Uzbekistan publishes draft Ecological Code consolidating environmental regulation into a single framework

17 July 2026

A draft Ecological Code was published for public consultation from 30 June to 15 July 2026, prepared by the National Committee on Ecology and Climate Change. If adopted, it will replace the existing Law on Nature Protection and a range of sector-specific environmental instruments with a single codified framework. As with other recent draft legislation, specific figures and provisions may be revised during the legislative process, but the underlying direction of the reform is clear and unlikely to change materially.

Why this reform was introduced

Uzbekistan's current environmental legislation consists of more than a dozen separate laws adopted between the 1990s and 2010s, with inconsistent definitions, overlapping competences between regulatory bodies, and enforcement mechanisms that have not kept pace with the scale of industrial and agricultural activity. The draft acknowledges this directly and aims to establish a coherent, hierarchically structured framework aligned with international environmental standards and Uzbekistan's commitments under multilateral environmental agreements including the Paris Agreement, the Convention on Biological Diversity and the UN Convention to Combat Desertification.

A new permitting architecture

The draft introduces a unified environmental permitting system replacing the current patchwork of sector-specific approvals. All activities with a potential environmental impact are classified into three categories based on the level of risk and scale of impact. Category I covers large-scale industrial, extractive, energy and infrastructure activities with significant environmental impact, requiring a full environmental permit issued by the national regulatory body. Category II covers medium-impact activities, requiring a simplified permit. Category III covers low-impact activities subject only to notification and compliance with established norms.

Permits are issued for defined periods and must be renewed. Operating without a required permit, or in breach of permit conditions, constitutes an environmental violation subject to administrative and, in serious cases, criminal liability. The draft introduces a single environmental permit concept, consolidating what are currently separate air, water and waste discharge approvals into one instrument per facility, with unified monitoring and reporting obligations.

Environmental impact assessment

The draft establishes a mandatory environmental impact assessment procedure for all Category I activities and a defined list of Category II activities. EIA is a precondition for project approval and must be completed before construction or operational permits are issued. The assessment must cover the full project lifecycle including construction, operation, decommissioning and post-closure monitoring. Public participation is mandatory, with a defined consultation period and an obligation to consider and respond to public submissions in the final assessment document.

Strategic environmental assessment is introduced as a separate procedure applicable to government programmes, sector development plans and spatial planning documents. Both procedures are subject to state ecological expertise, a formal review by the authorised body whose positive conclusion is required for project approval.

Environmental liability and the polluter pays principle

The draft significantly strengthens environmental liability. Liability for environmental harm is established on the basis of actual damage caused to the environment, human health or third parties, regardless of whether the activity was conducted lawfully and with all required permits in place. This is a departure from the current approach, under which compliance with permit conditions largely insulates operators from further claims.

Damage is assessed using standardised methodologies approved by the authorised body. Where damage cannot be remedied in kind, monetary compensation is payable to the state environmental fund. The draft introduces joint and several liability for environmental harm caused by multiple operators contributing to the same damage. Directors and senior officers of legal entities may bear personal liability where harm results from their decisions or instructions.

The statute of limitations for environmental damage claims is set at twenty years from the date the harm was or should have been discovered, which is significantly longer than the general civil law limitation period.

Climate obligations and carbon market mechanisms

The draft includes a dedicated chapter on climate change, reflecting Uzbekistan's Paris Agreement commitments. Large industrial emitters above defined greenhouse gas thresholds will be required to report annual emissions to a national greenhouse gas registry. The registry will be publicly accessible, at least in aggregated form.

The draft provides the legal basis for a domestic carbon market, including the issuance, transfer and cancellation of carbon units, and the recognition of internationally issued carbon credits subject to conditions set by the government. Companies operating in emissions-intensive sectors should note that the draft also provides for the introduction of mandatory greenhouse gas reduction targets for large emitters, with the specific thresholds and targets to be determined by subordinate regulation. Voluntary carbon market participation is also permitted under the framework.

Waste management and extended producer responsibility

The draft introduces an extended producer responsibility framework for defined categories of goods, requiring producers and importers to either organise the collection and recycling of post-consumer waste from their products or pay into a producer responsibility fund. Product categories subject to extended producer responsibility will be defined by government decree. The draft also introduces requirements for hazardous waste tracking, manifesting and disposal through licensed operators only.

Protected areas and biodiversity

The draft strengthens protections for specially protected natural areas and introduces biodiversity impact assessment as a component of the general EIA procedure for activities in or near protected zones. Companies with operations or planned projects near protected areas, buffer zones or ecological corridors should note that the draft significantly restricts permitted activities in these areas and introduces mandatory biodiversity offsetting for residual impacts that cannot be avoided or mitigated.

Reporting, monitoring and public disclosure

The draft introduces mandatory environmental reporting for Category I and II operators, with annual reports submitted to the authorised body and published on its website. Reports must cover emissions to air, water discharges, waste generation and disposal, energy consumption, and greenhouse gas emissions where applicable. The authorised body maintains a unified state environmental monitoring system integrating data from operator self-monitoring, state inspections and remote sensing. Operators are required to install automated continuous monitoring equipment at defined emission points, with real-time data transmitted to the state system.

Enforcement and sanctions

The draft provides for a risk-based inspection regime, with inspection frequency calibrated to the environmental risk category of the facility. Unscheduled inspections may be triggered by complaints, accidents or indicators of non-compliance. The draft introduces a range of enforcement tools including binding orders, administrative fines, permit suspension and revocation, and injunctions requiring immediate cessation of harmful activities. Criminal liability for serious environmental offences, including causing significant environmental damage, is addressed through amendments to the Criminal Code referenced in the draft.

What this means for your business

The draft Ecological Code, if adopted broadly as drafted, would establish the most demanding environmental compliance framework Uzbekistan has had. For international companies, several elements stand out.

The single environmental permit concept and unified reporting obligations will simplify the administrative burden compared to the current fragmented system, but the substantive requirements, particularly for Category I operators, are significantly more demanding. The shift to harm-based liability regardless of permit compliance is the most consequential change for operational risk management: companies should review their insurance arrangements, indemnity provisions in project agreements, and environmental due diligence procedures in light of this change.

The twenty-year limitation period for environmental damage claims, the introduction of director-level personal liability, and joint and several liability for shared damage are all elements that will need to be factored into project structuring, corporate governance and contractual risk allocation.

The climate chapter and carbon market provisions signal that greenhouse gas management is moving from a voluntary to a regulatory matter. Companies in energy, extractives, cement, chemicals and other emissions-intensive sectors should begin preparing emissions baselines and tracking systems now, ahead of the specific thresholds being set in subordinate regulation.

The public consultation closed on 15 July 2026. The timeline for parliamentary consideration has not been announced. Companies with significant environmental footprints in Uzbekistan should monitor the legislative progress closely and engage during the public consultation process on subordinate regulatory instruments, where the specific thresholds, methodologies and timelines that will determine actual compliance obligations will be set.