How to Open a Pharmacy in Uzbekistan (2026): Pharmaceutical Licence, Requirements and Fees
Who needs a pharmaceutical licence, what it costs at a BRV of UZS 440,000, how to open a pharmacy and how wholesale and manufacture differ: premises and manager requirements, terms, Asl belgisi marking, prescriptions and fines as of October 2026.
As of October 2026, to open a pharmacy in Uzbekistan a legal entity must obtain a licence for pharmaceutical activity from the Ministry of Health, applying with an e-signature through the "Litsenziya" information system (license.gov.uz) or the my.gov.uz portal. For retail trade the decision takes 7 working days, the licence is valid for 5 years, and at a BRV of UZS 440,000 the payments are UZS 880,000 for the review (2 BRV) and UZS 4,400,000 in state duty (10 BRV). Wholesale, compounding and manufacture of medicines are licensed under a different passport: 15 working days (5 expedited) and a fee of 2 or 4 BRV; a sole proprietor cannot obtain the licence.
In short
- What you need. The "pharma licence" is the licence for pharmaceutical activity: retail of medicines, compounding, wholesale and manufacture. Only pharmacies and their branches may sell medicines at retail.
- Money. A pharmacy pays UZS 880,000 for the review and UZS 4,400,000 in state duty, UZS 5,280,000 in total. Wholesale and manufacture: the same duty and a fee of UZS 880,000 or UZS 1,760,000 (expedited).
- Terms. Retail takes 7 working days, wholesale and manufacture 15 (5 expedited). The licence is valid for 5 years.
- Requirements. The applicant must be a legal entity; the manager must hold a relevant higher education; the premises must be on the ground floor, at least 34 m², with a separate street entrance; sales are video-recorded, with a cash register and a card terminal.
- Marking and prescriptions. The "Asl belgisi" code is scanned when the receipt is issued; in Tashkent and the pilot districts, data exchange with the "Electronic Prescription" module has been mandatory since 10 December 2025, and nationwide it applies from 1 January 2027.
- Without a licence. A legal entity is fined 300 BRV (UZS 132,000,000).
Which licence you need: retail, wholesale, manufacture
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A licence is required for the manufacture, compounding, wholesale and retail of medicines and for the retail of medical products. Manufacture, compounding and wholesale of the medical products themselves, research, quality control, and packaging and wholesale of medicinal herbal raw material do not need one (Arts. 15–16 of the Law "On Medicines and Pharmaceutical Activity", the Medicines Law). The activity is listed in Annex 1 to Law No. ZRU-701 (item 26), and the conditions are in passports 28 and 29 of the Unified Regulation on Licensing (Cabinet of Ministers Resolution No. 80 of 21 February 2022, CMR 80; the passports are published in Uzbek). Decree UP-137 of 19 August 2025 (para. 4(g)) provided for moving the retail of medical products from a licence to a notification from 1 January 2026, but as of October 2026 neither the Medicines Law nor Annex 1 to ZRU-701 nor passport 29 has been amended, and no notification procedure for it has been approved. This does not affect a pharmacy; a shop selling only medical products should confirm the procedure before launch. The general logic is covered in our overview of licensed activities.
| Activity | Passport, authority | Fee and duty | Review | Key requirement |
|---|---|---|---|---|
| Retail of medicines and medical products (pharmacy, branch) | No. 29, Ministry of Health | 2 BRV (UZS 880,000) + 10 BRV (UZS 4,400,000) | 7 working days | a manager with a relevant higher education, premises of at least 34 m² |
| Compounding of medicines | No. 28, Ministry of Health | 2 BRV, or 4 BRV (UZS 1,760,000) expedited, + 10 BRV | 15 or 5 working days | a specialist with a higher pharmaceutical education, a contract with a laboratory |
| Wholesale of medicines | No. 28, Ministry of Health | 2 or 4 BRV + 10 BRV | 15 or 5 working days | a warehouse manager with a pharmaceutical education, GDP and GSP |
| Manufacture of medicines | No. 28, Ministry of Health | 2 or 4 BRV + 10 BRV | 15 or 5 working days | two production and quality specialists, GMP |
A manufacturing licence also allows wholesale of the licensee's own products, and a compounding licence allows retail of the medicines it compounds (note to passport 28). Handling narcotic and psychotropic substances needs a separate licence (passport 37: 5 BRV fee, 5 BRV duty, 15 working days).
Who issues the licence and where to apply
- Authority. The licensing authority is the Ministry of Health (Art. 6 of the Medicines Law; para. 4 of passports 28 and 29 as amended by CMR No. 456 of 24 August 2026). Annex 1 to ZRU-701 (item 26) and the State Duty Law still name the Agency for the Development of the Pharmaceutical Industry under the Ministry of Health (renamed the Agency for the Development of the Medical and Pharmaceutical Industry by Decree UP-77 of 5 May 2026), but since 2023 the Ministry has been the Agency's successor in registration of medicines, certification and licensing of pharmaceutical activity (Presidential Resolution PP-197 of 20 June 2023, para. 7), and licensing is handled by the Ministry's Pharmaceutical Products Safety Centre (Annex 2 to PP-197).
- Where. The application is filed round the clock with an e-signature through the "Litsenziya" system or my.gov.uz; since 25 August 2026 Public Service Centres can also process it through the system, and since 22 October 2026 an applicant in the United States may file through the us-uz.gov.uz platform (paras. 4 and 10 of the Unified Regulation).
- Approvals. The application is sent to the Sanitary and Epidemiological Welfare Committee, the state institution "Centre for Good Practices" ("Zarur amaliyotlar markazi") and the construction control inspectorates (accessibility for people with disabilities). They reply within 5 working days, and silence counts as consent (para. 10 of passport 29; para. 18 of the Unified Regulation).
Opening a pharmacy step by step
- Set up a legal entity. A pharmacy is a legal entity or its subdivision (Art. 21 of the Medicines Law), and only a legal entity may apply. Usually this is an LLC.
- Choose premises before you sign a lease: ownership or a lease registered with the tax authorities (para. 9 of passport 29; for new companies since 1 September 2025, PP-190, para. 9).
- Hire the manager and equip the outlet: cash register, card terminal, video surveillance, refrigerator; register in "Asl belgisi".
- File the application with an e-signature: the entity's details, the address, the staff and consent to comply with the conditions; pay UZS 880,000. No other documents may be demanded (Art. 26 of ZRU-701).
- Get the decision in 7 working days; curable shortcomings can be fixed within up to 30 working days (Art. 29 of ZRU-701).
- Pay the duty, UZS 4,400,000, within 30 days of the notice, otherwise the decision is cancelled (para. 29 of the Unified Regulation). The licence with a QR code arrives in your personal account (Art. 27 of ZRU-701; para. 30 of the Unified Regulation).
Premises, staff and equipment requirements
The conditions of the retail licence are in para. 9 of passport 29. It sets no minimum distance between pharmacies.
- Location. A separate building (ground floor only), an extension to a residential or non-residential building (ground floor), or the ground floor of a multi-storey building; in a block of flats there must be a separate street entrance for visitors and a service door facing the yard for receiving goods.
- Area. A service hall of at least 16 m² (8 m² staff workplace and 8 m² visitor area), storage of medicines and products with a refrigerator for thermolabile items 12 m², a staff room 4 m² and a toilet 2 m²: 34 m² in total. A pharmacy with branches adds a picking and dispatch room (10 m²) and a medical products storeroom (6 m²): 50 m² in total.
- Equipment. A ramp 1.0 m wide, air conditioning in the hall and the storeroom, thermometers; continuous video recording of sales, kept for a month (except pharmacies at rural polyclinics and medical posts), a cash register and a terminal.
- Staff. The manager holds a higher pharmaceutical education, or a higher medical education plus a special course at a pharmaceutical higher education institution; a branch manager holds a higher pharmaceutical or a secondary specialised (pharmacist assistant) education. Only people with a pharmaceutical education may sell. A change of manager is reported to the authority within 10 days.
State duty and fees
| Payment | BRV | Amount, UZS | Basis |
|---|---|---|---|
| Review fee, retail | 2 | 880,000 | passport 29, para. 6 (per branch if filed together) |
| Review fee, wholesale, compounding, manufacture | 2 (expedited 4) | 880,000 (1,760,000) | passport 28, para. 6 |
| State duty for issue | 10 | 4,400,000 | passports 28 and 29, para. 7; ZRU-600, annex, item 47 |
| Re-issue after a change of name or address of the entity, filed within 5 working days (retail) | 1 | 440,000, no duty; no fee if filed via a Public Service Centre on re-registration | Unified Regulation, paras. 32–34 |
| Amendment: new branch or place (retail) | 1 + 5 | 440,000 + 2,200,000 | Unified Regulation, para. 38: half the fee and 50% of the issue duty |
| Renewal (retail) | 1 + duty | 440,000 + duty under ZRU-600 (on automatic renewal, the issue duty) | Unified Regulation, paras. 35, 35¹, 36 |
The BRV has been UZS 440,000 since 1 September 2026 (Decree UP-115 of 23 June 2026). The fee is paid on filing and the duty after a positive decision; obtaining a retail licence costs UZS 5,280,000 in total.
Terms, renewal and changes
- Review. 7 working days for retail, 15 (5) for the other sub-types, with a general statutory ceiling of 20 working days (Art. 28 of ZRU-701). If the authority misses the deadline, the applicant may start work once it has paid the state duty, and the licence is issued through the system (Art. 28 of ZRU-701 as amended by ZRU-1099, from 1 March 2026; para. 20 of the Unified Regulation also requires notifying the authority through the system).
- Validity. 5 years, shorter only at the applicant's request (Art. 16 of the Medicines Law). A renewal application is filed before expiry, and work may continue until the decision (para. 35). For licensees with a business stability rating of "B" or higher, renewal has been automatic since 25 August 2026: a month before expiry an invoice for the amount of the issue duty arrives, to be paid within 15 days but at least 5 days before expiry (para. 35¹).
- Transfer. Transferring a licence or the rights under it to other persons is prohibited (Art. 13 of ZRU-701); on liquidation or reorganisation (except transformation and a merger of companies holding the same licences) it ends (para. 49 of the Unified Regulation).
Wholesale, import and manufacture
- Wholesale. A warehouse manager with a pharmaceutical education and a warehouse meeting sanitary standards (Art. 19 of the Medicines Law). Passport 28 adds GDP and GSP and connection to the information system for tracking pharmaceutical products.
- Import. The law names no separate import licence, but only registered medicines may be imported, save for the cases in Art. 24 (for example, orphan medicines ordered by the Ministry of Health), and only manufacturers and licensed wholesalers may sell them wholesale (Art. 19). The Ministry of Health registers them through the Pharmaceutical Products Safety Centre (CMR No. 738 of 24 November 2025, Annex 1): the certificate is valid for 5 years, a national GMP certificate is required (except for registration by recognition and WHO-prequalified medicines), the review takes 210 days under the general procedure (time for fixing remarks and GMP inspection is not counted), and for medicines registered by WHO Listed Authorities or regulators at maturity level 4 the recognition route takes 60 days (paras. 3, 11, 19).
- Sales. Since 1 July 2025 an importer sells medicines to wholesalers and pharmacies directly or through official dealers on an electronic invoice, and digitally marked goods may be sold wholesale only by bank transfer (PP-190, para. 3). Contracts are covered in our article on distribution agreements.
- Foreign manufacturer. It must have an accredited representative office in Uzbekistan or a contract with a local legal entity on marking (CMR No. 149, para. 5); a foreign participant sets up its own LLC following this guide.
"Asl belgisi" marking, prescriptions and prices
Marking. Digital marking of medicines (HS 3003, 3004) was introduced in three groups: from 1 September 2022, 1 November 2022 and 1 March 2023 (CMR 149, para. 2); a fourth group, medicines and medical products on an approved list, follows from 1 July 2027. Unmarked stock had to be sold or withdrawn by 1 August 2025, 1 November 2025 and 1 March 2026 respectively (Annex 4, item 7), so unmarked packs of the first three groups may not be stored or sold. Since 1 September 2025 the cash register issues a receipt only after the code is entered; remote audits and a 0.2–2% scale of net revenue after a second warning are set out in PP-190 (paras. 7–8, Annex 2), but they take effect only once the Tax Code is amended: as of October 2026 the amending law has not been signed, and Art. 227¹ of the Tax Code still sets a fine of 2% of revenue, or 20% for a repeat violation. Unmarked medicines are a gross breach of the licence, and the tax authorities may initiate its suspension (passport 29, para. 9(b); PP-190, para. 9).
Prescriptions and prices. The Ministry of Health approves the prescription form and the procedure for classifying medicines as prescription or non-prescription (Arts. 6 and 20 of the Medicines Law). Under para. 9(o) of passport 29 a pharmacy connects to the "Electronic Health" system and exchanges data through the "Electronic Prescription" module: in Tashkent and 15 pilot districts (cities) since 10 December 2025 and in all regions from 1 January 2027. Decree UP-191 of 10 September 2026 (Annex 4, item 41) added to the technical requirements for online cash registers that a prescription medicine is sold only against an issued electronic prescription, its number is printed on the receipt, and otherwise the register does not issue the receipt. Compliance with state price regulation is a gross condition of the licence (para. 9(a)); UP-191 (Annex 4, item 44) narrows it to prescription medicines, and lex.uz shows the new wording of the passport as effective from 1 January 2027.
Refusal, suspension and annulment
A licence may be refused for an incomplete set of documents, non-compliance, false data or a negative conclusion of the approving bodies; refusal as "inexpedient" is banned, at least 10 working days are given to fix the problem, and a repeat review takes up to 5 working days with no fee (paras. 21–27 of the Unified Regulation). The authority may suspend a licence for up to 10 days and a court for up to 6 months; annulment goes through a court on the authority's claim if systematic (two or more in a year) or gross violations caused harm to life, health, rights or safety (paras. 41, 51). Passport 29 treats as gross: breach of price rules; selling medicines without certificates, unregistered, unmarked, substandard or falsified; sales by a person without a pharmaceutical education; operating at an address outside the licence; no qualified manager; no data exchange via "Electronic Prescription". The addresses and staff of pharmacies whose licence was annulled go into open registers for 3 years. Your rights during inspections are covered in a separate article.
Liability for operating without a licence
- A legal entity without a licence: 300 BRV (UZS 132,000,000) (Arts. 52 and 54, Annex 4, section I, item 22 of ZRU-701); operating while the licence is suspended is also a ground for a fine (Art. 52). If 50% of the fine is paid within 15 days (70% within 30 days) and a licence application is filed, the rest is written off (Art. 55).
- Individuals and officials: 15–20 BRV and 20–25 BRV (Art. 165 of the Code of Administrative Liability).
- Selling outside pharmacies and branches, and trading in substandard or falsified medicines: 50–100 BRV (UZS 22,000,000–44,000,000) with confiscation (Art. 165¹, part 1).
- Breaching the prescription sales procedure: 50–100 BRV, and 100–200 BRV for medicines containing potent substances (Art. 165¹, parts 2–3; these sanctions apply since 8 June 2026).
- Marking violations by a manufacturer or importer: 100 BRV on the official (Art. 166).
- Criminal liability applies to unlicensed activity with especially large income and to sales of medicines outside pharmacies after an administrative penalty (Criminal Code, Arts. 190 and 276¹²).
Typical mistakes
- Opening a pharmacy as a sole proprietor.
- Appointing a manager without the required education or one from the violators' register.
- Keeping unmarked stock and buying without an electronic invoice.
- Opening a new outlet without adding its address to the licence, or buying a "pharmacy" as premises and equipment: the licence belongs to the legal entity and is not transferable.
- Relying on CMR No. 284 of 12 May 2017: its para. 1 and Annexes 1–5 on licensing lost force on 1 March 2022 (Annex 4 to CMR 80, item 39).
How Pactum helps
- We identify the licence sub-type and check the premises and the manager before you sign a lease.
- We register an LLC, from UZS 1,500,000.
- We prepare the application, answer notices to fix shortcomings and prepare applications to add new outlets to the licence.
- We review supply contracts from UZS 2,000,000 and foreign trade contracts for importers from UZS 4,000,000.
- We support you through inspections; in court, our lawyers prepare the position and an advocate of our partner bureau appears at the hearings under a separate agreement.
Support with obtaining a business licence starts from UZS 2,500,000; the price of a sector licence, including a pharmaceutical licence, is quoted after we review the task, and state duties and fees are paid separately. We do not guarantee that a licence will be issued: the Ministry of Health takes the decision. Learn more on our page about business licences or book a lawyer consultation: 60 minutes, UZS 300,000, credited toward the cost of the service. Phone +998 99 050 50 70, Telegram, info@pactum.uz, office: 21 Afrosiyob Street, Tashkent.
FAQ
How to get a pharmaceutical licence in Uzbekistan?
The "pharma licence" is the licence for pharmaceutical activity. A legal entity files an application with an e-signature through the "Litsenziya" system (license.gov.uz) or my.gov.uz, pays the fee, passes the approvals and, after the decision, pays the 10 BRV duty (UZS 4,400,000). The Ministry of Health issues the licence for 5 years; a renewal application is filed before expiry.
Do you need a licence for a pharmacy or a pharmacy point?
Yes. The law allows the retail of medicines only through pharmacies and their branches (Art. 20), and it has no separate "pharmacy point" category. The outlet is formalised as a pharmacy or a branch and entered in the licence.
How much does a pharmacy licence cost in Tashkent?
The same as anywhere in the country: UZS 880,000 in fees and UZS 4,400,000 in duty, UZS 5,280,000 in total. In Tashkent and the pilot districts, data exchange via "Electronic Prescription" has been mandatory since 10 December 2025, and in the other regions it applies from 1 January 2027.
Can a sole proprietor open a pharmacy in Uzbekistan?
No. Passports 28 and 29 name only legal entities as applicants, so an entrepreneur first registers an LLC.
What education is required to open a pharmacy?
The pharmacy manager needs a higher pharmaceutical education, or a higher medical education plus a special course at a pharmaceutical higher education institution; a branch manager needs a higher pharmaceutical or a secondary specialised (pharmacist assistant) education.
Do you need a licence for wholesale and import of medicines?
Wholesale needs a licence (passport 28): a fee of 2 or 4 BRV and a duty of 10 BRV. The law names no separate import licence, but only registered medicines may be imported, and they may be sold wholesale only under a wholesale licence (Art. 19 of the Medicines Law).
Sources
- Law "On Medicines and Pharmaceutical Activity" No. 415-I of 25 April 1997 (new edition, ZRU-399 of 4 January 2016), Arts. 6, 15–16, 19–21¹, 24 (in Russian)
- Law No. ZRU-701 on Licensing, Permitting and Notification Procedures, Arts. 13, 16, 25–29, 52–55, Annexes 1 and 4 (in Russian)
- CMR No. 80 of 21 February 2022, Unified Regulation on Licensing, passports 28, 29 and 37 (in Uzbek)
- Law No. ZRU-600 on State Duty, annex, item 47 (in Russian)
- Presidential Decree No. UP-115 of 23 June 2026, BRV of UZS 440,000 (in Russian)
- Presidential Resolution No. PP-197 of 20 June 2023, para. 7 and Annex 2 (in Uzbek)
- Presidential Decree No. UP-137 of 19 August 2025, para. 4(g) (in Uzbek)
- Presidential Decree No. UP-77 of 5 May 2026 (in Uzbek)
- Presidential Resolution No. PP-190 of 23 May 2025 on digital marking (in Uzbek)
- CMR No. 149 of 2 April 2022 on marking of medicines (in Uzbek)
- CMR No. 738 of 24 November 2025 on registration of medicines (in Uzbek)
- Presidential Decree No. UP-191 of 10 September 2026, Annex 4, items 41 and 44 (in Uzbek)
- Code of Administrative Liability, Arts. 165, 165¹, 166 and Criminal Code, Arts. 190, 276¹² (in Russian)
- "Litsenziya" information system and Single Portal of Interactive Public Services
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