In 2026, the Republic of Uzbekistan took another step in the development of its digital economy. The Law “On Amendments and Additions to Certain Legislative Acts Aimed at Improving the Sphere of Electronic Commerce” (the “Law”), adopted by the Legislative Chamber on 10 February 2026 and approved by the Senate on 18 May 2026, introduces substantial changes simultaneously to two key legislative acts — the Tax Code of the Republic of Uzbekistan and the Law “On Electronic Commerce” No. ZRU-792 dated 29 September 2022. The Law is aimed at creating a transparent and open e-commerce ecosystem, protecting the rights of purchasers of digital goods and services, and establishing a clear tax environment for foreign market participants.
Amendments to the Tax Code: foreign legal entities under new regulation
One of the novelties of the Law is a substantial expansion of the scope of tax regulation of foreign legal entities. Whereas Chapter 39 of the Tax Code previously applied only to providers of electronic services, it now also covers foreign legal entities selling goods through electronic trading platforms where the place of sale is recognised as the Republic of Uzbekistan. The place of sale is deemed to be Uzbekistan where both the buyer’s place of residence and the place of delivery of the goods are located in the territory of the republic.
The Law regulates the institution of the tax agent in detail. Depending on the structure of the transaction, the tax agent may be an intermediary — a foreign or Uzbek legal entity directly involved in settlements with buyers under commission, brokerage, agency or other similar agreements — or the operator of an Uzbek electronic trading platform making settlements in favour of a foreign seller. Where the buyers are Uzbek legal entities or permanent establishments of foreign companies, it is they who are recognised as tax agents.
A clear procedural framework has been established: a foreign legal entity must file an application for registration with the tax authority no later than thirty calendar days from the date it begins providing services or selling goods through electronic trading platforms. All tax reporting is submitted electronically through the taxpayer’s personal account. In addition, the Law sets a special rule for foreign legal entities under which documents are deemed received thirty days after dispatch, whether sent on paper or via telecommunications channels.
Amendments to the Law on E-Commerce: new actors, new obligations
No less significant are the amendments to the Law “On Electronic Commerce”. First of all, the Law substantially updated the conceptual framework by introducing a number of new definitions. The concepts of an electronic trading platform — a hardware and software system providing the infrastructure for concluding sale-and-purchase contracts and making payments — and of an order aggregator — a system providing the infrastructure for concluding service contracts — are now enshrined in legislation. The concept of a digital streaming service has also been introduced: a platform enabling the use of digital products in real time (online). Digital products cover both electronic copies of intellectual property items (digital goods) and services in the electronic information environment that have no tangible result, including cloud technologies.
The list of e-commerce operators now includes three categories: operators of electronic trading platforms, operators of order aggregators and operators of digital streaming services. Separate rights and obligations are established for each of them. In particular, the operator of an electronic trading platform must verify sellers’ licences and permits, take measures to stop the sale of goods withdrawn from circulation, ensure the confidentiality of personal data and compliance with cybersecurity requirements, ensure the transparency of product recommendation algorithms, and store buyers’ reviews without altering them. An operator must announce its intention to suspend operations or change its terms of service at least thirty days in advance.
A fundamentally important novelty is the introduction of subsidiary liability of e-commerce operators to buyers. The primary responsibility for performance of the contract and the quality of goods lies with the seller; however, if the seller cannot satisfy the buyer’s lawful claims, the platform operator bears subsidiary liability, unless otherwise provided by contract or by law.
The Law also introduces, for the first time in Uzbek legislation, the concept of cross-border electronic commerce, defining it as a type of e-commerce in which the participants and operators are located in different states, one of which is the Republic of Uzbekistan. Cross-border e-commerce procedures fall within the competence of the Cabinet of Ministers.
Significance of the adopted changes
The adopted Law is a comprehensive step towards bringing order to the rapidly developing e-commerce market. The introduction of tax obligations for foreign sellers of goods via online platforms puts them on an equal footing with local market participants and is aimed at eliminating tax arbitrage. Enshrining the subsidiary liability of platform operators strengthens consumer protection and creates incentives for platforms to monitor their sellers more closely. Finally, the detailed regulation of the rights and obligations of the various types of operators creates a predictable legal environment for all participants in the digital economy, both domestic and foreign.