Black Swan Consulting presents the first comprehensive Guide to Nuclear Law in Uzbekistan.

Where the programme stands

Uzbekistan holds significant uranium resources and is building the infrastructure for the peaceful use of atomic energy. The strategic milestone was the 2018 intergovernmental agreement with the Russian Federation on the construction of a nuclear power plant, amended twice in 2025. The first amendment, of 20 June 2025, made the project phased — a small nuclear power plant and a large one on a single site in the Jizzakh region, near Lake Tuzkan — keeping the provisions on units of up to 1.2 GW each and adding a small-capacity plant based on RITM-200N reactor units. The second, of 26 September 2025, fixed the configuration: two high-power VVER-1000 reactors of 1,000 MW each and two low-power RITM-200N reactors of 55 MW each, giving an integrated station of roughly 2.1 GW that combines small and large nuclear technology. The Concept for the Development of Nuclear Energy until 2029 was approved in 2019, and the Uzatom Agency, responsible for implementing and coordinating projects in the field, was established in 2024.

International obligations

Uzbekistan acceded to the Treaty on the Non-Proliferation of Nuclear Weapons on 7 May 1992. Under Article II it may not produce or acquire nuclear weapons or other nuclear explosive devices and must accept IAEA safeguards, while retaining the right to research, to peaceful use, and to international cooperation and technology exchange.

The Comprehensive Nuclear-Test-Ban Treaty was ratified by resolution of the Oliy Majlis No. 432-I of 25 April 1997 and entered into force for the country on 23 August 1997. The Treaty on a Nuclear-Weapon-Free Zone in Central Asia was signed at Semipalatinsk on 8 September 2006, ratified by Law No. 80 of 2 April 2007, and entered into force on 21 March 2009 once all five regional states had ratified it. Under it, Uzbekistan may not research, develop, manufacture, acquire, store or station nuclear weapons on its territory, may not permit the disposal of foreign radioactive waste, must use nuclear materials exclusively for peaceful purposes under IAEA safeguards including the Additional Protocol, and must maintain effective physical protection standards. The International Convention for the Suppression of Acts of Nuclear Terrorism was acceded to by Law No. 146 of 9 April 2008 and entered into force on 21 April 2008; the competent authority designated under Article 7 is the State Security Service. Separately worth noting is the Vienna Convention on Civil Liability for Nuclear Damage: Uzbekistan acceded to it by Law No. 1086 of 26 September 2025, and its provisions became legally binding for the country in the same year. The Convention assigns liability exclusively to the operator of a nuclear installation, which establishes a single subject of liability and eases victims’ access to justice.

Two IAEA documents shape practice directly. The physical protection recommendations INFCIRC/225/Rev.5 (2012) are the standard to which, under the 2018 agreement with Russia, the physical protection system of the plant’s main and auxiliary facilities is designed — including the obligations to keep nuclear material under continuous control of competent authorities, to record the moment responsibility transfers between states or carriers, to conclude written arrangements for the international transport of Category I materials, to detect unauthorised intrusion and maintain sufficient guard and response forces, and to admit to protected areas only vetted and authorised persons. Transport follows the Regulations for the Safe Transport of Radioactive Material, SSR-6 (Rev. 1), 2018 edition, whose four specific measures are containment of the radioactive contents, control of external dose rate, prevention of criticality, and prevention of damage from heat generation.

The national framework

The cornerstone is the Law No. ZRU-565 “On the Use of Atomic Energy for Peaceful Purposes” of 9 September 2019, adopted in implementation of Presidential Decree No. 5484 of 19 July 2018. It covers the siting and construction of nuclear installations and storage facilities, their operation, the transport of nuclear materials and radioactive substances, and the import, export, storage, processing and disposal of installations and waste. Around it stand the Law “On Radiation Safety” No. 120-II of 31 August 2000, the law on accession to the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management, the laws on sanitary and epidemiological well-being, waste, transit of special cargoes, subsoil, export control, environmental control and nature protection, and the Codes on Administrative Liability and Criminal law.

Licensing and liability

Licensing is carried out by the Committee on Industrial, Radiation and Nuclear Safety under the Cabinet of Ministers, under the Regulation approved by Cabinet of Ministers Resolution No. 663 of 28 October 2020. Two activities of operating organisations are licensed — construction and operation of nuclear installations and/or storage facilities, and handling of radioactive substances, nuclear materials and radioactive waste — against three conditions: a positive safety justification expert conclusion, financial provision to compensate radiation damage, and justified financial stability across the full lifecycle of the facility. Nine further activities are licensed for other legal entities, from design and construction and the manufacture of equipment through safety justification expertise, handling of radioactive substances, radioactive waste management, scientific research, import and export of materials, equipment and technologies, provision of services, and the training of operating personnel. A licence is issued to legal entities without a time limit, and neither it nor the rights to it may be transferred.

Operating without a licence, or obtaining one on forged documents, carries a fine of 300 base calculation values under the Law “On Licensing, Permit and Notification Procedures” No. 701 of 14 July 2021 — one BCV being 412,000 soums as of the guide’s publication. Article 98 of the Code on Administrative Liability punishes breaches of the rules for accounting, storage and use of explosive and radioactive materials with one to three BCVs for individuals and five to seven for officials, rising to three to five and ten to fifteen on repetition within a year. The Criminal Code adds Articles 246, 252–254 and 297. Civil liability insurance of operators for nuclear damage is mandatory.

Who manages what

The institutional architecture separates two functions. State management sits with the Cabinet of Ministers, the authorised state management body and bodies with separate powers. Safety regulation sits with the Committee on Industrial, Radiation and Nuclear Safety as the specially authorised body — it forms state policy on facility safety, exercises state control and supervision, approves norms and rules, supervises physical protection and the accounting of nuclear materials, organises safety justification expertise, licenses activities and issues work permits to employees. Alongside it, bodies with separate regulatory powers include the ecology, emergency situations, health, construction, geology, customs, hydrometeorology and internal affairs authorities. The Institute of Nuclear Physics of the Academy of Sciences holds licence AS No. 0036 of 26 August 2019, and the national operator for radioactive waste disposal is the State Unitary Enterprise “Republican Radioactive Waste Disposal Facility” within the Institute.

The life cycle of a facility

The decision to build a nuclear installation or storage facility is taken by the President on the proposal of the Cabinet of Ministers; the Cabinet selects the site; the specially authorised body organises the state examination of the site’s safety justification and issues the permit for its use. If the safety justification expertise later reveals circumstances that lower the safety level or worsen the environmental condition, the decision is subject to cancellation and works must be stopped or suspended — cancellation, like the original decision, is made by the President on the Cabinet’s proposal.

A facility is accepted for operation together with all industrial and domestic facilities envisaged by its project. Commissioning follows a programme approved by the operating organisation on the basis of the design documentation and agreed with the safety regulators, and is permitted only where the operating organisation holds an operating licence. The operating organisation answers for the safety of the facility and for the handling of radioactive substances, nuclear materials and waste — and continues to answer for it even after losing its licence, until the facility passes to another operator or a new licence is obtained.

Decommissioning measures must be built into the design documentation from the start. To pay for them, the operating organisation forms a Decommissioning Fund, whose formation procedure must be determined before commissioning; for a nuclear power plant or a unit of one it is funded from the sale of electrical and thermal energy and other services. Its money may be spent only on decommissioning, on spent fuel handling, and on research aimed at justifying and improving the safety of these facilities.

Emergency preparedness, damage and physical protection

Preparedness runs on two plans. The internal emergency plan is developed by the operating organisation, which funds its material, technical and personnel readiness itself; it is verified in practice before commissioning and throughout operation at a frequency set by the specially authorised body and the Ministry of Emergency Situations. The external plan defines emergency response zones and the actions of state and local bodies and of the State System for Prevention and Response to Emergency Situations; the Ministry of Emergency Situations coordinates its development, and the Cabinet of Ministers approves it.

Damage caused by the operating organisation through radiation exposure is compensated regardless of fault. The operator is not liable where the damage arose from force majeure or military action, and is released where the injured person deliberately harmed their own life or health. Environmental damage caused through the operator’s fault is compensated in the manner set by the legislation on atomic energy, and claims may be brought by state management bodies, environmental authorities and local government. The operator must hold financial provision, and may not suspend or terminate it without giving the specially authorised body and the authorised management body at least three months’ written notice. Where damage exceeds the operator’s liability limit set by international treaty, the Cabinet of Ministers pays part of the compensation, and it also compensates damage arising from force majeure or military action.

Physical protection is defined as a unified system of planning, coordination, state supervision and control, and technical and organisational measures, aimed at preventing unauthorised access to nuclear installations, storage facilities, radioactive substances, nuclear materials and waste and their theft or damage; at the timely detection and suppression of attempts against their integrity and of sabotage and terrorist acts; and at the detection and recovery of lost or stolen material.

People and permits

Under Article 21 of the Law, employees of operating organisations and other legal entities may perform certain work in the field only if they hold permits; the lists of positions and types of work requiring them are approved by the Cabinet of Ministers. Training, retraining and certification follow Cabinet of Ministers Resolution No. 13 of 10 January 2022. Certification is initial, periodic or extraordinary. Initial certification takes place within three months of employment or appointment. Periodic certification runs on three clocks: heads of organisations and the chairs and deputy chairs of their certification commissions — once every five years; employees responsible for departmental control of nuclear and radiation safety, technological processes, accounting and control of nuclear materials and radioactive substances, their physical protection and transport, together with members of certification commissions — once every three years; engineering and technical personnel and other employees — once a year.

Extending a unit’s life, and protecting radiation sources

Once a decision to extend the operation of an NPP unit is taken, the operating organisation prepares a programme based on a comprehensive inspection: compliance analysis against the norms and rules of nuclear energy use, justification of the residual life of safety-important structures and buildings and assessment of their foundations, justification of the residual life of components for the additional period, replacement of components whose life is exhausted or unmeasurable, elimination of non-compliances or compensation of their effects, modernisation, radiation survey of premises, equipment and pipelines, testing of systems and components, a lifespan management programme, condition monitoring measures, a standard non-destructive testing programme for metals and pipes, a safety justification report covering the whole extended period, and changes to the operational documentation.

The Rules for Ensuring the Safety of Radiation Sources, approved by Resolution No. 24 of the Committee on 13 October 2025 and registered with the Ministry of Justice on 28 October 2025 under number 3695, require a multi-level protection programme of physical barriers and organisational and technical measures. Among its requirements: a suitable location for Category 1 and 2 sources, safety conditions considered at the design stage, automatic safety systems equipped with self-protection, technical diagnostics within the timeframes set by the technological documentation with mandatory elimination of defects, and — for accidents outside the design basis — preservation of the integrity of the premises and removal of radioactive substances from the source within 24 hours by automatic safety systems. Radiation protection follows SanPiN No. 0193-06, comprising NRB-2006 and OSPORB-2006.

Tax benefits

Under the 2018 intergovernmental agreement of 7 September 2018, Russian authorised organisations including the general contractor, Russian subcontractors and third-country organisations engaged by them are exempt from taxation — their operations, capital, assets, cash, income and profit, and their personnel — from all types of taxes, fees and duties, including profit tax, VAT, personal income tax of personnel, property tax, state duties, excise taxes and mandatory contributions to state target funds. Equipment, materials, spare parts, devices, instruments, nuclear fuel in the form of complete fuel assemblies and control and protection system rods in the quantities needed for commissioning and operation, component products, documentation and software imported by those organisations are exempt from customs payments levied in Uzbekistan.

Where practice and rule diverge

The guide’s conclusions are not uniformly favourable. Article 6 of the Aarhus Convention provides for public consultation before decisions on the construction of facilities with significant environmental impact — but in Uzbekistan the sequence was reversed: construction of the plant in the Farish District of the Jizzakh Region began on 9 October 2025, while public hearings on the project were scheduled only for November–December 2025. The guide sets this against the Aarhus Compliance Committee’s findings in comparable cases — ACCC/C/2014/104 on the lifetime extension of the Borssele plant in the Netherlands, ACCC/C/2009/37 in Belarus, ACCC/C/2004/3 in Ukraine and ACCC/C/2011/59 in Kazakhstan — where late or formal participation was qualified as a violation of the Convention. It also flags an unresolved discrepancy in the record of Uzbekistan’s participation in CIS agreements: the country participates in six international documents, yet Appendix 4 to its 2024 national report to the IAEA lists only one, and the guide’s authors could not establish from official sources whether participation in the others has been terminated.

The full guide sets out each of these areas with citations to the underlying acts, alongside a glossary, the international standards and the complete list of references.