Uzbekistan Crypto Exchange Licence 2026: NAPP Requirements, State Fee and Steps

As of October 2026, a crypto exchange licence in Uzbekistan is issued by the National Agency for Prospective Projects (NAPP), and only to a resident legal entity, so a foreign group enters the market through a local subsidiary, a partnership with a licensee or the purchase of a stake in one; a separate regime of the Tashkent International Financial Centre (TIFC) is still taking shape. Four types of provider are licensed — a crypto exchange, a crypto depository, a crypto store and a mining pool — and each needs its own licence. The state fee for an exchange is 73,400 BRV, about UZS 32.3 billion at a BRV of UZS 440,000. On top of it come a monthly fee of 740 BRV and a charter capital requirement of at least 5,000 BRV in cash on the application date, of which 3,000 BRV must sit in a separate account with a bank in Uzbekistan. NAPP decides within 20 working days of accepting the application, and the state fee is paid only after a positive decision.

Key points

• Who can hold a licence. Outside the TIFC, NAPP issues an indefinite licence only to a resident legal entity, and it cannot be transferred to another legal entity (Licensing Regulation, Ministry of Justice reg. No. 3380, as amended on 1 October 2026).
• State fees. Exchange — 73,400 BRV, depository — 7,000, crypto store — 3,700, mining pool — 3,000 BRV, at the rate on the payment date.
• Exchange capital. At least 5,000 BRV in cash at the BRV on the application date (UZS 2.2 billion at a BRV of UZS 440,000), from own funds only; 3,000 BRV of it in a separate account.
• Infrastructure. Servers in Uzbekistan; data on transactions and clients is stored for 5 years.
• New from 1 October 2026. A sale of a stake in a licensee, including to a non-resident, and a change of director, deputies or head of AML/CFT require NAPP’s consent.
• Market. As of 12 October 2026, the NAPP register shows 2 crypto exchange licences, 6 crypto depository licences and 13 crypto store licences in force, 4 of the latter suspended.

Abbreviations: NAPP — National Agency for Prospective Projects; BRV — base calculation value (UZS 440,000 from 1 September 2026); TIFC — Tashkent International Financial Centre; AML/CFT — anti-money laundering and countering the financing of terrorism; UP — Presidential Decree; PP — Presidential Resolution; ZRU — Law of the Republic of Uzbekistan; cl. — clause of the act cited. Sub-clause letters in quotation marks (“a”, “b”, “v”…) are the Cyrillic letters of the official text in Latin transliteration.

Who needs a licence: the four types of provider

The type of activity determines the state fee, the monthly fee and the capital requirements, so the business model is first mapped against the list in the Licensing Regulation.

Why a foreign platform needs a local company

Residents may buy and sell crypto assets only through national providers, except in cases set by law (sub-clause “d” of clause 3 of PP-3832). Access to platforms operating without a licence is restricted under Art. 12¹ of the Law “On Informatization”, and operating without a licence entails liability under Art. 165 of the Code of Administrative Liability and Art. 190 of the Criminal Code (NAPP FAQ). There is no formal “working in the Uzbek market” test, but an interface in local languages, settlements in soums and local advertising are strong signals that a local licensed company is needed. How to set one up is covered in our article on an LLC with a foreign founder.

Three ways to enter the market

Having your own licence is not the only route. In early 2024 NAPP fined Binance UZS 102 million for providing services without a licence, a local legal entity and servers in Uzbekistan (Spot.uz, 6 February 2024), and in January 2025 it announced that the exchange would serve residents through the licensee Coinpay as its local partner (Spot.uz, 17 January 2025).

A stake purchase is run as an M&A deal with an additional regulatory stage — more on our page about buying a company in Uzbekistan.

Budget: state fee, monthly fee and capital

The state fee is set by Order No. 100 of the NAPP Director of 5 December 2024 (Ministry of Justice reg. No. 3584) and is calculated in BRV at the rate on the payment date. From 1 September 2026 the BRV is UZS 440,000 (Decree UP-115 of 23 June 2026). The monthly fees are set by the Regulation on Fees, Ministry of Justice reg. No. 3388, as amended on 29 July 2026.

Amounts in soums are as of October 2026: the state fee and monthly fees are calculated at the BRV on the payment date, and the capital at the BRV on the application date. The exchange’s monthly fees come to 8,880 BRV a year, about UZS 3.9 billion. How to fit the whole project into this budget is covered on our page on crypto activity licensing.

• No fee is charged for reviewing the application (cl. 16 of the Licensing Regulation); the licence is issued within 3 days after the state fee is paid (cl. 21).
• The monthly fee is paid in advance by the 10th of the current month (cl. 5 of the Regulation on Fees); if the licence was obtained after the 20th, it accrues from the 1st of the following month (cl. 3).
• Capital is formed only from the founders’ own funds and property, without loans, borrowings or pledged money (cl. 12 of the Licensing Regulation).
• The law sets no norm for spending on servers, software and AML/CFT staff; these costs are calculated after the project is reviewed.

Requirements for the applicant, owners and infrastructure

Founders, beneficial owners and managers

The applicant discloses the ownership structure down to the ultimate beneficial owner (sub-clause “b” of clause 14 and Annex 2 to the Regulation). Foreign founders and managers submit a certificate of no criminal record with an apostille or legalisation and a notarised translation into Uzbek (sub-clause “v” of clause 14). Under the version of 1 October 2026, the following cannot be founders or managers (sub-clauses “z” and “i” of clause 9):

• persons involved in terrorism or the financing of the proliferation of weapons of mass destruction, or suspected of it;
• persons with an unspent conviction for economic, corruption or IT crimes, laundering of criminal proceeds, organised crime and drug offences;
• persons who reside or are registered in states that do not cooperate on AML/CFT.

NAPP’s page for service providers still says that companies from offshore zones cannot participate in the capital. The word “offshore” does not appear in the Regulation as amended on 1 October 2026: the ban is worded through jurisdictions that do not cooperate on AML/CFT. According to Spot.uz, the benchmark is the FATF “black” and “grey” lists; the ownership chain is checked against both criteria on the filing date.

Infrastructure and data

• The platform and the software and hardware run on servers in Uzbekistan (sub-clause “a” of clause 9). Servers abroad are a gross violation (sub-clause “e” of clause 54).
• Data on all transactions, participants’ identification data and correspondence are stored for 5 years (sub-clause “b” of clause 9).
• The provider complies with AML/CFT legislation and with legislation on personal data (sub-clause “v” of clause 9). Hidden mining and anonymous crypto assets are prohibited (sub-clause “d” of clause 9).

Steps: from group structure to licence

Annex 1 to the Regulation divides the procedure into 12 stages; for a foreign group it is easier to lay it out like this:

• Choose the route into the market and the licences you need.
• Check the ownership chain against sub-clauses “z” and “i” of clause 9, restructure it if needed, and obtain certificates of no criminal record for the foreign persons.
• Register the local legal entity and fund the capital; for an exchange, 3,000 BRV go into a separate account with a bank in Uzbekistan.
• Set up servers in Uzbekistan, data retention and AML/CFT rules, and name a candidate for AML/CFT officer from among the deputy heads.
• File the application (NAPP notifies the applicant of deficiencies within 1 working day), then the expert commission and the decision.
• Pay the state fee at the BRV on the payment date and receive the licence; the AML/CFT officer is appointed no later than a month after that.

Refusal, suspension and revocation

The list of grounds for refusal in clause 24 is closed, but it includes a reasoned opinion of the licensing authority, so a complete set of documents does not yet mean approval.

NAPP may suspend a licence for up to 10 days; for a longer period only a court can, for up to 6 months (cl. 40), and at least 5 working days are given to remedy a breach (cl. 41). At the licensee’s own request, activity is suspended for up to 6 months (cl. 47), and if no application to resume is filed within that period, the licence terminates. The grounds for revocation (cl. 50) include the licensee’s application, liquidation, unremedied, systematic or gross violations (cl. 54) and forged documents; after revocation on certain grounds a new licence cannot be obtained for one year.

Who already operates legally: the NAPP register

In the NAPP electronic register, as of 12 October 2026, there are 2 crypto exchange licences, 6 crypto depository licences and 13 crypto store licences in force, 4 of the latter suspended; mining pools do not appear in the register of provider licences.

Four crypto store licences — CRYPTO MAGNAT, CRYPTOCORP, C-CASH and T-FIRM — have been suspended for 6 months, some from 1 September (Order No. 73 of 28 August 2026) and the rest from 1 October 2026 (Orders No. 79–81 of 28 September 2026). The register does not state the grounds; the period matches a voluntary suspension under clause 47 of the Regulation. The CRYPTO MARKET licence was annulled on 2 September 2026 (Order No. 77) because the company did not file an application to resume.

What is new in 2026

TIFC: a parallel regime for digital assets

Constitutional Law ZRU-1158 of 13 July 2026 on the Tashkent International Financial Centre has applied since 25 July 2026. TIFC participants will be able to conduct digital-asset activity, including running exchanges and custody, with the permission of the centre’s regulator, TFSA (Art. 7). Services to persons in Uzbekistan outside the centre must comply with national legislation (Art. 5), so the NAPP licence remains the benchmark for the country’s mass market; the activation of the centre and the TFSA acts are checked on the filing date.

AML/CFT rules for crypto providers from 29 September 2026

A joint resolution of NAPP and the Department for Combating Economic Crimes (Ministry of Justice reg. No. 3309-3 of 28 September 2026) amended the Internal Control Rules on AML/CFT for providers.

• The responsible officer is appointed by order of the head from among the deputies (cl. 5).
• The officer must be appointed, and their personal details sent to NAPP, within a month of receiving the licence; a change of officer is notified no later than the day of the new appointment.
• The authenticity of client data can be verified through a third party — an organisation that confirms information from the authorised bodies of Uzbekistan or a foreign state (cl. 20).

Stablecoins, tokenised securities and advertising

PP-359 of 27 November 2025 introduced from 1 January 2026 a special regime for stablecoins as a means of payment (cl. 8). The procedure is set out in the joint regulation of NAPP and the Central Bank, Ministry of Justice reg. No. 3818, in force since 16 April 2026, with a participation period of up to 3 years. A payment-system project built on distributed ledger technology (DLT) needs an operator licence (cl. 14); more in our article on payment organisations.

Resident legal entities have been able to issue tokenised shares and bonds since 1 January 2026: a separate platform is created on stock exchanges holding an exchange-activity licence, and the procedure for issue and circulation is to be set by NAPP (cl. 9 of PP-359); check on the transaction date whether it has been approved.

Annex 5 to PP-359 restated the advertising requirements in sub-clause “i” of clause 3 of PP-3832: it is forbidden to promise returns on crypto-asset transactions, to present them as an “easy way to get rich” and to claim that crypto assets can be used to pay in Uzbekistan, except in cases set by law. Detailed requirements are in clause 11 of the Licensing Regulation: a risk warning, disclosure of terms, and a ban on information about bonuses and discounts, on promises of returns (except verified results of past periods) and on images of minors.

Exchanges for the special tax regime for foreigners

Under Decree UP-180 of 4 October 2025, from 1 January 2026 a foreigner who is a tax resident and has received a positive decision of the Commission pays a special fee of $50,000, opens an account with an authorised bank or a crypto wallet on an authorised exchange, and is exempt from personal income tax on foreign-source income. NAPP Order No. 49 of 1 June 2026 named COINPAY (CE #0004) and ASTERIUM (CE #0006) as authorised exchanges; a new exchange will receive this client flow only if NAPP adds it to the list. Whether applications under the regime are actually open is covered in our article on the special tax regime for foreigners and should be checked on the filing date.

Mining and mining pools

According to the NAPP FAQ and PP-3832, only legal entities may mine, and as a general rule they must do so on electricity from solar photovoltaic plants. If the unified power grid is used, the tariff applies with a coefficient of 2 plus peak-hour surcharges, and with a coefficient of 5 in the case of an unlawful connection; mining is allowed only at the address given at registration. PP-143 of 17 April 2026 excluded the Besqala Mining Valley zone from the “solar” rule and allowed miners to sell what they mine through national exchanges or foreign platforms, including under direct contracts, with the proceeds credited to accounts with banks in Uzbekistan. Mining does not require a licence, but electronic registration and a fee of 10 BRV a month are required; residents of Besqala Mining Valley are exempt from fees until 1 January 2035. More in our article on crypto assets and mining.

After the licence: what keeps it in force

• Fees. Paid in advance by the 10th; on suspension, accrual stops from the 1st of the following month (cl. 4 of the Regulation on Fees).
• AML/CFT officer. A deputy head appointed within a month of receiving the licence, with notice to NAPP.
• Stakes and key persons. A sale of a stake and a change of director, deputies or head of AML/CFT require NAPP’s consent (sub-clauses “k” and “l” of clause 9).
• Resumption. A voluntary suspension lasts up to 6 months (cl. 47); without an application to resume within that period the licence terminates, as happened with CRYPTO MARKET.

Common mistakes that derail a project

• Capital from a loan. An intra-group loan is also borrowed money (cl. 12).
• Capital at the bare minimum. It is calculated at the BRV on the application date (cl. 10): if the BRV rises before filing, 5,000 BRV at the old rate will not be enough.
• Buying a “ready-made licence”. A licence is not transferable, and a deal for a stake in a licensee closes only after NAPP’s consent.
• A participant from a “grey” jurisdiction. It is found at the NAPP stage, and the structure is rebuilt in a hurry.
• An AML/CFT officer who is not a deputy head. From 29 September 2026 this is a breach of the internal control rules.
• Advertising copied from a foreign template. Referral bonuses, commission discounts and promises of returns are prohibited, and a risk warning is mandatory (cl. 11 of the Regulation, sub-clause “i” of clause 3 of PP-3832).

Example: a foreign group launches an exchange in Tashkent

The example is hypothetical; rates are as of October 2026. A group with an EU holding company opens an exchange that also holds clients’ assets, that is, it obtains crypto exchange and crypto depository licences.

• Among the minority shareholders they find a fund from a jurisdiction that does not cooperate on AML/CFT and buy out its stake before filing.
• They register an LLC and contribute capital from the parent company’s own funds: 5,000 BRV at the rate on the filing date (UZS 2.2 billion at a BRV of UZS 440,000) plus a reserve in case the BRV rises; 3,000 BRV are set aside in a separate account.
• Servers are placed in Tashkent, the AML/CFT rules are adapted to Uzbek law, and one of the director’s deputies is prepared as the responsible officer.
• After the positive decision they pay the state fees: UZS 32,296,000,000 for the exchange and UZS 3,080,000,000 for the depository.
• The licences are issued on the 24th, so monthly fees accrue from the 1st of the following month: 745 BRV, or UZS 327,800,000 a month.

How Pactum helps

• We compare the routes into the market and determine the NAPP licences you need.
• We check the ownership chain against clause 9 of the Regulation and restructure it before filing.
• We register the local legal entity (LLC registration from UZS 3,500,000) and support the formation of capital.
• We prepare the dossier and the AML/CFT rules, run the project at NAPP and remedy deficiencies.
• After the licence we handle compliance: fees, NAPP approvals and advertising checks.

The cost of a licensing project is set after we review the task. More on our page on crypto activity licensing; you can start with a lawyer consultation: 60 minutes, UZS 300,000, credited toward the cost of the service.

FAQ

Can a foreign company obtain a crypto licence in Uzbekistan?

A NAPP licence can be obtained only through a local subsidiary, because it is issued to resident legal entities. Foreign founders are permitted if neither they nor the chain up to the beneficial owner fall under the restrictions of clause 9 of the Regulation. A separate route is TFSA permission for a TIFC participant, but serving clients in Uzbekistan outside the centre is subject to national legislation.

How much does a crypto exchange licence cost in Uzbekistan?

The state fee is 73,400 BRV, or UZS 32,296,000,000 at a BRV of UZS 440,000 as of October 2026. On top of it come a monthly fee of 740 BRV (UZS 325,600,000) and a charter capital requirement of at least 5,000 BRV on the application date; the capital stays in the company and is not a payment.

Can you serve Uzbek clients from abroad or through a local partner?

From abroad without a licence, as a rule, you cannot: residents work only through national providers, and operating without a licence entails liability under Art. 165 of the Code of Administrative Liability and Art. 190 of the Criminal Code. Through a partner — yes: in January 2025 NAPP announced that Binance would serve residents through the licensee Coinpay. The client agreement, servers and compliance must then fit within the partner’s licence.

Do P2P and OTC trades need a licence?

The starting point is sub-clause “d” of clause 3 of PP-3832: residents buy and sell crypto assets only through national providers, except in cases set by law. NAPP has stated publicly that it does not plan to legalise P2P transactions until there is a mechanism to control them (Spot.uz, 6 February 2024). OTC sales to clients in one’s own name are close in substance to the crypto store model, but the conclusion depends on the structure, and it is analysed before launch.

Are stablecoins legal in Uzbekistan?

Issuing stable tokens and using them as a means of payment are allowed only under the special legal regime of NAPP and the Central Bank (reg. No. 3818): the issuer is a resident legal entity, and the backing is no less than the nominal value, held with the Central Bank or in blocked government securities. Buying and selling crypto assets, including stablecoins, is possible through licensed national providers under the general rules; check with the provider which tokens are admitted to trading. Paying with crypto assets outside the regime is prohibited (sub-clause “v” of clause 6 of PP-3832).

How long does the licence last, and can it be sold with the company?

The licence is indefinite and cannot be transferred to another legal entity; a stake in the licensee can be sold, and from 1 October 2026 only with NAPP’s consent. Reissue is possible on a change of name or location and on a merger (cl. 33–34): the application is filed within 5 working days after re-registration and is reviewed within 5 working days (cl. 38). Another kind of reorganisation may become grounds for revocation (cl. 50), so the scheme is agreed with NAPP in advance.

Sources

The sources are the original-language texts: acts on lex.uz, the NAPP FAQ and the Spot.uz articles are in Russian, while NAPP pages with /en/ in the address are in English. Titles below are translated.

• Regulation on licensing of providers of services in the sphere of crypto-asset turnover, Ministry of Justice reg. No. 3380
• Order No. 100 of the NAPP Director of 5 December 2024 on the state fee, Ministry of Justice reg. No. 3584
• Regulation on fees in the sphere of crypto-asset turnover, Ministry of Justice reg. No. 3388
• Decree UP-115 of 23 June 2026
• Resolution PP-3832 of 3 July 2018, as amended by PP-359 and PP-143
• Resolution PP-359 of 27 November 2025
• Regulation on the special legal regime for stablecoins, Ministry of Justice reg. No. 3818
• Decree UP-180 of 4 October 2025
• Constitutional Law ZRU-1158 of 13 July 2026 on the Tashkent International Financial Centre
• Amendments to the AML/CFT Internal Control Rules for crypto providers, Ministry of Justice reg. No. 3309-3
• NAPP: requirements for service providers
• NAPP: electronic register of licences
• NAPP: authorised crypto exchanges, Order No. 49
• NAPP: frequently asked questions
• Spot.uz: amendments to the licensing of crypto providers, 30 June 2026
• Spot.uz: NAPP on the Binance fine and P2P transactions, 6 February 2024
• Spot.uz: Binance agreed with NAPP to operate through Coinpay, 17 January 2025