Why Choose Uzbekistan for Crypto Licensing?
Uzbekistan offers a codified four-licence crypto regime with 0% tax on crypto operations until , supervised by the National Agency of Perspective Projects (NAPP) under Presidential Resolution PP-3832 of . The framework serves a captive 660,000-client domestic market protected by foreign-exchange access blocks, making it a regional Central Asia play rather than an EU-passporting route.[1]
A Codified Regulatory Perimeter Since 2018
Uzbekistan placed crypto-asset activities inside a formal legal perimeter in with PP-3832, well ahead of most emerging-market peers. The regime defines four discrete licence categories (crypto-exchange, crypto-store, crypto-depository, and mining-pool), each with its own fee schedule, monthly operational levy, and scope. Unlike Kazakhstan, which channels crypto activity into the Astana International Financial Centre’s bespoke jurisdiction, Uzbekistan applies its rules across the national territory through NAPP, a presidential agency with direct enforcement reach.[1][2]
0% Tax on Crypto Operations Until 1 January 2028
Operations of legal entities and individuals related to the turnover of crypto-assets are not subject to taxation, and the income received from these operations is not included in the taxable base under PP-3832 Article 3(b). The 0% regime covers corporate income tax, value-added tax, and capital-gains tax for licensed providers and their users.[1] Compare this with Estonia, where MiCA-authorised CASPs pay the 22/78 distributed-profits CIT model, or Labuan, where international companies pay 3% on net audited profits.
A Captive 660,000-Client Domestic Market
From , Uzbek residents may purchase, sell, or exchange crypto-assets only through nationally licensed providers, with access to foreign exchanges blocked at the network level since .[3] Law ZRU-899 of added criminal penalties of up to five years’ imprisonment for unlicensed crypto activity, codified in Criminal Code Articles 278⁸ and 278⁹.[4] As of , the 21 licensed providers serve 663,691 registered clients (661,850 residents) with USD 2 billion in 2025 turnover.[5][6]
PP-359 Stablecoin and Tokenisation Expansion
Presidential Resolution PP-359 of opened a joint NAPP–CBU regulatory sandbox from for stablecoin payments and tokenised securities issued by Uzbek legal entities on licensed exchanges. The resolution also mandates open-banking infrastructure by and targets USD 1 billion in fintech foreign direct investment by 2030.[7] Operators positioning for the stablecoin-payments use case have a six-to-twelve-month window to engage NAPP and the Central Bank of the Republic of Uzbekistan (CBU) before the perimeter ossifies.
Regulatory Framework
The crypto regulatory framework rests on Presidential Resolution PP-3832 “On measures to develop the digital economy and crypto-assets turnover sphere” of ,[1] elaborated through Ministry of Justice registrations 3380 (licensing procedure), 3379 (exchange trading rules), 3388 (fees), 3395 (crypto-store rules), 3409 (sandbox), 3461 (mining permits), 3507 (mining-pool rules), and 3584 (updated fee schedule, registered ).[8] NAPP is the sole crypto regulator; the Central Bank of the Republic of Uzbekistan (CBU) is the AML/CFT umbrella supervisor but not a co-equal crypto authority.
Definition: Crypto Licence in Uzbekistan
A crypto licence in Uzbekistan is one of four activity-specific authorisations issued by NAPP (crypto-exchange, crypto-store, crypto-depository, or mining-pool) under Ministry of Justice registration 3380 of . Licences are issued for an unlimited period to Uzbek-registered legal entities. The licensing perimeter is set by PP-3832 and its successor decrees; the General Prosecutor’s Office Department for Combating Economic Crimes is the financial intelligence unit.
Regulatory History
Uzbekistan’s crypto regime has evolved through four phases. Phase one () introduced PP-3832 and PP-3926, establishing crypto-asset property rights and the original crypto-exchange concept under the predecessor agency, the National Agency for Project Management (NAPM). Phase two () added Ministry of Justice registration 3309, the AML/CFT internal-control rulebook for crypto service providers.[9] Phase three () restructured NAPM into NAPP via Presidential Decree DP-121, established the Special Regulatory Sandbox, and rolled out the operative Ministry of Justice registrations 3380, 3379, 3388, 3395, and 3409 between August and December 2022.[10] Phase four (–) added criminal enforcement through Law ZRU-899, updated state-duty schedules through NAPP Order No. 100 of , and opened the PP-359 stablecoin and tokenisation sandbox.[4][7]
Recent Regulatory Developments
- · Presidential Resolution PP-359 opens joint NAPP–CBU sandbox for stablecoin payments and tokenised securities from ; open-banking deadline .[7]
- · Presidential Decree DP-180 + NAPP Order No. 82 publishes list of crypto-exchanges authorised for the special tax regime for foreign citizens.[11]
- · Ministry of Justice registration 3584 (NAPP Order No. 100): updated state-duty schedule lifting crypto-store one-off fee to 3,700 BRV and mining-pool fee to 3,000 BRV.[8]
- · Presidential Decree UP-108 raises the Base Calculation Value (BRV) from UZS 340,000 to UZS 375,000, mechanically increasing UZS-denominated licence costs.[12]
- · Law ZRU-899 introduces criminal and administrative penalties for unlicensed crypto activity; up to five years’ imprisonment under Criminal Code Article 278⁸.[4]
- · Ministry of Justice registration 3507: Mining-Pool Operating Rules.[13]
- · Ministry of Justice registration 3461: Mining Permits Procedure.[14]
- : Residents-must-use-licensed-CASPs rule from PP-3832 enters force.[1]
Regulatory Overlap
Three regimes overlap with NAPP’s crypto perimeter. AML/CFT obligations under Law No. 660-II of apply to all crypto service providers alongside banks and securities professionals, supervised through the CBU and the General Prosecutor’s Office FIU.[15] Currency-regulation rules administered by the CBU apply to fiat legs of crypto transactions, though licensed CASPs benefit from a PP-3832 exemption for crypto-related conversions. Tax administration sits with the State Tax Committee, which applies the PP-3832 Article 3(b) exemption while monitoring compliance for the 1 January 2028 sunset.
License Types and Activities Covered
NAPP issues four discrete activity-specific licences under Ministry of Justice registration 3380. Each authorises a defined scope of activities, carries its own state duty, monthly operational fee, and substance requirements, and is issued for an unlimited period. There is no umbrella VASP or CASP licence covering multiple activities; operators wanting to combine activities must obtain each licence separately.
Covered Activities
- Crypto-Exchange Licence. Operating an electronic platform for the purchase, sale, and exchange of crypto-assets with order-book matching, serving both legal entities and individuals. Highest-cost category. Three operators licensed as of .[5]
- Crypto-Store Licence. Operating a platform for the purchase and sale of crypto-assets brokered to individuals, online and offline including physical points accepting bank cards and cash. Twelve operators licensed as of .[5]
- Crypto-Depository Licence. Operating a platform for the issuance, initial placement, and storage of crypto-assets, equivalent to a custodian and registrar function. Six operators licensed as of .[5]
- Mining-Pool Licence. Operating a platform for the consolidation of computing power for crypto mining. Distinct from mining itself, which is unlicensed but requires NAPP registration.
What Does NOT Require a NAPP Licence
- Mining as an activity. Mining is registered with NAPP rather than licensed. Only legal entities may mine; solar mining is preferred and tax-advantaged, while grid-connected mining is subject to a double tariff plus peak surcharges. Hidden mining and anonymous-coin mining are prohibited.
- NFT activities on foreign platforms. Resident NFT sales on foreign platforms remain permitted as the sole carve-out from the resident-uses-domestic-CASPs rule.[3]
- Pure technology services. Software development, blockchain analytics, wallet infrastructure not engaged in regulated activities falls outside the perimeter and may pursue IT Park residency instead.
Activity Restrictions
Residents may not issue Stable Tokens (asset- or currency-backed) or Unsecured Tokens outside the PP-359 sandbox; crypto-depositories may not register such issuances. Only certain Utility Tokens (Access and Ticket types) are freely permitted under Ministry of Justice registration 3397 of . From , the PP-359 sandbox opens stablecoins as a means of payment and tokenised shares and bonds issued by Uzbek legal entities, subject to joint NAPP–CBU oversight.[7]
Regulatory Sandbox
The Special Regulation Regime in Crypto-Assets Circulation under Decree DP-121 and Ministry of Justice registration 3409 permits pilots without a full licence, with tax exemptions, customs preferences (except duties on imported hardware and software), and a fixed 7.5% personal income tax on sandbox-employee wages. The first three participants registered in 2023 were Uzinfocom (NFT for “.uz” domains and Token.uz on Ethereum and Arbitrum), Kapital Bank, and Ravnaq Bank (Cryptocard products). PP-359 extends the sandbox to stablecoin payments and tokenised securities from .[7][10]
Requirements
NAPP licensing requires an Uzbek-registered legal entity with paid-up charter capital, fit-and-proper founders and managers, a registered local office, and platform infrastructure physically located in Uzbekistan with five-year data retention. Crypto-exchange applicants face the most demanding capital threshold; other categories carry no numerical charter-capital floor on the NAPP licensing page.
| Requirement | Standard | Crypto-Exchange Specifics |
|---|---|---|
| Legal Entity | Uzbek-registered legal entity (typically LLC / MChJ) | Same |
| Min. Directors | Not specified in primary source; in practice one resident manager | Same |
| Foreign Ownership | Permitted; offshore-registered companies prohibited as shareholders | Same |
| Charter Capital | Not numerically specified for crypto-store / crypto-depository / mining-pool on NAPP page | 5,000 BCV paid-up (~USD 144,000), of which 3,000 BCV (~USD 86,500) reserved in a separate Uzbek commercial-bank account at the date of application |
| Office | Registered office in Uzbekistan | Same |
| Servers | Physical location in Uzbekistan; 5-year data retention | Same |
| Fit-and-Proper | No unspent convictions for economic, corruption, or information crimes among founders and managers | Same |
| Local Senior Staff | Expected in practice; no explicit citizenship rule | Same |
| Name Restrictions | No use of “state”, “government”, “national”, “Uzbekistan”, or Republic-city names in any language | Same |
| Technical | Full KYC, transaction monitoring, FIU reporting; AML/CFT framework under Ministry of Justice registration 3309 | Same |
Fit-and-Proper Assessment
NAPP assesses founders, beneficial owners, the head of the entity, and the head’s deputies. The principal disqualifying conditions are unspent convictions for economic crimes, corruption offences, and information crimes. The second disqualifying condition operates at the shareholder level: companies incorporated in offshore jurisdictions are barred from holding shares in a licensed CASP, irrespective of beneficial ownership transparency. Operators planning to capitalise through an offshore holding vehicle should restructure before filing, since the NAPP review will identify and reject the structure.
Local Presence / Local Representation
A licensed CASP must operate as a registered Uzbek legal entity, with a registered office in Uzbekistan and platform infrastructure on servers physically located in Uzbekistan. Transaction and client data must be retained for five years and made available to state authorities on lawful request. The local-entity requirement applies uniformly across all four licence categories; there is no representative-office or branch route available to foreign operators.
AML/CFT and Travel Rule
AML/CFT obligations sit under Law No. 660-II of , elaborated for CASPs through Ministry of Justice registration 3309 of , the Internal Control Rules for Crypto Service Providers.[9][15] The framework aligns with FATF Recommendation 15 (VASPs) and Recommendation 16 (Travel Rule). Customer identification and verification is mandatory for all clients; transaction monitoring and suspicious-transaction reports flow to the Department for Combating Economic Crimes within the General Prosecutor’s Office, which is the financial intelligence unit. The EAG’s 2022 Mutual Evaluation Report rated Uzbekistan Largely Compliant on Recommendation 15.[16]
Application Process
NAPP applications take 3–6 months end-to-end from entity formation to licence issuance. There is no application fee; state duty is payable on issuance only. Applications are filed directly with NAPP at info@napp.uz, by post, or in person at Nukus street 22, Mirabad district, Tashkent. The application language is Uzbek; supporting documents in other languages require notarised translations.
Pre-Application Engagement
NAPP does not operate a formal pre-application or innovation hub for the full licensing route, but the Ministry of Justice registration 3409 sandbox is available for pilots that need to validate the model before committing to full licensing. Direct engagement with NAPP via email or in-person consultation is the norm for clarifying scope ahead of dossier preparation.
Entity Formation
Forming an Uzbekistan entity is the first step. State registration of a limited-liability company (MChJ) takes 1–2 working days at a state fee of 1 BCV, UZS 375,000 (about USD 30 for residents, USD 300 for non-resident applicants). The entity must be incorporated locally before any NAPP submission.
Dossier Preparation
Compile the full reg. 3380 dossier: corporate constitutional documents, KYC files for founders and managers, AML manual aligned with Ministry of Justice registration 3309, business plan and financial projections, IT architecture documentation, and proof of server location in Uzbekistan. Engaging local counsel familiar with NAPP review patterns shortens this stage materially.
Charter Capital Deployment and Bank Reservation
For a crypto-exchange application, deposit 5,000 BCV (about UZS 1.875 billion / USD 144,000) of paid-up charter capital and reserve 3,000 BCV (about USD 86,500) in a separate Uzbek commercial-bank account in the entity’s name. The reservation must be in place at the date of submission. Other licence categories have no numerical capital floor on the NAPP page; verify with local counsel.
NAPP Review
NAPP reviews the complete dossier and may request supplementary documentation. The agency is statutorily prohibited from requiring documents beyond those listed in reg. 3380, which limits the surface area for delays where the initial dossier is complete. Incomplete dossiers are routinely returned and reset the review clock.
State-Duty Payment and Licence Issuance
Pay the one-time state duty per the December 2024 fee schedule (see Section 7) and receive the licence. The licence is issued for an unlimited period; there is no fixed renewal cycle, though the monthly operational fee is payable in advance by the 10th of each month from the issuance date.
Jagelski & Partners coordinates the full NAPP application end-to-end through its licensing partners: entity formation, charter-capital reservation, dossier compilation aligned with Ministry of Justice registration 3380, AML manual drafting per registration 3309, and post-issuance compliance support. The compliance documentation package and IT-substance review are the two stages where independent specialist support most reliably shortens the timeline.
Required Documents
Crypto-licence applications under Ministry of Justice registration 3380 require a defined dossier of corporate, governance, technical, and AML/CFT documents. NAPP cannot lawfully require documents beyond those enumerated in the registration, which gives well-prepared applicants a predictable review surface.
| Document | Purpose |
|---|---|
| Corporate constitutional documents (charter, certificate of incorporation, register of members) | Establishes the Uzbek legal entity |
| Beneficial ownership disclosure for all founders and shareholders ≥ 5% | NAPP fit-and-proper review |
| KYC files for founders, head, and deputies (passport, no-conviction certificates, CV) | Fit-and-proper at the natural-person level |
| Confirmation of charter-capital deposit | Capital adequacy (crypto-exchange) |
| Bank confirmation of 3,000 BCV reserved account | Capital adequacy (crypto-exchange) |
| Business plan (services, target customers, revenue projection, capital adequacy) | Commercial substance review |
| AML/CFT internal control rules per Ministry of Justice registration 3309 | AML/CFT compliance |
| IT architecture documentation (system diagrams, security framework, server location proof) | Technical substance review |
| Data-retention plan (5-year retention; state-authority access framework) | Operational compliance |
| Proof of registered office in Uzbekistan | Local presence |
| Proof of payment of state duty (on issuance) | Fee compliance |
| Notarised translations into Uzbek for foreign-language documents | Procedural |
Compliance Documentation Drafting
Jagelski & Partners coordinates the drafting and assembly of the full reg. 3380 documentation pack through its licensing partners, sequencing the AML manual aligned with Ministry of Justice registration 3309, the IT-architecture and server-location proof, business plan, and fit-and-proper files so the dossier opens with a complete record. Drafting Uzbek-specific procedures referencing the operative Ministry of Justice registrations by number, rather than adapting a generic template, is the most reliable predictor of a clean NAPP review.
Costs and Pricing
Crypto licence costs in Uzbekistan are anchored on two figures from the Ministry of Justice registration 3584 of (NAPP Order No. 100 of ): a one-time state duty payable on issuance, and a monthly operational fee payable in advance from the licence-issuance date.[8] The Base Calculation Value (BRV / BCV) is UZS 375,000 from per Presidential Decree UP-108 of .[12]
Government / NAPP Fees
| Licence | One-time state duty | Monthly operational fee |
|---|---|---|
| Crypto-Exchange | ≈ USD 2,117,00073,400 BRV · UZS 27,525,000,000 | ≈ USD 21,500740 BEU · UZS 277,500,000 |
| Crypto-Depository | ≈ USD 202,0007,000 BRV · UZS 2,625,000,000 | ≈ USD 1445 BEU · UZS 1,875,000 |
| Crypto-Store | ≈ USD 107,0003,700 BRV · UZS 1,387,500,000 | ≈ USD 5,300185 BEU · UZS 69,375,000 |
| Mining-Pool | ≈ USD 87,0003,000 BRV · UZS 1,125,000,000 | ≈ USD 2,900100 BEU · UZS 37,500,000 |
State duty is distributed 80% to the State Budget and 20% to NAPP. The fee was last updated in the December 2024 NAPP Order No. 100 (crypto-store raised from 2,600 BRV; mining-pool raised from 1,900 BRV). USD conversions assume the CBU reference rate of ~13,000 UZS/USD as of mid-2025; the rate fluctuates and should be reconfirmed at application.
Total Cost Summary
| Cost Line | Crypto-Exchange | Crypto-Store | Crypto-Depository | Mining-Pool |
|---|---|---|---|---|
| One-time state duty | ~USD 2,117,000 | ~USD 107,000 | ~USD 202,000 | ~USD 87,000 |
| Charter capital deployment | ~USD 144,000 (5,000 BCV) | Not specified | Not specified | Not specified |
| Entity formation + corporate services | ~USD 1,500–3,000 | ~USD 1,500–3,000 | ~USD 1,500–3,000 | ~USD 1,500–3,000 |
| Legal advisory (dossier, AML manual) | ~USD 35,000–60,000 | ~USD 25,000–45,000 | ~USD 30,000–50,000 | ~USD 25,000–40,000 |
| Compliance documentation (AML manual, risk assessment, sanctions framework, Travel Rule SOPs) | ~USD 15,000–25,000 | ~USD 15,000–25,000 | ~USD 15,000–25,000 | ~USD 15,000–25,000 |
| IT setup (servers in Uzbekistan, 5-yr retention infrastructure) | ~USD 80,000–150,000 | ~USD 25,000–60,000 | ~USD 40,000–80,000 | ~USD 30,000–60,000 |
| Local representative / office (Year 1) | ~USD 8,000–15,000 | ~USD 6,000–12,000 | ~USD 6,000–12,000 | ~USD 6,000–12,000 |
| Monthly operational fee × 12 | ~USD 258,000 | ~USD 64,000 | ~USD 1,700 | ~USD 35,000 |
| Total Year 1 | ~USD 2,650,000–2,800,000 | ~USD 240,000–310,000 | ~USD 295,000–375,000 | ~USD 200,000–260,000 |
| Annual ongoing cost (Year 2+) | ~USD 320,000–380,000 | ~USD 90,000–115,000 | ~USD 20,000–35,000 | ~USD 55,000–75,000 |
Licences are issued for an unlimited period; there is no fixed annual renewal fee, but the monthly operational fee continues for the life of the licence. Charter-capital figures for crypto-store, crypto-depository, and mining-pool are not numerically specified on the NAPP licensing page; some consultancies cite a 300,000 dollar minimum, but this cannot be confirmed against NAPP, so verify with local counsel before relying on it.
Timeline
NAPP licensing takes 3–6 months end-to-end. The realistic distribution across the five application stages is shown below, with the bank-reservation and NAPP-review stages typically the longest variable.
| Stage | Duration | Cumulative |
|---|---|---|
| Entity formation (MChJ registration) | 1–2 working days | Week 1 |
| Dossier preparation | 4–8 weeks | Week 2–10 |
| Charter-capital deployment + bank reservation | 2–4 weeks | Week 10–14 |
| NAPP review | 4–13 weeks | Week 14–27 |
| State-duty payment + licence issuance | 1–2 weeks | Week 27–29 |
| Total | 3–6 months | Week 12–29 |
NAPP processed 21 licences cumulatively between 2022 and , with monthly issuance running at roughly one licence per month across all four categories.[5] The pace is rising as the regime matures and the December 2024 fee schedule reduced applications from speculative entrants. Crypto-exchange reviews tend to run longer than crypto-store reviews because the capital-reservation and technical-substance documentation is more demanding.
Taxation
Uzbekistan is a zero-tax jurisdiction for crypto activities of licensed CASPs and their users until , anchored in PP-3832 Article 3(b).[1] Uzbekistan has not enacted domestic Pillar Two legislation; the OECD Global Minimum Tax applies only to multinational groups with consolidated revenue exceeding EUR 750 million, a threshold unlikely to affect standalone Uzbekistan-domiciled CASPs.
| Tax | Rate | Crypto Application |
|---|---|---|
| Corporate Income Tax | 15% standard | 0% on crypto operations of licensed CASPs (PP-3832 Article 3(b)) until |
| Capital Gains Tax | None on crypto | Crypto disposals not taxable for individuals or licensed CASPs |
| Value-Added Tax | 12% standard | 0% on crypto trades and CASP operations |
| Withholding Tax | 10% (royalties/interest); 15% (dividends) | Standard rates apply to non-crypto income flows |
| Payroll Tax | 12% PIT standard | 7.5% PIT for sandbox-resident employees |
| Stamp Duty | None on crypto operations | Not applicable |
The IT Park Uzbekistan Special Regime
IT Park Uzbekistan offers a parallel zero-tax regime extended to for technology businesses: 0% corporate income tax, 0% VAT, 0% social tax, 7.5% personal income tax for resident employees, 5% dividend tax for non-resident founders, and customs-duty exemption on imported equipment until .[17] Crypto-exchange and CASP activity is not on IT Park’s permitted core-activity list, so the licensed CASP entity sits outside IT Park under NAPP’s 0% crypto regime; the technology arm of a crypto group may reside in IT Park and complement (not overlap with) the CASP entity. Operators should confirm direct CASP eligibility with both NAPP and IT Park; the relationship is not crystal-clear in primary sources.
CRS/CARF Reporting
Uzbekistan is a participating jurisdiction in the OECD Crypto-Asset Reporting Framework (CARF) timeline and continues to expand Common Reporting Standard (CRS) coverage. Licensed CASPs should expect to be brought into the CARF reporting perimeter ahead of the first multilateral exchange in , with domestic implementing legislation expected to follow the OECD model rules. As of , Uzbekistan has not published the final domestic CARF implementing instrument; operators should track NAPP and Ministry of Finance announcements.
Tax-Regime Sunset Risk
The Budget Memorandum for 2025–2027 asked NAPP and the Ministry of Finance to design a phased tax model for crypto operations by Q4 2026, with proposed (not enacted) parameters of 3% retail capital-gains tax and 5% CASP corporate levy. As of , these remain proposals; the 0% regime is confirmed in force until , and any successor regime would require fresh primary legislation. Operators should plan for taxed operations from 2028 onwards in financial models, even though the headline figure today is 0%.
Ongoing Compliance & Post-Registration
A NAPP licence creates a permanent compliance infrastructure obligation: monthly fee payments, annual reporting, AML/CFT monitoring, transaction reporting to the FIU, and a five-year data retention obligation. Licensees are subject to NAPP supervisory inspections and to administrative and criminal penalties for compliance breaches under Law ZRU-899.
The compliance documentation pack required by NAPP includes the AML manual aligned with Ministry of Justice registration 3309, a risk assessment, a sanctions-screening framework, Travel Rule SOPs, and the annual review cycle that ties them to current FATF guidance and EAG-MER findings. Specialist support maintains this pack against successive regulatory updates.
Annual Reporting Obligations
Licensed CASPs file audited financial statements annually with the State Tax Committee and NAPP, with deadlines aligned to the standard Uzbek corporate financial year. The compliance officer files internal AML/CFT reports and threshold transaction reports to the General Prosecutor’s Office FIU on a rolling basis. Annual transaction-volume reporting to NAPP is required for the agency’s published statistics (cumulative client count, turnover, jobs created).
Renewal Fees / Supervision Fees
The NAPP licence is issued for an unlimited period; there is no renewal cycle. The monthly operational fee per Ministry of Justice registration 3388 (updated June 2024) is payable in advance by the 10th of each month and runs for the life of the licence: 740 BEU for crypto-exchange, 185 BEU for crypto-store, 100 BEU for mining-pool, and 5 BEU for crypto-depository. Recurring costs additional to NAPP fees include accounting and audit (~USD 8,000–20,000 per year), local representative or office (~USD 6,000–15,000 per year), and compliance support (~USD 25,000–60,000 per year depending on transaction volume).
Regulatory Inspections
NAPP conducts scheduled supervisory inspections and is empowered to conduct unannounced inspections where it has reason to believe the licensee is in breach of Ministry of Justice registration 3380 or related instruments. Thematic reviews in 2024–2025 focused on Travel Rule implementation, server-localisation compliance, and KYC documentation. NAPP requested blocking of over 3,000 online resources in 2025 and fined three to four foreign crypto platforms (identities not publicly disclosed).[5]
Enforcement
Operating a crypto-related business without the appropriate NAPP licence carries criminal penalties under Law ZRU-899: fines, administrative arrest, restriction of freedom, and up to five years’ imprisonment for repeat or organised offences under Criminal Code Article 278⁸. Administrative penalties under Article 278⁹ apply to lesser breaches. NAPP fined Binance UZS 99 million (~USD 7,300) in for unauthorised provision of services to Uzbek residents; Binance subsequently entered the market through a licensed local partner in .[3][18]
Advertising and Promotion Rules
Licensed CASPs must include risk warnings in promotional material; advertising cannot guarantee returns or present crypto as a quick-wealth route. NAPP exercises supervisory authority over CASP advertising practice as part of its general supervisory mandate. Specific penalty amounts for advertising breaches are administered under the Code on Administrative Responsibility.
Banking
Banking access for Uzbekistan-licensed CASPs is structurally different from EU or offshore-licensed counterparts: licensed CASPs operate within a domestic banking system supervised by the CBU, with the UZS as the principal settlement currency. PP-3832 Article 3 exempts licensed CASPs from currency-regulation norms for crypto-related conversions, which materially eases multi-currency operational flow inside Uzbekistan.
Jagelski & Partners’ banking network supports Uzbekistan-licensed CASPs with pre-qualified onboarding routes across Uzbek commercial banks and Central Asian correspondent partners, working alongside the licensing service to align the banking timeline with the NAPP application cycle. Open a corporate banking pathway for your Uzbekistan-licensed entity →
The Local Banking Landscape
The Uzbek commercial banking sector is the primary settlement venue for licensed CASPs, with multiple banks now offering crypto-business accounts. Sandbox commercial banks have launched specialised products, for example Kapital Bank and Ravnaq Bank operate Cryptocard products under the Ministry of Justice registration 3409 sandbox.[10] The CBU has progressively relaxed bank engagement with the regulated crypto sector while maintaining tight prudential oversight.
Cross-Border Settlement
Uzbekistan is not on the FATF grey or black list, which materially eases correspondent banking relationships compared with higher-risk jurisdictions. Cross-border USD settlement for licensed CASPs is feasible through tier-2 Central Asian and selected Western correspondent banks, with documentary requirements proportionate to a clean-status jurisdiction. UZS has depreciated steadily against USD since the 2017 currency liberalisation; charter-capital buffers should be sized with this trend in mind.
Open Banking from September 2026
Presidential Resolution PP-359 mandates open-banking infrastructure by , with a standardised data-exchange layer between licensed financial institutions and authorised third-party providers.[7] For licensed CASPs, this is the foundation for tokenised-securities flows on licensed exchanges and stablecoin-payment integrations under the joint NAPP–CBU sandbox.
For an Uzbekistan-licensed CASP the architecture is domestic-first: UZS settlement through CBU-supervised commercial banks, Central Asian correspondent partners for regional flows, and tier-2 Western correspondents for USD legs, aligned with the NAPP application cycle. The partner network maintains live account-opening routes in every jurisdiction Jagelski & Partners services, and banking feasibility is confirmed at the scoping stage, before any licence application is filed.
Explore Banking SolutionsFATF Status & International Standing
Uzbekistan is a member of the Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG), a FATF-style regional body, and is not on the FATF grey or black list as of . The country sits in the regular follow-up category, having been upgraded from enhanced follow-up in 2023.
2022 Mutual Evaluation Report
The EAG conducted an on-site visit from to ; the MER was adopted in 2022.[16] Uzbekistan was rated Compliant or Largely Compliant on most FATF Recommendations, including a Largely Compliant rating on Recommendation 15 (Virtual Asset Service Providers).
2023 First Enhanced Follow-Up Report
The 2023 First Enhanced Follow-Up Report upgraded ratings on Recommendations 6, 7, and 22 from Partially Compliant to Largely Compliant, and transferred Uzbekistan from enhanced to regular follow-up.[19] Regular follow-up is the lower-frequency, less-intrusive supervisory category; transfers from enhanced to regular signal sustained improvement and reduce the reputational drag on cross-border banking.
No EU Passporting
Uzbekistan is a non-EU, non-EEA third country, and there is no equivalence or recognition regime for third-country crypto licences under MiCA (Regulation (EU) 2023/1114). For a detailed analysis of what constitutes solicitation and the documentation requirements under the third-country exemption, see Reverse Solicitation Under MiCA →.
Advantages and Limitations
Uzbekistan offers a codified four-licence regime, a 0% tax window until 2028, and a captive 660,000-client domestic market, but operators trade EU passporting, reputational tier, and certain entry-cost economics for those advantages. Every limitation below carries a mitigation strategy.
- 0% tax on crypto operations until 1 January 2028. No corporate income tax, no VAT, no capital-gains tax, among the lowest globally, anchored in PP-3832 Article 3(b).
- Codified four-licence taxonomy. Uzbekistan placed crypto in a formal legal perimeter from the outset, not legalised retroactively.
- Captive 660,000-client domestic market. Foreign exchanges blocked since August 2022; resident transactions criminalised outside licensed channels.
- Not on FATF grey or black list. EAG regular follow-up since 2023; Largely Compliant on R.15 (VASPs).
- Strong government strategic backing. Digital Uzbekistan 2030; PP-359 (November 2025) materially expands the perimeter; NAPP reports directly to the President.
- Reasonable cost for crypto-store and mining-pool licences. USD 100,000–300,000 total Year 1 range is competitive with mid-tier European regimes.
- Active regulatory sandbox. No-licence pilot route with tax preferences; stablecoin and tokenised-securities expansion from January 2026.
- No EU passporting. An Uzbekistan licence does not grant EU market access. Mitigation: Operators targeting EU clients can obtain a separate CASP authorisation in an EU member state (full market access via passporting) or, for isolated genuinely unsolicited contacts only, may fall within the narrow reverse solicitation exemption under MiCA Article 61.
- Crypto-exchange entry cost is extraordinarily high. USD ~2.1 million one-time state duty plus USD ~21,500/month is among the highest globally. Mitigation: Target the crypto-store or mining-pool category if the business model permits; both have realistic Year 1 totals under USD 310,000.
- Reputational tier is emerging-market. Less prestigious than EU MiCA or Singapore MAS. Mitigation: Position the entity as a regional Central Asia operator; pair the Uzbekistan licence with an EU CASP authorisation if reputational signalling matters for the customer base.
- Local-presence burden. Mandatory Uzbek LLC, servers in Uzbekistan, 5-year data retention, name restrictions. Mitigation: Plan IT architecture for Uzbek hosting from day one; budget USD 25,000–150,000 for substance setup depending on category.
- Tax-regime sunset risk. The 0% regime is confirmed only until 1 January 2028. Mitigation: Build forward financial models assuming taxed operations from 2028 onwards; track Q4 2026 NAPP / Ministry of Finance policy announcements.
- Restrictive token taxonomy outside the sandbox. Residents barred from issuing Stable Tokens or Unsecured Tokens outside the PP-359 sandbox. Mitigation: Apply to the joint NAPP–CBU sandbox early if the model depends on stablecoin or tokenised-security issuance.
- Criminal exposure for non-compliance. Law ZRU-899 carries up to 5 years’ imprisonment. Mitigation: Operate strictly inside the licensed perimeter; do not market to Uzbek residents from a foreign entity.
How Uzbekistan Compares
Uzbekistan competes for Central Asia operator flow against Kazakhstan (AIFC bespoke regime), Kyrgyzstan (recently established crypto framework), and Labuan (Malaysian APAC alternative at comparable cost). Estonia is the natural cross-tier reference for operators considering an EU upgrade.
| Factor | Uzbekistan | Kazakhstan (AIFC) | Kyrgyzstan | Labuan (Malaysia) |
|---|---|---|---|---|
| Licence Type | Crypto-Exchange / Store / Depository / Mining-Pool (NAPP) | Operating a Digital Asset Trading Facility (AFSA) | VASP licence (Exchange / Trading Operator) | Digital Asset Exchange / Credit Token (Labuan FSA) |
| Regulator | NAPP | AFSA within AIFC | State Service for Regulation and Supervision of the Financial Market | Labuan FSA |
| Timeline | 3–6 months | 6–7 months | 1–3 months | 3–6 months |
| Min. Capital | 5,000 BCV (~USD 144,000) for crypto-exchange | Higher of USD 200,000 or 12 months’ working capital | Exchange Operator ~USD 460,000 | DAX: MYR 5,000,000 (~USD 1,100,000) |
| Total Year 1 Cost | USD 200,000–2,800,000 | USD 200,000–400,000 | USD 50,000–150,000 | USD 80,000–150,000 |
| Corporate Tax | 0% on crypto until 1 Jan 2028 | AIFC participants exempt from CIT until 2066 | Standard CIT; mining 10% electricity tax | 3% on net audited profits (international) |
| Local Presence | Uzbek LE; servers in country; 5-year data retention | AIFC registration with substance | Kyrgyz LLC; ≥2 directors; ≥1 Kyrgyz-resident | Labuan IBC + operational office |
| EU Passporting | No | No | No | No |
| FATF Status | EAG member; not grey-listed; regular follow-up | EAG member; not grey-listed | EAG member; under enhanced monitoring | APG member; FATF-aligned |
| Best For | Central Asia operators with captive-market positioning | Premium AIFC-tier operators | Cost-leader Central Asia entry | APAC-focused operators |
Compare every crypto jurisdiction side by side →
Uzbekistan and Kazakhstan are the two serious Central Asia options, distinguished by cost structure and regulatory architecture: Uzbekistan applies its rules nationally through NAPP, while Kazakhstan channels crypto into the AIFC’s bespoke jurisdiction. Kyrgyzstan is the cost-leader but carries enhanced-monitoring FATF status; Labuan offers APAC-tier credibility at a comparable price point but requires substantially higher charter capital for the exchange tier.
For operators whose primary market is the EU, none of these jurisdictions is the right answer. The natural cross-tier reference is Estonia’s MiCA CASP regime: EUR 50,000–150,000 minimum capital, 22/78 distributed-profits CIT, and full passporting across 30 EEA member states.
When Uzbekistan Is the Right Choice
Choose Uzbekistan if:
- The primary target market is the Uzbek captive 660,000-client base or Central Asia more broadly
- The business model can absorb the local-presence and IT-localisation burden
- You value a clean FATF status and a clearly codified four-licence taxonomy
- You can afford the crypto-store or mining-pool category and do not need the full crypto-exchange tier
Consider alternatives if:
- The EU is the primary target market (Estonia’s MiCA CASP is the natural upgrade)
- The cost ceiling is below USD 200,000 (Kyrgyzstan is the cost leader, FATF status considered)
- APAC presence is a priority (Labuan offers a 3% tax regime and APAC-tier credibility)
- Operating an AIFC-tier exchange is the strategic objective (Kazakhstan AIFC is the regional premium option)
Not sure which column is you? Ask Emma. She compares these jurisdictions in seconds, in your language.
Common Mistakes in Uzbekistan Applications
NAPP’s review patterns and Law ZRU-899’s enforcement reach generate a recurring set of application failures and operational missteps. The following six are the practitioner-level issues that most consistently derail Uzbekistan crypto licensing applications.
- Assuming a single “VASP” licence covers all activities. Each activity (exchange, store, depository, mining-pool) requires its own licence, with separate state duty and monthly fees. A combined exchange-and-custody business needs two licences, not one.
- Underestimating the charter-capital reservation rule. Crypto-exchange applicants must deposit 5,000 BCV paid-up and reserve 3,000 BCV in a separate Uzbek commercial-bank account at the date of application. Credit-funded capital is invalid. Late reservation resets the review clock.
- Using offshore-company shareholders. Companies incorporated in offshore jurisdictions are barred from holding shares in a NAPP-licensed CASP. The structure must be restructured before filing; NAPP review will identify and reject it.
- Failing to localise servers and data. Platform infrastructure must run on servers physically located in Uzbekistan with five-year data retention. Late-stage IT redesigns to meet the localisation requirement add weeks and material cost to the build.
- Marketing to Uzbek residents from a foreign entity. The Binance precedent of January 2024 shows that NAPP exercises enforcement reach against unlicensed foreign providers serving Uzbek residents. Fines, lawsuits, and criminal exposure under Law ZRU-899 follow; entry through a licensed local partner is the only compliant route.
- Confusing IT Park residency with CASP licensing. IT Park’s 0% CIT regime does not extend to licensed crypto-exchange activity; that is NAPP’s 0% regime under PP-3832 Article 3(b). The two are complementary (a tech holding can reside in IT Park while the CASP entity operates under NAPP) but not interchangeable.
Frequently Asked Questions
The National Agency of Perspective Projects (NAPP) is the sole crypto-asset regulator in Uzbekistan. NAPP is a presidential agency established in its current form by Presidential Decree DP-121 of , succeeding the National Agency for Project Management (NAPM). It holds exclusive statutory authority over crypto-asset activities including licensing, supervision, and enforcement. The Central Bank of the Republic of Uzbekistan (CBU) supervises AML/CFT compliance across the financial sector and is the open-banking authority under PP-359, but it does not issue crypto licences. Applications are filed directly with NAPP at info@napp.uz, by post, or in person.
Foreign individuals and non-offshore corporate shareholders can own NAPP-licensed CASPs through an Uzbek legal entity (typically an LLC / MChJ). The licence is issued only to Uzbek-registered legal entities, so foreign ownership operates through a domestic holding structure. Companies incorporated in offshore jurisdictions are barred from holding shares in a licensed CASP, irrespective of beneficial ownership transparency. Operators planning to capitalise through an offshore holding vehicle must restructure before filing. Senior management is expected to include resident staff in practice, though there is no explicit citizenship rule on the NAPP licensing page.
NAPP issues four activity-specific licences under Ministry of Justice registration 3380 of . Crypto-Exchange covers electronic order-book trading platforms (three licensees as of March 2026). Crypto-Store covers retail purchase and sale of crypto-assets brokered to individuals, online and offline (twelve licensees). Crypto-Depository covers issuance, initial placement, and storage of crypto-assets, equivalent to a custodian and registrar function (six licensees). Mining-Pool covers consolidation of computing power for mining. There is no umbrella VASP or CASP licence; operators combining activities must obtain each licence separately.
Through a separate framework. Beyond the NAPP crypto regime, Uzbekistan has introduced a framework for DLT-issued tokenised equities and bonds traded on regulated exchanges from 2026; a tokenised security runs through that securities-side regime, not a generic crypto licence. Where the vehicle is a fund, route via fund licensing.
A realistic timeline is 3–6 months end-to-end from entity formation to licence issuance. Entity registration takes 1–2 working days. Dossier preparation, including the AML manual aligned with Ministry of Justice registration 3309, takes 4–8 weeks. Charter-capital deployment and the 3,000 BCV bank reservation (crypto-exchange applicants only) take 2–4 weeks and must be completed at the date of application. NAPP review runs 1–3 months for a complete dossier and longer where supplementary documentation is needed. State-duty payment and licence issuance run 1–2 weeks at the end.
Yes. The Special Regulation Regime in Crypto-Assets Circulation under Decree DP-121 of and Ministry of Justice registration 3409 of permits pilots without a full NAPP licence, with tax exemptions, customs preferences, and a fixed 7.5% personal income tax on sandbox-employee wages. The first three participants registered in 2023 were Uzinfocom, Kapital Bank, and Ravnaq Bank. PP-359 of extends the sandbox to stablecoin payments and tokenised securities from under joint NAPP–CBU supervision.
The crypto-exchange licence carries a one-time state duty of 73,400 BRV, approximately USD 2.1 million at the 13,000 UZS/USD rate, plus a monthly operational fee of 740 BEU (~USD 21,500 per month). Charter capital is 5,000 BCV (~USD 144,000), of which 3,000 BCV (~USD 86,500) must be reserved in a separate Uzbek commercial-bank account at the date of application. Realistic total Year 1 cost including legal advisory, compliance documentation, IT setup, and local presence is USD 2,650,000–2,800,000. Annual ongoing cost from Year 2 is USD 320,000–380,000. For most operators, the crypto-store or mining-pool licence is materially more economical.
The NAPP licensing page does not specify a numerical charter-capital floor for crypto-store, crypto-depository, or mining-pool licences; the 5,000 BCV figure applies only to crypto-exchange. Some consultancies cite a 300,000 dollar minimum for general VASP applications, but this figure cannot be confirmed against NAPP primary sources and should be verified with local counsel before relying on it for financial planning. The practical minimum is set by Uzbek LLC ordinary share-capital rules, 1 BCV (UZS 375,000, ~USD 30), plus whatever working capital NAPP considers proportionate to the business plan.
Uzbekistan is not on the FATF grey or black list as of . The country is a member of the Eurasian Group on Combating Money Laundering and Financing of Terrorism (EAG), the FATF-style regional body. The 2022 Mutual Evaluation Report rated Uzbekistan Compliant or Largely Compliant on most FATF Recommendations including Largely Compliant on Recommendation 15 (VASPs). The 2023 First Enhanced Follow-Up Report upgraded ratings on Recommendations 6, 7, and 22 and transferred Uzbekistan from enhanced to regular follow-up, the lower-frequency supervisory category, which materially eases correspondent banking relationships.
Yes. Licensed CASPs operate within a domestic banking system supervised by the CBU, with multiple Uzbek commercial banks offering crypto-business accounts. Sandbox banks have launched specialised products. PP-3832 Article 3 exempts licensed CASPs from currency-regulation norms for crypto-related conversions, easing multi-currency operational flow. Cross-border USD settlement is feasible through tier-2 Central Asian and selected Western correspondent banks given Uzbekistan’s clean FATF status. Open-banking infrastructure under PP-359 is due by , which will provide a standardised data-exchange layer between licensed financial institutions and licensed CASPs.
An Uzbekistan licence does not grant EU market access or MiCA passporting rights. Uzbekistan is a non-EU, non-EEA third country, and there is no equivalence regime for third-country crypto licences under MiCA. MiCA Article 61 permits third-country firms to serve EU clients only when the client initiates contact entirely on their own initiative, the reverse-solicitation exemption, but ESMA’s guidelines interpret this very narrowly, and any form of EU-targeted marketing voids it. Operators seeking systematic EU market access must obtain a separate CASP authorisation in an EU member state. See the full reverse solicitation guide for the operational detail.
Law ZRU-899 of added Criminal Code Articles 278⁸ and 278⁹ covering unlicensed crypto activity. Penalties include fines, administrative arrest, restriction of freedom, and up to five years’ imprisonment for repeat or organised offences. NAPP fined Binance UZS 99 million in January 2024 for unauthorised provision of services to Uzbek residents; Binance subsequently entered the market through a licensed local partner. Foreign exchanges are blocked at the network level since August 2022. The compliant route for foreign operators is licensing or partnering with a NAPP-licensed entity.
Presidential Resolution PP-359 of opens a joint NAPP–CBU regulatory sandbox from covering stablecoins as a means of payment and tokenised shares and bonds issued by Uzbek legal entities on licensed exchanges. Sandbox-only at launch, with nationwide rollout dependent on pilot outcomes and subsequent secondary legislation through 2026–2027. The resolution also mandates open-banking infrastructure by and targets USD 1 billion in fintech foreign direct investment by 2030. Operators positioning for stablecoin-payment integrations have a six-to-twelve-month window to engage NAPP and CBU.
Uzbekistan Company Formation
Set up the Uzbek LLC (MChJ) that NAPP licensing requires. State registration in 1–2 working days at a 1 BCV fee.
Open a Banking Pathway for Your CASP
Pre-qualified banking onboarding routes across Uzbek commercial banks and Central Asian correspondent partners.
Start Your Uzbekistan Crypto Licence Application
Jagelski & Partners coordinates the full NAPP licensing process, from entity formation, charter-capital reservation, AML compliance documentation, NAPP submission, and post-licensing banking, through licensing partners who have built and operated regulated crypto businesses.
Not ready to book? Ask Emma first. She answers now, and if it needs a human she takes your details so the consultation starts ahead.
References
Show all references
- Republic of Uzbekistan, Presidential Resolution PP-3832, “On measures to develop the digital economy and the sphere of crypto-assets turnover in the Republic of Uzbekistan”, lex.uz, accessed .
- Republic of Uzbekistan, Presidential Decree DP-121, “On measures for further development of the digital economy and the crypto-assets sphere” (27 April 2022), lex.uz, accessed .
- Cointelegraph, Uzbekistan blocks access to foreign crypto exchanges over unregistered trading, cointelegraph.com, accessed .
- Republic of Uzbekistan, Law ZRU-899, “On amendments and additions to the Criminal Code, Criminal Procedure Code and Code on Administrative Responsibility” (19 January 2024), lex.uz, accessed .
- UzDaily, Uzbekistan Has 21 Crypto Service Providers in 2025, Including Exchanges, Shops, and Depositories (citing NAPP First Deputy Director, 18 March 2026), uzdaily.uz, accessed .
- UzDaily, Uzbekistan’s Crypto Turnover Surpasses US$2 Billion in 2025, uzdaily.uz, accessed .
- Republic of Uzbekistan, Presidential Resolution PP-359, “On measures for the further development of financial technologies in Uzbekistan” (27 November 2025), lex.uz, accessed .
- UzDaily, Fees for issuing licenses to crypto asset service providers established (Ministry of Justice registration 3584, NAPP Order No. 100), uzdaily.uz, accessed .
- Republic of Uzbekistan, Ministry of Justice registration 3309, “Internal Control Rules for Crypto Service Providers” (9 June 2021), lex.uz, accessed .
- National Agency of Perspective Projects, Crypto-asset service providers, napp.uz, accessed .
- National Agency of Perspective Projects, List of specially authorized crypto-exchanges for providing a special tax regime to foreign citizens, napp.uz, accessed .
- KDB Bank Uzbekistan, Change in the Base Calculation Value (BRV) from 1 October 2024, kdb.uz, accessed .
- Republic of Uzbekistan, Ministry of Justice registration 3507, “Mining Pool Operating Rules” (20 March 2024), lex.uz, accessed .
- Republic of Uzbekistan, Ministry of Justice registration 3461, “Mining Permits Procedure” (29 September 2023), lex.uz, accessed .
- Republic of Uzbekistan, Law No. 660-II, “On combating the legalization of proceeds from criminal activity, the financing of terrorism and the financing of the proliferation of weapons of mass destruction” (26 August 2004), lex.uz, accessed .
- Eurasian Group on Combating Money Laundering and Financing of Terrorism, EAG Mutual Evaluation Report on Uzbekistan (2022), eurasiangroup.org, accessed .
- EY Uzbekistan, Decree on Additional Incentives to Support IT Park Residents Involved in Export Activities within the Digitalization Sector, ey.com, accessed .
- Crowdfund Insider, Digital Assets Exchange Binance Obtains Authorization To Offer Services In Uzbekistan, crowdfundinsider.com, accessed .
- FATF, Uzbekistan’s progress in strengthening measures to tackle money laundering and terrorist financing, First Enhanced Follow-Up Report 2023, fatf-gafi.org, accessed .
- Central Bank of the Republic of Uzbekistan, EAG and the Mutual Evaluation of Uzbekistan, cbu.uz, accessed .