Settling a dispute with a public authority

A dispute with a public authority can be concluded through an administrative complaint, revocation of the act by the authority itself, or a settlement agreement in the administrative court. The choice depends on the required outcome: revoking the decision, reducing a fine, obtaining a payment schedule, restoring a right, and securing performance so that the dispute does not have to be started again.

In brief:

• An administrative complaint is usually filed within 30 days (Article 64 of the Law on Administrative Procedures), and a decision on it is made within 30 working days (Article 67).
• A settlement agreement under the Code of Administrative Court Procedure is possible only where the authority has administrative discretion and mutual concessions are permitted.
• The current Code of Administrative Liability allows a fine to be deferred for up to one month (Article 328); instalments may be available under enforcement rules or a special law.
• For a durable outcome, record the revocation of the disputed act, the new administrative outcome, the time limits for restoring the right, and the documents proving full performance.

Updated: 05 September 2026

How to choose a settlement route

The route is chosen according to the legal outcome required. An act, action, or omission (Article 62 of the Law on Administrative Procedures) may be challenged through the administrative procedure. It is usually not mandatory to apply first to a superior authority: an applicant may go directly to court unless a special law establishes a mandatory pre-trial procedure. The Supreme Court Plenum (paragraph 12) has explained this rule.

The general time limit for applying to the administrative court is six months (Article 186 of the CACP) from receipt of information about the violation. The court evaluates whether there is a valid reason for missing the deadline. Negotiations should not be used as a reason for inaction until the deadline expires: file the complaint or application on time and continue negotiations in parallel.

This article does not cover a private dispute between companies. The article on a commercial dispute settlement explains mediation, debt restructuring, and settlement in the economic court; it applies when the respondent is a counterparty rather than an administrative authority.

How to complain to a superior authority

A complaint is addressed to a superior or other authorised authority through the authority that issued the disputed act or performed the action. The receiving authority must forward the complaint with the administrative file within three working days (Article 63 of the Law on Administrative Procedures).

A complaint may be written, oral, or electronic. It must contain the required information (Article 65):

• the name of the authority that issued the act;
• the applicant’s or representative’s details and address or, for a company, its name and postal address;
• the applicant’s requests;
• a list of attached documents;
• the filing date.

The applicant or representative signs the complaint. A representative attaches a power of attorney or other proof of authority. An electronic complaint requires an email address, a unified identifier, and, when required by law, an electronic digital signature.

The superior authority reviews the case in full (Article 66), so the complaint should ask it to examine any formal error, the authority’s competence, the evidence, the calculation of the amount, proportionality, and the act’s consequences. The review may result in one of four decisions (Article 69):

• leave the act unchanged;
• amend the act;
• revoke the act and, if necessary, issue a new one;
• require the lower authority to issue a specific act or perform a specific action.

If the applicant is dissatisfied with the outcome, the complaint decision may be challenged in court within the thirty calendar days stated in Article 69, unless the law sets another period. If the superior authority fails to decide the complaint within the prescribed period, its omission may also be challenged in court.

When the authority may revoke its own act

An authority may correct the dispute without a court decision. An act may be revoked or amended by the authority that issued it, a superior authority, or another authority in cases prescribed by law. This can be done on the authority’s own initiative when legislation changes, public interests are threatened, illegality is discovered, or in other cases established by law. An unlawful act must be revoked or amended (Article 59 of the Law on Administrative Procedures).

Restrictions that protect the addressee apply to a favourable act. The law protects a good-faith person’s reliance on the decision (Article 11-1 of the CACP). If the person has already used the property or right granted, entered into a transaction, or otherwise relied on the benefit, revocation in some cases must be decided by a court. Protection does not apply, for example, in cases of fraud, awareness of the illegality, failure to perform additional duties, or a direct statutory requirement to revoke the act.

Revocation in favour of the interested person may be carried out without a hearing. If revocation is adverse to that person’s interests, the act is reviewed at a hearing (Article 60), unless a special law provides otherwise. The new act should expressly identify which part of the previous act ceases to have effect and from what date.

The phrase “the act is revoked” is insufficient where money has already been withheld, a licence cancelled, or an entry made in a register on its basis. Termination of the act also terminates documents issued under it (Article 58), but each restorative action and refund should be listed separately with the responsible person and deadline.

How to settle under the CACP

A settlement agreement under the Code of Administrative Court Procedure of the Republic of Uzbekistan (CACP) is possible at any stage of the case and during enforcement of the judicial act. It is permitted only when the respondent has administrative discretion (Article 126-1 of the CACP), concerns the parties’ rights and duties in the disputed public-law relationship, and involves permissible mutual concessions.

An agreement cannot be made for the listed exclusions (Article 27 of the CACP):

• a challenge to a departmental regulatory act;
• a challenge to decisions of election or referendum commissions;
• a challenge to refusal of a notarial act, registration of a civil-status record, or the related action or omission;
• an appeal against refusal or evasion of state registration.

Terms affecting the rights of third parties are also impermissible. Reconciliation with the victim in certain administrative-offence cases is a different procedure under the CAL, not a settlement agreement with an administrative authority under the CACP.

The written agreement must be enforceable and contain the terms, procedure, and deadlines (Article 126-2 of the CACP), as well as an allocation of legal costs. The parties’ duties cannot be made dependent on each other or on a future event. The number of signed copies must exceed the number of parties to the agreement by one: the additional copy remains in the case file.

A general litigation power of attorney does not include the power to settle (Article 62 of the CACP). The representative’s specific authority should therefore be verified, or the represented person should sign the agreement personally.

The court considers the matter with mandatory participation of the parties and reviews the circumstances, arguments, and evidence. At the enforcement stage, the first-instance court approves the agreement within 15 days (Article 126-3). The court cannot rewrite or partially approve the agreement, but it may propose removing unlawful terms.

The court will refuse approval if the agreement fails five requirements (Article 126-5):

• it contradicts legislation;
• it affects third parties’ rights or legitimate interests;
• it is unrelated to the subject matter of the case;
• it is made when the respondent has no discretion;
• it is conditional.

When approving the settlement agreement, the court terminates the proceedings (Article 108 of the CACP). The applicant’s simple withdrawal of the claim may also terminate the case, but it does not record reciprocal duties of the authority and is therefore usually weaker than an approved agreement for a final settlement.

How to reduce a fine

First identify the nature of the penalty: an administrative fine under the CAL, a financial fine imposed on a business, or a special tax, customs, or licensing sanction. An administrative penalty takes account of the nature of the violation (Article 30 of the CAL), the person’s circumstances, degree of fault, and mitigating and aggravating circumstances.

The mitigating circumstances (Article 31 of the CAL) include:

• sincere remorse;
• prevention of harmful consequences, voluntary compensation for loss, or remedying the harm;
• strong emotional distress or difficult personal, family, or other circumstances;
• threat, coercion, or official, financial, or other dependence;
• minority;
• pregnancy or raising a child under fourteen alone.

The authority or court may recognise other proven circumstances as mitigating. The court may impose a penalty below the statutory minimum (Article 33) or apply a more lenient type. If another authority is hearing the case, it submits the issue to the court, which considers it within three days (Article 308-1). For a minor violation, the court may limit the penalty to a warning (Article 21).

If the fine has already been imposed, the appeal may request revocation of the decision and termination of the case, remittal for reconsideration, or modification of the penalty without making it more severe. Grounds include an incomplete or one-sided review, inconsistency with the facts or law, a material procedural violation, and an unjust penalty (Article 321).

Simplified payment is also available: payment of 50 per cent within 15 days (Article 332-1) or 70 per cent within 30 days releases the person from the balance. This procedure does not apply to offences under Articles 131, 132, 136, 140, and the third part of Article 211 of the CAL, where an appeal or protest is filed, or where the same violation is repeated within one year.

Example. If an administrative fine of UZS 10,000,000 is imposed and Article 332-1 of the CAL applies, 50 per cent is UZS 5,000,000. Filing an appeal removes the simplified-payment option, so the expected outcome of the appeal should first be compared with the available discount.

How to obtain a deferral or instalments

Under the current CAL, the authority that issued the decision may grant only a deferral of an administrative fine for up to one month where immediate enforcement is impossible; a fine collected at the place of the offence is excluded. Instalments become available at the enforcement stage or under a special sector rule.

An authority’s decision in an administrative-offence case is an enforceable instrument (Article 5 of the Law on Enforcement of Judicial Acts and Acts of Other Bodies). Where there are objective obstacles, the state enforcement officer, creditor, or debtor may ask the court or the body that issued the enforcement document for a deferral or instalments (Article 32). During a deferral, enforcement action is not taken for the specified period, but an account attachment is removed only where the decision expressly says so. Under an instalment order, recovery proceeds in the specified parts and by the specified deadlines.

For recovery into state revenue in the interests of a debtor-business, the Business Ombudsman, the Chamber of Commerce and Industry, and their territorial divisions may also file this application. The application should include documents on cash flow, mandatory expenses, assets, the amount already paid, and a realistic schedule.

Special tax deadlines, interest, and security are not covered here. The articles on tax authority appeals and tax payment extensions explain the tax procedure; they apply where the dispute arose from an audit or tax debt.

How to suspend enforcement of the act

Registration of an administrative complaint generally suspends the act and enforcement (Article 70 of the Law on Administrative Procedures). A special law may establish an exception, so obtain confirmation of registration and check the sector-specific rule.

The court may grant preliminary protection measures. They are available where there is a clear risk of infringement or where protection without them would be impossible or difficult, and may be granted at any stage (Article 92 of the CACP). The court may grant one or more measures (Article 93):

• prohibit the respondent from taking specified action;
• prohibit other persons from taking action related to the subject matter of the dispute;
• suspend the sale of property;
• suspend enforcement of the disputed act in full or in part;
• attach the respondent’s property or funds.

The request may be included in the court complaint or filed later. It must contain the reasons and requested measure (Article 94), as well as details of the court, parties, subject matter, and attachments. A request filed with the complaint is decided when the case is accepted, a request made at a hearing is decided at that hearing, and a later request is decided by the next day (Article 95). The order is enforced immediately (Article 97).

How to secure the outcome and prevent reissue

An authority cannot be completely prohibited from issuing any lawful act in the future: the facts, law, or public interest may change. The purpose of final settlement is to prevent repetition of the same decision on the same facts and to eliminate every consequence of the previous act.

The complaint decision, new administrative act, or draft settlement agreement should therefore record:

1. The full details of the act being revoked, the part revoked, and the moment it ceases to have effect.
2. The factual and legal grounds for the outcome. An administrative act must have descriptive, reasoning, and operative parts (Article 53 of the Law on Administrative Procedures), and in court the authority itself proves legality and its grounds (Article 67 of the CACP).
3. A new positive administrative outcome: restoration of a licence, removal of an entry, acceptance of an application, return of a document, or another act concerning the subject matter. An existing act of the same authority in a case with the same parties, subject matter, and grounds requires it to terminate the new procedure (Article 39).
4. Every restorative action, the responsible person, the deadline, the method of confirmation, and the treatment of money, documents, restrictions, and register entries.
5. Unconditional duties. Wording that “the authority will revoke the act if the applicant then performs another action” risks violating the prohibition on a conditional settlement agreement.
6. Procedural closure: approval of the agreement and termination of the case instead of only a letter stating that there are no objections or the applicant’s withdrawal of the complaint.

If the court declares the act invalid, it orders the authority to restore the right and report performance to the court and applicant within one month (Article 189 of the CACP), unless another period is set. Specific measures should be requested because the Plenum requires courts to identify the steps for complete restoration (paragraph 23).

After approval of the agreement and termination of the case, a new court application between the same persons concerning the same subject matter and on the same grounds is not permitted (Article 109 of the CACP). This procedural bar applies to repeat court proceedings. Protection against a repeat administrative act comes primarily from a complete new act on the merits, recorded grounds, and completed restorative measures.

How to enforce the agreement and recover money

The court order approving the settlement agreement contains its terms, the allocation of costs, and termination of the case. The agreement is first performed voluntarily and, if breached, is enforced under the CACP (Article 126-4). The authority performs a final judicial act within one month (Article 276), unless the court sets another period; the court issues a writ of execution for recovery of money.

If the authority fails to perform its own administrative act within the specified period or, where no period is specified, within ten days (Article 82 of the Law on Administrative Procedures), the omission may be challenged in the same way as the act. If a court decision is not performed, the court supervises the outcome, fines the official, and sets a new period of up to one month; a second fine is ten times the original amount (paragraph 25 of the Plenum resolution).

Revocation of an administrative-offence decision with termination of the case entails repayment of recovered amounts (Article 324 of the CAL), return of items, and removal of related restrictions. If an item intended for business use cannot be returned, its value and lost profit are compensated.

The agreement should allocate costs expressly. If the authority voluntarily satisfies the claims after the court application has already been filed, costs are charged to the respondent (Article 115 of the CACP). Do not assume that the state fee is automatically refunded from the budget: the general list of refund grounds (Article 18 of the Law on State Duty) does not separately mention approval of a settlement agreement.

What changed in 2026

• Supreme Court Plenum Resolution No. 19 of 3 July 2026 clarified that an applicant seeking preliminary protection does not have to prove the merits of the claim. The court examines the statutory ground, necessity, connection between the measure and the dispute, and proportionality.
• Under Presidential Resolution PP-138 of 15 April 2026, from 1 October 2026 a business will be able to choose voluntary payment of 50 per cent of a financial fine within one month or six equal monthly payments. The instalment arrangement will start with payment of one sixth of the amount within that month.
• The same future procedure will require a financial fine and penalty cancelled by a court to be repaid within 15 days. Interest equal to one three-hundredth of the Central Bank base rate will accrue for each day of delay.

Example. For a financial fine of UZS 60,000,000, from 1 October 2026 the first payment for automatic instalments will be UZS 10,000,000: 60,000,000 / 6. The alternative is to pay UZS 30,000,000, or 50 per cent, within one month and be released from the balance.

What to check before closing the dispute

Before withdrawing the complaint or signing the agreement, compare the document with the actual outcome. The dispute file should retain:

• the disputed act and the complete administrative case file;
• proof of the date the act was received, registration of the complaint, and suspension of enforcement;
• documents supporting every argument on illegality, the fine calculation, mitigating circumstances, or inability to pay at once;
• a power of attorney covering the chosen procedural action;
• the final act revoking or amending the decision, a new administrative act, or the signed settlement agreement;
• the court order approving the agreement and terminating the case;
• payment documents, register extracts, returned originals, and other proof of performance.

Withdrawal of the complaint is safe only after checking that restorative actions have already been completed or included in an enforceable judicial act. If the authority promises to carry them out later, the agreement must identify every action, deadline, and document that will confirm performance.

Frequently asked questions

Must I complain to a superior authority first?

As a general rule, no: an application may be made directly to the administrative court. A special law may nevertheless establish mandatory pre-trial review for a particular category of acts. The sector-specific rule and deadline should be checked before choosing the route. If an administrative complaint is filed, it is submitted through the authority that issued the act, and the general time limit is thirty days from proper notification.

Does a complaint suspend the act?

An administrative complaint generally suspends the operation and enforcement of the act from registration. A special law may establish an exception. Applying to court does not cause automatic suspension under the general CACP rule, so a request for preliminary protection is usually filed with the complaint to suspend the disputed act in full or in part.

May the authority reissue a revoked act?

Revocation alone does not create an absolute prohibition on a future act. To avoid the same decision on the same facts, record the factual and legal grounds for revocation, issue a new act on the merits, reverse every consequence, and close the case through an approved agreement or judicial decision. New facts or a change in law may give the authority a lawful basis for a different decision.

Can an administrative fine be paid in instalments?

The CAL expressly allows the issuing authority to defer enforcement of a fine for up to one month. Instalments may be requested from the court or authority that issued the enforcement document once enforcement has started and objective obstacles exist. Special rules apply to certain tax and other financial sanctions. From 1 October 2026, business financial fines will qualify for automatic six-month instalments after payment of the first one-sixth.

What if the authority breaches the agreement?

Rely on the court order approving the agreement: a settlement agreement not performed voluntarily is enforced under the CACP. A writ of execution is obtained for monetary recovery. For non-monetary duties, the court supervises performance, may fine the official, and may set a new deadline. The agreement’s terms should therefore be unconditional, specific, and verifiable.