Uzbekistan extends VAT to foreign sellers on e-commerce platforms and overhauls operator obligations

12 September 2026

On 10 September 2026, President Mirziyoyev signed Law No. 1173 amending the Tax Code and the Law on E-Commerce. Adopted by the Legislative Chamber on 10 February 2026 and approved by the Senate on 18 May 2026, the law takes effect three months after official publication, on 12 December 2026. It has two distinct blocks: a significant extension of Uzbekistan's VAT regime to foreign companies selling goods through e-commerce platforms, and a comprehensive rewrite of the rights and obligations of e-commerce operators. It follows closely on the operator notification procedure covered in our earlier insight, which takes effect on 24 September 2026.

Tax: foreign sellers on e-commerce platforms become VAT taxpayers

The most commercially significant change is the extension of Uzbekistan's existing regime for foreign suppliers of electronic services to now also cover foreign legal entities selling goods through e-commerce platforms. Chapter 39 of the Tax Code is retitled accordingly.

Under the amended Article 278, foreign legal entities supplying electronic services or selling goods through e-commerce platforms where the place of supply is Uzbekistan are recognised as taxpayers in respect of supplies to individuals. Critically, the law establishes a clear place-of-supply rule for goods: where goods are sold to individuals through an e-commerce platform, the place of supply is Uzbekistan if both the buyer's place of residence and the delivery destination are in Uzbekistan.

Uzbekistan's standard VAT rate is 12%, which is the rate that will apply to these supplies.

Tax agent rules and where liability falls

The law sets out a layered tax agent structure:

• Where a foreign legal entity supplies electronic services or sells goods through e-commerce platforms to individuals with Uzbekistan as the place of supply, intermediaries participating directly in settlements with individuals, whether foreign legal entities or Uzbek legal entities, acting under commission, agency, mandate or similar agreements, are recognised as tax agents
• Where multiple intermediaries participate in a settlement chain sequentially, the intermediary settling directly with both the individual buyer and the foreign supplier is the tax agent, regardless of whether it has a direct contract with the foreign supplier
• Where a foreign legal entity supplies services or sells goods through an Uzbek e-commerce platform, the operator of that platform, if it conducts settlements in favour of the foreign supplier, is the tax agent
• Where such services are supplied to Uzbek legal entities or to non-resident legal entities operating in Uzbekistan through permanent establishments, those buyers are the tax agents

For Uzbek e-commerce platform operators, this is a material new compliance obligation: they become responsible for VAT collection and remittance on behalf of foreign sellers using their platform.

Registration, tax base and reporting

Foreign legal entities supplying electronic services or selling goods through e-commerce platforms to individuals, where they settle directly with buyers without intermediaries, must register with the Uzbek tax authority. Registration and deregistration are based on an application plus supporting documents in a list approved by the State Tax Committee. Applications must be submitted no later than thirty calendar days from the date electronic service supply or platform-based goods sales begin or end. Foreign intermediaries recognised as tax agents follow the same registration procedure.

For goods sold by foreign legal entities to individuals through e-commerce platforms with Uzbekistan as the place of supply, the tax base is the value of the goods calculated from actual selling prices, inclusive of the tax amount. Tax reporting is submitted electronically to the tax authority through the taxpayer's personal cabinet in a prescribed format.

E-Commerce Law: new definitions and expanded scope

The amendments substantially rewrite the definitional framework of the E-Commerce Law, introducing or redefining:

• Order aggregator: a hardware-software complex or ICT system providing technical, organisational and information infrastructure for e-commerce participants to conclude contracts for the provision of services or works and to make payments, using the internet and telecommunications networks
• Order aggregator operator: the legal entity owning and/or managing an order aggregator
• Digital products: electronic copies of intellectual property objects (digital goods), as well as services relating to performing certain actions or activities in an electronic information environment without a material result, including obtaining and subscribing to cloud technologies and digital services
• Digital streaming service: a system enabling e-commerce participants to access digital products in real time online, and providing infrastructure for concluding contracts and making payments
• Digital streaming service operator: the legal entity owning and/or managing a digital streaming service
• E-commerce platform: a system providing infrastructure for concluding sale and purchase contracts for goods, works and services between e-commerce participants and making payments
• E-commerce platform operator: the legal entity owning and/or managing an e-commerce platform

The law also replaces the older terminology of "trading platform" with "e-commerce platform" and "subjects" with "participants and operators" throughout.

Cross-border e-commerce defined for the first time

A new Article 10¹ defines cross-border e-commerce as e-commerce conducted where e-commerce participants and operators are located in different states, with at least one located in Uzbekistan. The procedures for cross-border e-commerce are to be established by the Cabinet of Ministers, which under Article 4 of the law must do so within three months of official publication.

Subsidiary liability of e-commerce operators

A significant consumer protection change: under new provisions in Article 12, the seller is the primary party liable for disputes arising from performance of contracts concluded through an e-commerce operator's information systems, including delivery of defective goods, works or services, or replacement of non-food goods of inadequate quality.

However, where the seller is unable to satisfy the buyer's lawful claims, the e-commerce operator bears subsidiary liability to the buyer, unless the contract terms or legislation provide otherwise. This places a real financial backstop obligation on platform operators, aggregators and streaming services.

Obligations of e-commerce platform operators

Beyond the general operator rights, platform operators may sell goods, works and services directly and independently on their own platform. In addition to general operator obligations, they must:

• Verify the licences, permit documents or notifications of sellers conducting licensed or permit-based activities, or activities subject to notification procedures
• Take measures to stop the sale of goods, works or services withdrawn from circulation or restricted in circulation
• Ensure confidentiality of users' personal data and comply with personal data legislation
• Ensure information security and cybersecurity requirements are met in processing payments
• Review complaints relating to platform activity in the manner prescribed by law
• Provide relevant information to the authorised state body in the cases and manner prescribed by law
• Ensure transparency of the algorithms used to offer and rank goods, works and services
• Enable buyers to leave reviews, refrain from altering them, and ensure their preservation, except where legislation provides otherwise
• Publish platform usage rules, contract (public offer) terms, and other information subject to mandatory disclosure on the platform

Where a platform operator intends to suspend its e-commerce activity or amend its service rules, it must publish notice on the platform at least thirty days in advance, except where legislation provides otherwise.

Obligations of order aggregator operators

A new Article 13¹ establishes a parallel regime for order aggregators. Aggregator operators have the right to independently form and set the final price of services or works offered to buyers, based on demand, supply and other factors. Their obligations mirror those of platform operators: seller licence verification, stopping restricted services, personal data confidentiality, information security and cybersecurity in payments, complaint handling, information provision to the authorised body, algorithm transparency, review integrity, and publication of usage rules and contract terms. The same thirty-day advance notice requirement applies to suspension of activity or changes to service rules.

Obligations of digital streaming service operators

A new Article 13² covers streaming operators, who have the right to independently establish rules for using digital products on their service and to moderate content in accordance with legislation. Their obligations include all of the above, plus two specific to their sector:

• Ensuring respect for copyright and related rights in digital products hosted on the service, monitoring unlawful use of intellectual property objects, and taking preventive measures
• Ensuring the quality of digital products and streaming services provided to users meets established requirements

They must also take measures to stop distribution of digital products that are restricted or prohibited in circulation, and observe the same thirty-day notice requirement.

Mandatory disclosure of returns and refunds

Article 16 is amended to require that e-commerce operators disclose the procedure and conditions for returning goods, works or services, and for refunding amounts paid to buyers. This becomes part of the mandatory pre-contractual information set.

Separate bank accounts for e-commerce settlements

Article 23 introduces a significant operational requirement: e-commerce operators, legal entities and individual entrepreneurs selling through e-commerce, and self-employed persons selling or delivering goods, works or services on order, or providing passenger transport by light motor vehicles, must conduct all e-commerce settlements exclusively through separate bank accounts. Individual entrepreneurs and self-employed persons may also use electronic wallets.

Income received by self-employed persons from e-commerce activity is accounted for in a separate bank account linked to their bank card and/or electronic wallet. Self-employed persons are given specific rights to accept payment on behalf of third-party sellers, to have funds pre-placed into their separate account or wallet from a supplier's or operator's account for subsequent write-off and collection, and to accept cash payment for delivered goods, works or services, retaining cash equal to the amount transferred to the supplier without needing to deposit it.

Escrow-based refunds

A new provision in Article 27 gives e-commerce operators providing escrow services the right to independently refund funds to the buyer, in the manner set out in the contract with the seller, where the seller refuses to make the refund. This gives buyers a practical remedy where a seller is uncooperative.

Digital product export and import

A new Article 27¹ addresses digital product cross-border movement:

• Digital products carried across Uzbekistan's customs border on material carriers are subject to customs clearance and declaration under standard procedures
• Digital products exported or imported by digital distribution methods are not subject to customs clearance at all
• Where digital products are exported through foreign e-commerce platforms by digital distribution, foreign currency proceeds arrive in the exporter's account net of the foreign platform's service fees, and the deadline for receipt of proceeds is determined by the foreign platform's own rules

This last point is a practically important accommodation for Uzbek software developers, content creators and digital exporters selling through international app stores and marketplaces, aligning currency control expectations with commercial reality.

Implementation timeline

The Cabinet of Ministers must establish cross-border e-commerce procedures within three months of official publication, align government resolutions with the law, and ensure republican executive bodies revise or repeal conflicting regulations. The National Agency for Prospective Projects and other interested organisations are tasked with ensuring implementation and public explanation of the law.

What this means for your business

This law has different implications depending on where a company sits in the e-commerce value chain.

For foreign companies selling goods to Uzbek consumers through e-commerce platforms, whether their own or third-party marketplaces, the key change is the creation of VAT liability in Uzbekistan at the standard 12% rate where the buyer resides and receives delivery in Uzbekistan. Where settlements run directly with buyers, the foreign seller must register with the Uzbek tax authority within thirty days of commencing sales. Where an Uzbek platform operator or an intermediary handles settlements, that party becomes the tax agent. Foreign sellers should map their settlement flows carefully to determine whether registration obligations fall on them directly or are absorbed by a tax agent in the chain, and should factor the 12% into pricing models for the Uzbek market.

For e-commerce platform operators, aggregators and streaming services operating in Uzbekistan, this law significantly expands both compliance burden and legal exposure. The tax agent role for foreign sellers is a new operational and financial responsibility requiring systems capable of calculating and remitting VAT. The subsidiary liability provision means operators can be held financially responsible to buyers where sellers fail to meet lawful claims, which requires review of seller agreements, indemnity arrangements and escrow structures. The algorithm transparency and review integrity obligations require product and engineering changes, not just legal documentation. The thirty-day advance notice requirement for changes to service rules constrains how quickly commercial terms can be adjusted.

For companies engaged in digital product export from Uzbekistan, the clarification that digitally distributed products are exempt from customs clearance, and that currency proceeds may arrive net of platform fees on the platform's own timeline, removes a longstanding source of friction for software and content exporters.

All affected parties should note that this law works alongside the operator notification procedure taking effect on 24 September 2026, and that the Cabinet of Ministers' cross-border e-commerce procedures, due within three months of publication, will add a further layer of operational detail. Companies should build both the December 2026 effective date and the pending Cabinet procedures into their compliance planning.