Uzbekistan has introduced a new regulatory framework requiring large investment projects to undergo mandatory anti-corruption review and assessment of their impact on the competitive environment. The initiative reflects the government’s continued focus on transparency, integrity, and fair competition in the preparation and implementation of strategically significant investments.

The new framework applies across the full lifecycle of qualifying projects from early planning and financing to procurement, implementation, monitoring, and operation.

Scope of Application: Which Projects Are Covered

 

The requirements apply to large investment projects falling within one or more of the following categories:

• projects financed from the State Budget or state-targeted funds;
• projects implemented under public-private partnership (PPP) arrangements;
• projects involving foreign investment or international financial institutions where state guarantees, privileges, or other forms of state support are provided.

This broad scope ensures that projects benefiting from public resources or state support are subject to enhanced oversight and integrity safeguards.

Anti-Corruption Review: Purpose and Content

 

The anti-corruption review is designed as a systematic process for identifying and analyzing corruption risks at all key stages of a project, including:

• planning and structuring;
• financing arrangements;
• procurement procedures;
• implementation and operation;
• ongoing monitoring and oversight.

The review is conducted by the Anti-Corruption Agency and includes the development of practical recommendations aimed at eliminating or mitigating identified risks. The focus is not only on detecting violations, but also on preventing structural vulnerabilities that could give rise to corrupt practices.

Assessment of Impact on the Competitive Environment

 

In parallel with the anti-corruption review, large investment projects are subject to an assessment of their impact on competition. This assessment is carried out by the authority responsible for competition development and consumer protection.

The assessment examines whether a project:

• creates unjustified advantages for specific market participants;
• restricts or distorts competition;
• contributes to the formation or strengthening of monopolistic positions;
• undermines equal market access conditions.

Where risks are identified, measures are proposed to ensure fair competition and a level playing field for all economic entities.

Institutional Roles and Accountability

 

The framework clearly delineates institutional responsibilities:

• the Anti-Corruption Agency is responsible for conducting anti-corruption expertise and monitoring implementation of recommendations;
• the competition authority conducts competitive impact assessments and proposes corrective measures;
• state bodies responsible for approving or financing projects are required to take the findings of both reviews into account in their decision-making.

The conclusions of the anti-corruption review and competition assessment are subject to mandatory consideration when decisions are taken on project approval, funding, or continuation.

Integration into the Investment Decision-Making Process

 

The introduction of mandatory reviews embeds integrity and competition analysis directly into the investment governance framework. This approach ensures that risks are addressed proactively, rather than after issues arise during implementation.

For investors and project sponsors, this means that compliance with anti-corruption and competition standards becomes an integral part of project preparation and documentation.

Implications for Investors and Project Sponsors

 

The new requirements have practical implications for:

• foreign and domestic investors;
• PPP project sponsors;
• lenders and international financial institutions;
• EPC contractors and procurement participants.

Project stakeholders should be prepared to:

• disclose relevant project structures and financing arrangements;
• demonstrate transparency in procurement and contracting;
• incorporate compliance and risk-mitigation measures into project design.

While the framework introduces additional review layers, it also enhances predictability, legal certainty, and long-term sustainability of large investments.

Strategic Significance of the Reform

 

By formalizing anti-corruption and competition review mechanisms for major investment projects, Uzbekistan strengthens investor confidence and aligns its investment governance practices with international standards.

The reform supports the creation of a transparent, competitive, and integrity-driven investment environment, particularly for large-scale projects with significant economic and social impact.

Conclusion

 

The introduction of mandatory anti-corruption and competition review for large investment projects marks an important step in Uzbekistan’s investment and governance reforms. By embedding integrity, accountability, and fair competition into the investment process, the framework enhances the quality of public decision-making and reduces systemic risks.

For investors, early engagement with these requirements will be key to ensuring smooth project approval and successful long-term implementation in Uzbekistan’s evolving investment landscape.