Analysis · Updated: October 15, 2026 · 8 min read

Can an individual entrepreneur bid in Uzbekistan public procurement?

Can an individual entrepreneur (IE, Uzbek: YaTT) take part in public procurement in Uzbekistan? Legally, yes. But since 1 October 2026 the Hayot Birja platform (xt-xarid.uz) has automatically barred individual entrepreneurs from lots they are not allowed to sell. We look at what an IE can do, what is a grey area and what is off limits, how many tenders IEs actually win and when it is time to set up an LLC.

The IE share is a Tanlo estimate based on the etender.uzex.uz deal register as of 15 October 2026. Methodology is at the end of the article.

Can an IE take part in public procurement: what the law says

Article 23 of Law No. ZRU-684 "On Public Procurement" defines a participant as "an individual or legal entity, whether resident or non-resident". The law contains no ban on IEs.

There are no small-business quotas either. The only preference is priority at an equal price in the electronic shop under Presidential Resolution PP-249, for small enterprises where more than half of the staff are women, young people or people with disabilities. We found no official clarification on whether it applies to IEs.

The catch is in Article 36: one of the requirements for a participant is "legal capacity to conclude the contract". And an IE has that capacity only within the scope of Cabinet of Ministers Resolution No. 6 of 7 January 2011. Its paragraph 2 states plainly that individuals "may not carry out types of activity not included in the List". So the real question is not "can an IE take part" but "for which subject of procurement".

What an IE can do, what is a grey area and what is off limits

The list in Resolution No. 6 (annex as amended by Resolution No. 175 of 16 April 2026) contains about 94 types of activity. For public procurement, we split them into three groups:

What about the "grey area" column? The platform does not block these lots for IEs, but a customer or an inspector may consider the contract to fall outside the permitted activities. A one-off deal is your own risk; if supplies and repairs for organisations are your main income, an LLC is the safer vehicle.

The takeaway for IT: an IE can build a website or software, but cannot resell other vendors' licences, such as Windows, 1C or antivirus. For construction, see our analysis of small construction tenders.

1 October 2026: Hayot Birja switched on a filter for IEs

Previously the platform did not check lots against Resolution No. 6; now it does so automatically. From the Hayot Birja documentation: "From 1 October, a supplier registered as an individual entrepreneur cannot post listings or submit offers for items on the list of goods whose sale by individual entrepreneurs is restricted".

The legal basis is Resolution No. 6 and letter No. 04-17/3309 of 15 September 2026 from the Agency for Industrial Cooperation and Public Procurement. How the filter works:

• The system compares the first 9 digits of an item's ENKT code (the national goods/works/services classifier code) with the list of restrictions. If they match, the item is closed to IEs, whatever the rest of the code. The same rule applies to goods, works and services.
• An IE cannot post a listing in the electronic shop, the national shop or the Ecosystem, or submit an offer in a tender, a selection or a request for proposals (including framework ones), or an application and bid in an auction. Budget and corporate customers cannot choose an IE as supplier under a direct contract or a simplified procurement contract.
• In an ordinary tender, lot or auction, a single restricted item means the IE cannot submit an offer. In multi-item tenders and selections, only that item is blocked, and the IE can bid for the rest.
• When an IE is refused, no bid security or platform fee is blocked. The rule does not affect contracts already signed or offers submitted earlier, but the platform has closed IEs' listings for restricted items.

How many tenders IEs win: Tanlo data

We studied the register of completed deals on etender.uzex.uz (UZEX, the Uzbek Republican Commodity Exchange), covering tenders and best-offer selections, procedures larger than the electronic shop. IEs were identified by a marker in the winner's name (details at the end of the article).

This is an approximate estimate: some IEs appear in the register without a marker, and a couple of winners are foreign IEs. In 2026 there were about 156 distinct IE winners with a marker.

A typical IE deal in 2026 is worth about UZS 80 million (median), roughly one and a half times less than for companies. But there is no ceiling: the largest IE win this year was UZS 2.46 billion, and in 2025 it was UZS 7.42 billion. For the wider picture of competition, see our article on who wins tenders.

Taxes: 1% turnover tax and a UZS 5.28 billion VAT threshold

Since 1 January 2026, IEs have paid turnover tax at 1% (Article 467 of the Tax Code). Previously they paid a fixed tax or turnover tax at the general rate, usually 4%.

For large lots, something else matters more: Presidential Decree PF-100 of 26 May 2026 raised the threshold for mandatory transition to VAT and profit tax to 12,000 BRV (base calculation amount) from 1 June, which is UZS 5.28 billion at the current BRV of UZS 440,000. The Tax Code still contains the old threshold of 1 billion, but the decree already applies. The same decree also abolished the automatic transfer of importers to VAT.

How much money to keep for deposits and fees is covered in a separate calculation.

Risks nobody mentions

• Liability with personal assets. Under Article 25 of the Civil Code, a citizen is liable for their obligations with all their property, except property that by law cannot be seized. An IE pays penalties for a failed public contract out of personal savings and assets. Members of an LLC are generally not liable for the company's debts (Article 48 of the Civil Code), except in cases of subsidiary liability and personal guarantees.
• Too few hands. According to the Tax Committee (a page dated April 2025), an IE may hire up to 5 employees. Yet Article 36 of the law requires "the necessary … human and other resources to perform the contract".
• The register of unscrupulous contractors. Refusing to sign a contract or failing to perform it through the supplier's fault can land both an IE and a company in the register of unscrupulous contractors for two years.

What an IE should do right now

1. Find your type of activity in the list of Resolution No. 6 on lex.uz. If it is not there, you cannot bid for that subject of procurement on any platform.
2. Get a digital signature (EDS, E-IMZO) key as an IE. According to the Tax Committee, the fee for an IE is 10% of BRV, or UZS 44,000; the key is valid for up to 24 months.
3. The list of restricted ENKT codes has not been published, so on xt-xarid.uz, try opening the offer submission form before you prepare documents. If the platform will not let you submit, it is the filter, not a glitch.
4. If you have more than 5 employees, check with the tax office whether this breaches the rules for IEs: the customer is entitled to verify your human resources.
5. Watch your annual income: a large contract can push you over the 12,000 BRV threshold and onto VAT.
6. If you want to supply goods to organisations regularly, trade in building materials, take on construction contracts or provide consulting, you need a legal entity such as an LLC. The list in Resolution No. 6 restricts only individuals, and the Hayot Birja filter does not apply to companies.

Set up a filter for your category in the Tanlo catalogue, for example IT tenders for developers, and get new lots in Telegram without scrolling through irrelevant ones.

How we calculated

The Tanlo database holds the etender.uzex.uz register of completed deals: 157,195 deals from 2022 to 15 October 2026. IEs were identified by a marker in the winner's name: "ЯТТ", "YTT", "YaTT", "ЯККА ТАРТИБДАГИ ТАДБИРКОР" or "ИП" (except "ИП ООО" and "ИП АО", which denote foreign enterprises). Most IEs have no taxpayer ID (INN) in the register. The electronic shop, auctions and xt-xarid.uz are not part of the register, so the figures cover only tenders and selections on UZEX. Neither the Agency nor the platforms publish official statistics on IE participation in public procurement.

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