Uzbekistan has introduced a new mandatory framework requiring large investment projects to undergo anti-corruption review and competition impact assessment before approval or implementation.

The new rules are aimed at strengthening transparency, preventing conflicts of interest and ensuring fair competition in strategically significant investment projects involving state support or public financing.

Projects subject to mandatory review

 

The framework applies to major investment projects involving at least the equivalent of USD 50 million in financing, including projects funded through:

• the State Budget or state target funds;
• public-private partnership (PPP) mechanisms;
• foreign investment or international financial institutions where state guarantees, benefits or other forms of state support are provided.

Projects that do not undergo the required anti-corruption and competition review cannot be approved or moved to the next stage of implementation.

Mandatory anti-corruption examination

 

The regulation establishes a detailed anti-corruption examination process covering the full project lifecycle, including:

• project planning and financing;
• procurement and tender procedures;
• contractor and investor selection;
• contract execution and monitoring phases.

The review is designed to identify corruption risks, conflicts of interest and excessive discretionary powers that may affect project implementation.

The framework specifically assesses:

• transparency of procurement and selection procedures;
• objectivity and clarity of evaluation criteria;
• existence of conflict-of-interest declarations;
• unjustified administrative barriers or discriminatory requirements;
• adequacy of monitoring and reporting mechanisms;
• anti-corruption compliance obligations and contractual safeguards.

The regulation also introduces standardized anti-corruption checklists and formal risk classification categories.

Projects are classified as:

• low risk;
• medium risk;
• high risk.

High-risk projects may receive a negative conclusion and cannot proceed until identified deficiencies are eliminated.

Competition impact assessment

 

In parallel with anti-corruption review, projects must also undergo assessment of their impact on the competitive environment.

The assessment evaluates whether a project could:

• create unjustified market advantages;
• restrict market access;
• establish monopolistic conditions;
• provide excessive exclusive rights or preferences;
• distort competition through state support mechanisms.

Particular attention is given to:

• exclusivity arrangements;
• state guarantees and subsidies;
• discriminatory tender conditions;
• restrictions affecting suppliers or market participants;
• barriers to entry for potential competitors.

Projects presenting significant competition risks may also receive negative conclusions unless corrective measures are implemented.

Expanded compliance and governance requirements

 

The framework introduces broader compliance expectations for project participants and state authorities.

Among other things, projects may now require:

• anti-corruption clauses in contracts;
• compliance programs and ethics policies;
• independent monitoring mechanisms;
• public reporting obligations;
• enhanced audit and oversight procedures.

The rules also permit repeated or extraordinary reviews if new corruption or competition risks arise during implementation.

Where serious violations are identified, authorities may:

• suspend financing;
• halt project implementation;
• initiate termination of PPP agreements;
• refer potential competition law violations to the Competition Committee.

Institutional coordination and digitalization

 

The framework requires coordinated review by:

• internal anti-corruption control units;
• anti-monopoly compliance officers;
• relevant state authorities and oversight bodies.

Projects and related documentation must be reviewed within prescribed timeframes, with conclusions becoming mandatory components of approval and financing decisions.

The regulation also introduces formalized reporting templates, standardized checklists and procedural requirements aimed at increasing consistency and transparency in project governance.

Implications

 

The new framework represents a significant development for:

• infrastructure and PPP projects;
• foreign investment transactions involving state support;
• public procurement and concession projects;
• lenders, sponsors and project developers.

The rules substantially increase compliance, governance and disclosure expectations for large-scale investment projects in Uzbekistan.

The regulation entered into force on 8 May 2026.