Medical practice and pharmacies, alcohol, passenger and freight transport, educational services — obtaining, re-registration and defence when a licence is suspended.
Who issues licences in Uzbekistan, and for how long?
The governing act is the Law of the Republic of Uzbekistan of 14 July 2021 No. ZRU-701 “On licensing, permit and notification procedures”: it separates three regimes of access to an activity — a licence, a permit document and a notification. Licences are issued with no limit on their period of validity, apart from a closed list of exceptions. The issuing authority depends on the sector: medical, pharmaceutical and pharmacy activity is licensed by the Ministry of Health of the Republic of Uzbekistan, international carriage of passengers and freight by the Ministry of Transport, domestic passenger carriage by the Ministry of Transport of the Republic of Karakalpakstan and the transport departments of the regions and Tashkent city (domestic freight carriage is not licensed), and non-state educational services by the State Inspectorate for Supervision of the Quality of Education. Applications are filed through the Unified Portal of Interactive Public Services. At Pactum, support in obtaining a licence starts from UZS 2,500,000 for the lawyers' work; state duties and fees are paid separately.
These are not abstract risks but the scenarios that make deals collapse and make state authorities decide against you.
Premises and equipment stand idle while rent and salaries keep running and there is no revenue. For a clinic that means months of dead cost.
Typical mistake: The lease was signed and the fit-out carried out before the premises were checked against the licensing requirements. An applicant's failure to meet the requirements is a direct ground for refusal.
The buyer gets a legal entity with no right to operate: either the deal falls apart or the price drops by the cost of re-licensing and downtime.
Typical mistake: Nobody read article 33 of ZRU-701: where an activity ceases as a result of a reorganisation the licence is annulled, and the exception is made for a change of legal form. The deal structure has to be chosen with that in mind, not after the fact.
A whole preparation cycle — charter fund, warehouse, contracts — was spent meeting the requirements of an act that is no longer in force.
Typical mistake: They worked from resolution No. 301 of 20 May 2020 on wholesale trade in alcohol. It has been repealed, and since 1 May 2025 resolution No. 45 of 29 January 2025 applies, which most articles online do not reflect.
Either an overpayment — beer was counted under the general levy for the right to sell alcoholic products — or an assessment, because the separate monthly fee for beer retail was forgotten.
Typical mistake: Different things get mixed up: the levy for the right to sell alcoholic products (it does not apply to beer), the separate monthly fee for beer retail of 10% of the base calculation value, the wholesale trade licence, and the requirements for a retail outlet.
Every idle day is lost revenue and customers moving to a competitor; a drawn-out suspension gets lease agreements terminated.
Typical mistake: They do not know that suspension by the authorised body is limited to ten days, and that anything longer is for a court to decide. Instead of removing the ground and demanding reinstatement, the business waits passively.
Either a fee was paid and weeks spent waiting where the notification regime would have done, or — the costlier version — the business operated on a notification where a licence was required.
Typical mistake: Nobody checked which regime the specific activity falls under. The licensing law expressly separates licences, permit documents and notifications, and the 2024 reform took part of the activities out of licensing.
Licence, permit or notification — for your specific activity, not for the sector as a whole.
We match the site and its equipment against the licensing requirements before the fit-out and the purchase of equipment.
Documents shaped to the issuing authority's requirements, filed through the Unified Portal of Interactive Public Services.
We take apart the ground, remove the non-compliance and re-file, instead of starting the cycle over blind.
Keeping the licence through changes in the company, and choosing a deal structure that does not annul it.
We remove the ground and get the licence reinstated on time, instead of waiting while the business stands idle.
We identify the regime, the issuing authority and the full list of requirements for your activity.
Premises, equipment, staff and documents are brought to a state that will pass inspection.
We file through the portal, answer the authority's queries and clear objections before a refusal, not after one.
Meeting the licensing requirements, re-registration when the company changes, defence during inspections.
Every point comes with a link to the primary source, so you can check it yourself.
The governing act is the Law of the Republic of Uzbekistan of 14 July 2021 No. ZRU-701 “On licensing, permit and notification procedures”, which separates licensing, permit and notification procedures.
lex.uz — ZRU-701Licences for licensed activities are issued with no limit on their period of validity, apart from a closed list of cases (art. 16 of ZRU-701).
lex.uz — art. 16 of ZRU-701Suspension of a licence by the authorised body is possible for up to ten days; suspension for a longer period falls within the competence of a court (art. 32 of ZRU-701).
lex.uz — art. 32 of ZRU-701A licence is annulled on liquidation of the legal entity, and also where the activity ceases as a result of a reorganisation — except for a change of legal form (art. 33 of ZRU-701).
lex.uz — art. 33 of ZRU-701The register of licences of Uzbekistan is public: it shows information on licences issued, suspended, reinstated, re-registered and annulled.
gov.uz — register of licencesApplications for licences and the documents attached to them are accepted through the Unified Portal of Interactive Public Services and the licensing information system.
gov.uz — licensingThe licence for medical activity is issued by the Ministry of Health of the Republic of Uzbekistan; the decision is taken within 30 days and the licence is valid for 5 years.
lex.uz — medical licence passport (CMR No. 80)The licence for pharmaceutical activity, including retail sale of medicines in pharmacies, is issued by the Ministry of Health of the Republic of Uzbekistan.
lex.uz — CMR No. 80, passports 28 and 29, item 4The licence for the international carriage of passengers and freight by road is issued by the Ministry of Transport of the Republic of Uzbekistan; for urban, suburban and intercity passenger carriage — by the Ministry of Transport of the Republic of Karakalpakstan and the transport departments of the regions and Tashkent city. Domestic freight carriage is not licensed. The licence itself has no time limit, but a licence sheet is issued for each vehicle, and the state duty for it is paid for every year.
lex.uz — ZRU-701, Annex 1, items 16–17The licence for activity in the field of non-state educational services is issued by the State Inspectorate for Supervision of the Quality of Education.
my.gov.uz — educational servicesCabinet of Ministers resolution No. 301 of 20 May 2020 on licensing wholesale trade in alcoholic products has been repealed; resolution No. 45 of 29 January 2025 is in force.
lex.uz — CM resolution No. 301 (repealed)The rules on accounting for and circulation of ethyl alcohol and alcoholic products are set by Cabinet of Ministers resolution No. 45 of 29 January 2025.
lex.uz — CM resolution No. 45 of 29.01.2025Presidential Decree No. UP-8 of 9 January 2024 provides for a reduction of mandatory requirements and simplification of licensing and permit procedures in business.
lex.uz — UP-8 of 09.01.2024The Law “On education” No. ZRU-637 of 23 September 2020 provides a separate regime for non-state educational activity, including licensing.
lex.uz — ZRU-637| What we compare | Licence | Permit document | Notification |
|---|---|---|---|
| When you may start | After the licence is issued | After the document is received | After the notification is filed |
| Period of validity | No time limit, apart from a closed list of exceptions | As set by the relevant act | Not applicable |
| What is checked in advance | Compliance with the licensing requirements | Compliance with the conditions for issue | As a rule, compliance is confirmed by the applicant |
| Risk if you get it wrong | Refusal, suspension, annulment | Refusal or withdrawal | Operating without the right to do so, if the regime was identified incorrectly |
The mistake is usually not in the documents but in identifying the regime: a business prepares a licence where a notification would be enough, or the other way round. So the first step is to qualify the specific activity, not to assemble a folder.
We will go through your situation, say what can realistically be done and by when, and name the cost once we understand the scope. Without that, any figure would be made up.
Want to talk it through with a lawyer first?
60-minute consultation — 300 000 UZS, paid in advance. The fee is credited toward the service if you go ahead.
Book a consultationThere are no testimonials or case studies here: they cannot be checked. Only what you can confirm yourself.
This material is for reference and is not legal advice on your specific situation. Rules and tariffs change — check the current wording through the links to the primary sources above. To have your case assessed, send us a request.