcement followed with Law ZRU-899 in January 2024, the state-duty schedule was updated in December 2024, and PP-359 opened the stablecoin and tokenisation sandbox in late 2025. The direction of travel is steadily toward a wider, more formal perimeter.
Where Other Regimes Overlap
Three regimes sit alongside NAPP’s perimeter. AML/CFT obligations under Law No. 660-II of 26 August 2004 apply to all crypto service providers, supervised through the CBU and the General Prosecutor’s Office financial intelligence unit. Currency-regulation rules apply to the fiat legs of crypto transactions, though licensed providers benefit from a PP-3832 exemption for crypto-related conversions. Tax administration sits with the State Tax Committee, which applies the PP-3832 exemption while monitoring the 1 January 2028 sunset.
The Four Licence Types
NAPP issues four activity-specific licences under Ministry of Justice registration 3380. Each authorises a defined scope and is issued for an unlimited period. There is no umbrella VASP or CASP licence; an operator combining activities obtains each licence separately, with its own state duty and monthly fee.
- Crypto-Exchange. An electronic order-book platform for the purchase, sale, and exchange of crypto-assets, serving both companies and individuals. The most demanding and expensive category.
- Crypto-Store. A platform brokering the purchase and sale of crypto-assets to individuals, online and offline, including physical points that accept bank cards and cash.
- Crypto-Depository. A platform for the issuance, initial placement, and storage of crypto-assets, equivalent to a custodian and registrar function.
- Mining-Pool. A platform for the consolidation of computing power for mining. Mining itself is registered with NAPP rather than licensed, and only legal entities may mine.
What Sits Outside the Licence
Pure technology services such as software development, blockchain analytics, and wallet infrastructure fall outside the perimeter and may instead pursue IT Park residency. Resident sales of NFTs on foreign platforms are the sole carve-out from the residents-use-domestic-providers rule. Residents may not issue asset-backed or unsecured tokens outside the PP-359 sandbox; only certain utility tokens are freely permitted.
Requirements
NAPP licensing requires an Uzbek-registered legal entity (typically an LLC, locally an MChJ) with paid-up charter capital, fit-and-proper founders and managers, a registered local office, and platform infrastructure physically located in Uzbekistan with five-year data retention. Crypto-exchange applicants face the most demanding capital threshold; the other categories carry no numerical charter-capital floor on the NAPP licensing page.
Ownership and Fit-and-Proper
Foreign individuals and non-offshore corporate shareholders can own a licensed provider through a domestic holding structure. Companies incorporated in offshore jurisdictions, however, are barred from holding shares, irrespective of how transparent the beneficial ownership is, so operators capitalising through an offshore vehicle must restructure before filing. NAPP assesses founders, beneficial owners, and senior managers; unspent convictions for economic, corruption, or information crimes are disqualifying.
Local Substance
A licensed provider must run as a registered Uzbek legal entity with a registered office in the country and platform infrastructure on servers physically located in Uzbekistan. Transaction and client data must be retained for five years and made available to state authorities on lawful request. The requirement applies uniformly across all four categories; there is no representative-office or branch route for foreign operators. For a crypto-exchange, charter capital is 5,000 BCV (about USD 144,000), of which 3,000 BCV must be reserved in a separate Uzbek commercial-bank account at the date of application.
AML/CFT
AML/CFT obligations sit under Law No. 660-II of 26 August 2004, elaborated for crypto providers through the Internal Control Rules for Crypto Service Providers. The framework aligns with FATF Recommendation 15 on VASPs and Recommendation 16, the Travel Rule. Customer identification is mandatory for all clients; transaction monitoring and suspicious-transaction reports flow to the financial intelligence unit within the General Prosecutor’s Office. A complete application typically runs to 3–6 months from entity formation to licence issuance.
Taxation
Uzbekistan is a zero-tax jurisdiction for the crypto activities of licensed providers and their users until 1 January 2028, anchored in PP-3832 Article 3(b). Operations related to the turnover of crypto-assets are not subject to tax, and the income from them is excluded from the taxable base. Uzbekistan has not enacted domestic Pillar Two legislation, and the OECD Global Minimum Tax applies only to multinational groups above EUR 750 million in revenue, a threshold unlikely to affect standalone Uzbekistan-domiciled providers.
| Tax | Standard rate | Crypto application |
|---|---|---|
| Corporate Income Tax | 15% | 0% on crypto operations of licensed providers until 1 January 2028 |
| Capital Gains Tax | None on crypto | Crypto disposals not taxable for individuals or licensed providers |
| Value-Added Tax | 12% | 0% on crypto trades and provider operations |
| Payroll Tax | 12% PIT | 7.5% PIT for sandbox-resident employees |
Sunset Risk
The Budget Memorandum for 2025–2027 asked NAPP and the Ministry of Finance to design a phased tax model for crypto operations, with proposed (not enacted) parameters of a 3% retail capital-gains tax and a 5% provider corporate levy. These remain proposals. The 0% regime is confirmed in force until 1 January 2028, and any successor regime would require fresh primary legislation, but operators should model taxed operations from 2028 onwards rather than assume the headline 0% rate continues.
Banking & FATF Standing
Banking for an Uzbekistan-licensed provider works differently from an EU or offshore counterpart. Licensed providers operate inside a domestic banking system supervised by the CBU, with the Uzbek som as the principal settlement currency, and PP-3832 exempts them from currency-regulation norms for crypto-related conversions. Multiple Uzbek commercial banks now offer crypto-business accounts, and the CBU has gradually relaxed bank engagement with the regulated sector while keeping prudential oversight tight.
Uzbekistan’s clean international standing helps. It is a member of the Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG), a FATF-style regional body, and is not on the FATF grey or black list. The 2022 Mutual Evaluation Report rated it Compliant or Largely Compliant on most FATF Recommendations, including Largely Compliant on Recommendation 15 for VASPs, and the 2023 follow-up report moved the country from enhanced to regular follow-up. That standing eases correspondent banking relationships, with cross-border USD settlement feasible through tier-2 Central Asian and selected Western correspondents. The som has depreciated steadily against the dollar since the 2017 liberalisation, so capital buffers should be sized with that trend in mind. Open-banking infrastructure mandated under PP-359 is due by 1 September 2026.
No EU Passporting
Uzbekistan is a non-EU, non-EEA third country, and there is no equivalence or recognition regime for third-country crypto licences under MiCA (Regulation (EU) 2023/1114). MiCA Article 61 permits a third-country firm to serve EU clients only on genuinely unsolicited contact, and any form of EU-targeted marketing voids the exemption. Operators seeking systematic EU access must obtain their own CASP authorisation in a member state. For an EU base, Estonia’s MiCA CASP regime is the natural reference point, with full passporting across the EEA.
Advantages and Limitations
Uzbekistan offers a codified four-licence regime, a 0% tax window to 2028, and a protected domestic market, but operators trade EU passporting, reputational tier, and certain entry-cost economics for those advantages.
- 0% tax on crypto operations until 1 January 2028. No corporate income tax, VAT, or capital-gains tax, among the lowest globally.
- Codified four-licence taxonomy. Crypto sat in a formal legal perimeter from the outset, not legalised retroactively.
- Protected domestic market with clean FATF standing. Foreign exchanges blocked since 2022; EAG regular follow-up and Largely Compliant on Recommendation 15.
- Active sandbox. A no-licence pilot route, with stablecoin and tokenised-securities expansion from January 2026.
- × No EU passporting. Operators targeting EU clients need a separate EU member-state CASP authorisation.
- × Heavy local substance and an emerging-market tier. A mandatory Uzbek entity, in-country servers, and five-year data retention, with a reputational tier below EU MiCA.
- × Tax sunset and criminal exposure. The 0% regime is confirmed only to 2028, and Law ZRU-899 carries up to five years’ imprisonment for operating outside the licensed perimeter.
How Uzbekistan Compares
Uzbekistan competes for Central Asia operator flow against Kazakhstan’s AIFC bespoke regime, Kyrgyzstan’s newer framework, and Labuan in Malaysia as an APAC alternative. Estonia is the cross-tier reference for anyone weighing an EU upgrade.
| Factor | Uzbekistan | Kazakhstan (AIFC) | Kyrgyzstan | Estonia (EU) |
|---|---|---|---|---|
| Regulator | NAPP | AFSA within AIFC | State Service for Financial Market Supervision | Financial Supervision Authority (FI) under MiCA |
| Timeline | 3–6 months | 6–7 months | 1–3 months | 3–6 months |
| Corporate Tax | 0% on crypto until 1 Jan 2028 | AIFC participants CIT-exempt | Standard CIT | 22/78 on distributed profits |
| Local Presence | Uzbek entity; in-country servers; 5-yr data retention | AIFC registration with substance | Kyrgyz entity; ≥1 resident director | Estonian entity with substance |
| EU Passporting | No | No | No | Yes (EEA-wide) |
| FATF Status | EAG; not grey-listed; regular follow-up | EAG; not grey-listed | EAG; enhanced monitoring | FATF member; EU AML regime |
| Best For | Central Asia, captive-market positioning | Premium AIFC-tier operators | Cost-led Central Asia entry | EU market access via passporting |
Uzbekistan and Kazakhstan are the two serious Central Asia options, distinguished by architecture: Uzbekistan applies its rules nationally through NAPP, while Kazakhstan channels crypto into the AIFC’s bespoke jurisdiction. Kyrgyzstan is the cost-leader but carries enhanced-monitoring FATF status. For an operator whose primary market is the EU, none of these is the answer; that is where an EU member-state CASP authorisation belongs.
When Uzbekistan Fits
It fits if your primary market is the Uzbek or wider Central Asian resident base, the model can absorb the local-presence and IT-localisation burden, and you value a clean FATF status and a clearly codified taxonomy. Look elsewhere if the EU is your primary market (an EU CASP is the upgrade), or if regional cost-leadership or APAC presence matters more than Uzbekistan’s captive market.
Frequently Asked Questions
Who is the crypto regulator in Uzbekistan?
The National Agency of Perspective Projects (NAPP) is the sole crypto-asset regulator. It is a presidential agency established in its current form by Presidential Decree DP-121 of 27 April 2022, succeeding the National Agency for Project Management (NAPM), and holds exclusive statutory authority over crypto-asset licensing, supervision, and enforcement. The Central Bank of the Republic of Uzbekistan supervises AML/CFT compliance across the financial sector but does not issue crypto licences.
What are the four crypto licence types in Uzbekistan?
NAPP issues four activity-specific licences under Ministry of Justice registration 3380 of 15 August 2022: Crypto-Exchange (order-book trading platforms), Crypto-Store (retail purchase and sale brokered to individuals), Crypto-Depository (issuance, initial placement, and storage, a custodian and registrar function), and Mining-Pool (consolidation of computing power for mining). There is no umbrella VASP or CASP licence; operators combining activities obtain each licence separately.
Can a foreign company own a NAPP-licensed crypto provider?
Foreign individuals and non-offshore corporate shareholders can own a licensed provider through an Uzbek legal entity (typically an LLC / MChJ). The licence is issued only to Uzbek-registered legal entities, so foreign ownership operates through a domestic holding structure. Companies incorporated in offshore jurisdictions are barred from holding shares, irrespective of beneficial ownership transparency, so operators capitalising through an offshore vehicle must restructure before filing.
How long does it take to get a crypto licence in Uzbekistan?
A realistic timeline is 3–6 months end-to-end from entity formation to licence issuance. Entity registration takes 1–2 working days and dossier preparation 4–8 weeks; NAPP review runs 1–3 months for a complete dossier. Crypto-exchange applicants must also complete charter-capital deployment and a separate bank reservation at the date of application.
Is there a sandbox alternative to full licensing?
Yes. The Special Regulation Regime in Crypto-Assets Circulation under Decree DP-121 of 27 April 2022 and Ministry of Justice registration 3409 permits pilots without a full NAPP licence, with tax exemptions and a fixed 7.5% personal income tax on sandbox-employee wages. PP-359 of 27 November 2025 extends the sandbox to stablecoin payments and tokenised securities from 1 January 2026 under joint NAPP–CBU supervision.
Is Uzbekistan on the FATF grey list?
No. Uzbekistan is not on the FATF grey or black list. It is a member of the Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG), the FATF-style regional body. The 2022 Mutual Evaluation Report rated it Compliant or Largely Compliant on most FATF Recommendations, including Largely Compliant on Recommendation 15 for VASPs, and the 2023 follow-up report moved the country from enhanced to regular follow-up, which eases correspondent banking relationships.
Can an Uzbekistan crypto licence serve EU clients?
No. An Uzbekistan licence does not grant EU market access or MiCA passporting rights. Uzbekistan is a non-EU, non-EEA third country, and there is no equivalence regime for third-country crypto licences under MiCA. MiCA Article 61 permits third-country firms to serve EU clients only on genuinely unsolicited contact, interpreted narrowly, and any EU-targeted marketing voids it. Operators seeking systematic EU access must obtain a separate CASP authorisation in an EU member state.
What is the penalty for unlicensed crypto activity?
Law ZRU-899 of 19 January 2024 added Criminal Code Articles 278⁸ and 278⁹ covering unlicensed crypto activity. Penalties include fines, administrative arrest, restriction of freedom, and up to five years’ imprisonment for repeat or organised offences. Foreign exchanges have been blocked at the network level since August 2022. The compliant route for foreign operators is licensing or partnering with a NAPP-licensed entity.
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Related Reading
- Estonia Crypto Licence: MiCA CASP authorisation with full EU passporting
- Kazakhstan Crypto Licence: the AIFC bespoke digital-asset regime
- Kyrgyzstan Crypto Licence: cost-led Central Asia entry
- Crypto Licensing Overview: the jurisdictions we deliver in directly