Marketplaces in Uzbekistan: platform rules and obligations

A marketplace, an order aggregator and a simple online showcase have different legal regimes. If a service forms orders or contracts, handles payments or manages settlements between a seller and buyer, its model should be built as an electronic trading platform or another e-commerce operator. A site that only displays information without taking part in the transaction may remain an information service.

In brief:

• a platform or aggregator operator must be an Uzbek-resident legal entity
• the service rules should separate the roles of the platform, seller, payment partner and delivery provider
• the offer, acceptance, receipt, transaction archive and refund should operate as one provable process
• personal data and ranking rules require separate internal controls
• before launch, test every actual function and its responsibility rather than relying on the product's label

Updated: 05 September 2026

Platform status and business form

How to identify the service's legal role

E-commerce covers the sale of goods, work or services under an agreement concluded through information systems. The law separately defines an electronic trading platform, its operator and the broader category of e-commerce operators. These core definitions (Article 3 of the Law) attach the regime to what the product actually does, not to the word “marketplace” in its brand.

E-commerce operators include a platform operator, payment service provider, telecommunications operator and an organization that stores electronic documents and messages. The list may be expanded by law. One group of companies can therefore perform several roles, but each service should be described separately: who provides the interface, receives money, stores documents and delivers an order. The operator categories (Article 11 of the Law) help allocate these functions.

A Cabinet resolution distinguishes an operator from an information website. A service that only displays information and assumes no duty to conclude electronic agreements or conduct electronic trading is not an e-commerce operator. By contrast, accepting an order, processing an offer, calculating commission, providing escrow, operating ratings or controlling performance points to an active platform model. Apply this functional test to the entire user journey.

In what form to launch a platform

An operator of an electronic trading platform, order aggregator or digital streaming service must operate as an Uzbek-resident legal entity. The same provision requires a separate account for e-commerce settlements. These model requirements cannot be replaced by a contract with a foreign company if that company actually operates the local platform.

Legal entities and individual entrepreneurs may sell on a platform; self-employed persons may also make retail sales. Merely using an online channel does not impose extra restrictions compared with the same offline activity. Match the seller categories (Article 8 of the Law) to the product range and method of sale.

A seller starts operating after state registration. If a product or service requires a licence, permit or notice, the online format does not remove that sector-specific authorization. The operator should maintain a category matrix recording the document, validity period, verification source, grounds for blocking and readmission procedure. The seller's duties (Article 9 of the Law) also require accurate product information and compliance with restrictions on circulation.

Resolution No. 885 separately instructed the authorities to prepare legislative amendments for an operator notification regime. Its appendix describes proposed requirements, but the instruction itself does not replace a procedure that must be established in the current licensing and notification legislation. A launch should therefore be checked against the current list of regulated activities and the service's actual functions, without treating the project appendix as a stand-alone filing basis.

Platform rules and contracts

What to put in platform rules

A platform operator checks sellers' licences, permits and notices, prevents the sale of prohibited or restricted goods, continuously displays its service agreement and trading rules, and allows users to review all transaction terms. It must announce a suspension or rule change at least thirty days in advance (Article 13 of the Law). Any exception should follow directly from legislation, not merely from an internal policy.

The rules should separate four layers of responsibility: the platform's relationship with the seller, the seller's relationship with the buyer, the payment service and delivery. For each operation, identify the contracting party, point of performance, commission, taxes, grounds for holding money, cancellation, refund, complaint channel and contents of the electronic archive. This prevents an interface, seller's offer and delivery contract from describing three different outcomes.

A general operator discloses its name, legal form, applicable authorizations, services, terms and tariffs. It may not unilaterally alter electronic documents and must protect messages and personal data. Convert these operator duties (Article 12 of the Law) into permanent disclosure cards and a version log rather than a one-off publication.

The information system must register and identify participants, while the relationship with an information intermediary is governed by a public agreement available in the system. This identification rule is supplemented by duties to publish the public agreement, rules and tariffs, and to locate the information system's servers in Uzbekistan. Apply the intermediary requirements together with the newer law and the specific personal-data rules.

A practical platform document set normally contains buyer terms, a seller agreement, a prohibited-goods policy, a seller-verification procedure, ratings and reviews rules, payment terms, a returns procedure, a data policy, a complaints process and a document-change log. Every document should use the same roles and order stages.

How to form the offer and electronic contract

An electronic agreement has the same legal force as a paper one and cannot be invalid merely because of its form. Acceptance may be recorded by an electronic document, a message or conduct expressly specified in the offer. This equal legal force (Article 15 of the Law) requires a provable process, not simply an easy interface.

The offer must identify the seller and its contacts, provide licence or permit details when required, explain how the agreement is concluded, revoked and amended, and state delivery, payment and price terms. Additional terms may be incorporated by a link. Display this offer content (Article 16 of the Law) before the confirmation button and preserve the version that the user saw.

The agreement is concluded when the party that sent the offer receives acceptance. The audit trail should therefore connect the user, seller, product card, price, offer version, confirmation action and event time. The contract formation point (Article 19 of the Law) matters for price changes, cancellation and the start of the delivery period.

Electronic documents must be stored for at least as long as the corresponding paper record. A transaction record should retain messages, operations, the offer, acceptance, date, time and individual identifiers. The retention period (Article 17 of the Law) is supplemented by rules giving the parties access to the archive, protecting it against alteration and allowing transmission only under a law or contract. Archive protection should cover event logs, backups and evidence exports.

How to arrange payments, delivery and returns

Since 1 July 2025, an operator, seller and the service providers named in the resolution have had to use separate bank accounts exclusively for e-commerce settlements. The separate-account rule should appear in the payment map: the buyer's payment, platform commission, seller's proceeds, refund and delivery settlement should not mix with unidentified flows.

The law permits cash through a virtual cash register or electronic terminal, bank transfer and electronic money. These payment methods (Article 22 of the Law) do not release the seller from using a virtual cash register, issuing an electronic receipt and generating an electronic invoice for a sale to a business. The fiscal records (Article 23 of the Law) must be generated for the correct seller even if the payment interface belongs to the platform.

A platform, payment organization or legal entity providing delivery may offer escrow. Money is held until performance is confirmed, accounted for separately by agreement and does not become the provider's property. The escrow rules (Article 24 of the Law) require the terms to describe delivery confirmation, a non-conformity dispute and the release or return of funds.

If no delivery period is agreed, the seller must fulfill the order no later than thirty days (Article 25 of the Law) after receiving acceptance. For defective goods, the law sets replacement periods of seven days, twenty days when a quality check is needed, or one month when an identical product is unavailable. Build these replacement periods (Article 26 of the Law) into complaint handling and seller notifications.

A refund is made through the same method unless the parties agree otherwise, and the seller bears the return costs. A delay carries a penalty of one percent of the refundable amount for each day, capped at the refund itself. The refund rule (Article 27 of the Law).

Example.

If UZS 1,000,000 must be refunded and the seller is five days late, the penalty is UZS 50,000. If the delay continues, the maximum is UZS 1,000,000.

Before checkout, a consumer must see information about the seller, manufacturer or importer, product, price, delivery, payment, applicable authorization, offer period, termination and return location. This pre-contract list (Article 28-1 of the Law) should match the product card, offer and receipt.

Personal data and competition

How to handle personal data

Define a processing basis for every data field. It may be consent, necessity to perform an agreement, a statutory duty or another ground expressly provided by law. The processing grounds (Article 18 of the Law) should not be replaced by one broad consent covering analytics, advertising, delivery and order performance.

The owner and operator must take legal, organizational and technical protection measures and preserve confidentiality. Map these security measures (Article 27 of the Law) to the data life cycle: collection, employee access, transfer to a seller or courier, storage, backup, deletion and incident response.

Cross-border transfers require a separate test. Data may be sent to a country without adequate protection only on a statutory ground, including the data subject's consent or the need to perform an agreement with that person. Check the transfer conditions (Article 15 of the Law) for each cloud service, analytics provider, support tool and foreign group company.

The current localization article requires biometric data, genetic data and telecommunications subscriber data to be stored in Uzbekistan. Other personal data may be stored abroad when the protective mechanisms provided by law are used. Apply these storage rules (Article 27-1 of the Law) to each dataset rather than treating the entire database identically.

What competition law restricts

A platform may sell goods itself, but combining the infrastructure and seller roles calls for neutral access, ranking and data-use rules. A dominant digital platform is expressly prohibited from restricting competition by requiring the use of its data, technologies or digital products. This platform prohibition (Article 18 of the Law) supplements general restrictions on discriminatory terms, tying unrelated obligations and obstructing market access; those examples are not the complete list.

Risk can arise without a formally dominant position. Superior bargaining power exists when the platform can unilaterally influence transaction terms, territory or price. The bargaining-power test (Article 14 of the Law) is especially relevant to commission, mandatory discounts, access to buyer data and priority for the platform's own product.

An e-commerce operator is generally not responsible for legal consequences arising from the content of documents and messages transmitted to it. But this liability boundary (Article 12 of the Law) does not cover the operator's own breach: incorrect platform rules, failure of a payment function it undertook, missing data safeguards or failure to check a seller's authorization. A contract may also expand the operator's assumed responsibility.

What changed recently

Law No. ZRU-1125 of 26 March 2026 amended the personal-data localization article, with the new version effective from 27 March 2026. The data-regime amendment separated mandatory localization for the specified sensitive categories from possible overseas storage of other data with protective mechanisms. Platforms should update their data map, cloud-provider agreements and cross-border transfer notices.

Presidential Resolution No. PP-136 of 13 April 2026 introduced an experiment from 1 July 2026 to 1 July 2028 for special electronic platforms selling goods from bonded warehouses. The experiment conditions apply to a special model involving a register, system integration and customs control; an ordinary marketplace does not receive this regime automatically.

Before a launch or major product change, repeat the functional test: who is the seller, who receives acceptance, who receives the money, who issues the receipt, who stores the archive, who transfers data, who is responsible for delivery and who handles the complaint. Then match each role to the contract, interface, technical audit trail and internal control owner.

Frequently asked questions

Is every online shop a platform operator?

No. A company selling only its own goods is primarily a seller. A platform operator provides the electronic environment for transactions between participants, while an aggregator accepts and processes service orders. An information showcase that only displays information and redirects the user to a seller is another category. Classification depends on the functions in the real user journey, not the site's name.

May a self-employed person sell through a marketplace?

Yes. The law includes self-employed persons among sellers making retail sales on an electronic trading platform. The product or service must still fall within the self-employment regime, and regulated activities remain subject to licences, permits and notices. The platform should verify the seller's status and sector documents before listing the relevant category.

Who is responsible to the buyer for the product and refund?

As a general rule, the seller is responsible for product information, quality, delivery and refunds. The platform is responsible for its own functions and duties, including its service rules, verification of applicable seller authorizations, operation of escrow it provides, retention of electronic records and data protection. If the interface or contract assumes additional obligations, the allocation of responsibility may become broader.

Must all data be stored only in Uzbekistan?

No. The current rule distinguishes categories. Biometric data, genetic data and telecommunications subscriber data must be stored in Uzbekistan. Other personal data may be stored abroad when the statutory protection mechanisms and cross-border transfer rules are met. The decision should follow an inventory of fields, systems, recipients and storage countries.