Explainer · Updated: October 22, 2026 · 8 min read
Appealing tender results in Uzbekistan: free, decided in 7 working days
Appealing public procurement results in Uzbekistan costs nothing: a complaint to the Complaints Review Commission for public procurement under the Ministry of Economy and Finance (the Commission) is free of charge, and a decision must be issued within 7 working days. By law, every participant has the right to complain. Typical grounds: the procurement commission rejected your offer without justification, set inflated requirements or chose the winner in breach of the rules. There is one trap, but it is a costly one: the contract with the winner can be signed as early as the day after the protocol is published, and at that point a complaint loses most of its value.
Based on the Law "On Public Procurement" and the Regulation on the review of complaints as in force on 22 October 2026. Links are at the end of the article.
Where disputes arise most often
In an auction the winner is determined by price alone, and in the e-shop (elektron do'kon) the contract is usually awarded at the lowest price, so the choice of winner is rarely disputed there. Even so, you can still challenge the cancellation of a lot, problems with the bid deposit or the platform's actions. Most disputes happen in tenders and in the selection of the best offers (otbor; on corporate platforms similar procedures are called "tanlov" or "request for proposals"). There, the winner is chosen by people: they check qualifications, award points and can throw out a bid over a single certificate. According to Tanlo data as of 22 October 2026, 1,651 of the 3,320 open lots across all platforms are procedures of exactly this kind. Almost every second lot.
Who can complain, and about what
The law gives the right to complain to every procurement participant: a company or an individual, a resident or a foreigner. You can complain about:
- the customer: a budget-funded organization or a corporate customer (a company in which the state holds 50% or more, and its subsidiaries);
- the procurement commission and its individual members;
- the platform, i.e. the operator of the electronic system, such as xarid.uzex.uz or xt-xarid.uz.
There is one condition: the actions must violate your rights. The right to complain is most solid for those who have submitted a bid. If the requirements kept you from taking part at all, complain before the deadline for offers.
Typical grounds expressly listed in the Regulation on the review of complaints:
- a bid was rejected or removed without a lawful reason;
- experience and qualification requirements were inflated or tailored to a single supplier;
- the bid deadline was changed without grounds;
- the customer bought from a single supplier instead of holding an open procedure, without legal grounds;
- collusion between participants, false information, restricted access to information.
The Commission or the courts
The law gives you a choice: the Complaints Review Commission or going straight to court. You are not required to go to the Commission first. Since 1 March 2025, the authority responsible for public procurement has been the Ministry of Economy and Finance, which also supports the Commission's work. The Commission is made up of representatives of government bodies, electronic platforms and the public.
| Commission under the Ministry of Economy and Finance | Court (economic or administrative) | |
|---|---|---|
| Fee | none | 10 BRV (base calculation amounts) — 4.4 million sum; small businesses pay half, 2.2 million |
| Timeframe | decision within 7 working days | usually considerably longer |
| The procurement in the meantime | frozen for up to 10 working days | continues unless the court prohibits signing or performing the contract |
| Decision | binding on the customer and the platform; can be challenged in court | can be appealed to a higher court |
BRV is the base calculation amount; since 1 September 2026 it has been 440,000 sum. For most suppliers, the sensible first step is the Commission: it is free, fast and halts the procurement. Court is for cases where you disagree with the Commission's decision or need to recover money.
The trap: there is no deadline to complain, but it is easy to be too late
Neither the law nor the Regulation says how many days you have to file a complaint. Because of that, many bidders take their time and lose. In practice, the window is set by the procedure itself:
- Selection of the best offers. The protocol is published for discussion for 2 working days. During that time you can file an objection with the procurement commission through the electronic system. Objections filed later are not considered.
- Tender. Once the protocol is published, you can ask the customer to explain the results. They must reply within 3 working days. This is not a complaint, but it is a quick way to find out why you lost points.
- The contract with the winner is concluded no later than 10 working days after the winner is determined. That is the customer's deadline, not your buffer: there is no mandatory standstill period before signing, and the contract may be signed immediately.
An objection in a selection and a complaint to the Commission are two different things. Missing the two-day window does not take away your right to complain, but after it the customer may sign the contract. Once it is signed, overturning the results is much harder, and the Commission does not hear disputes about contract performance at all.
How to file a complaint
The fastest route is electronic. In the participant's personal account on xarid.uzex.uz there are sections «Отправить жалобу в комиссию» ("Send a complaint to the commission") and «Мои жалобы» ("My complaints"). In the section «Протоколы и решения комиссии по рассмотрению жалоб» ("Protocols and decisions of the complaints review commission") you can also see how the Commission has ruled in similar disputes. If electronic filing is not available, submit the complaint in writing to the Ministry of Economy and Finance as the Commission's working body, and keep the stamp showing the date it was received.
Under the Regulation, a complaint must include:
- the company's name and address (for an individual, full name and place of residence), postal and email address, phone number;
- which actions or decisions you are challenging, and your arguments;
- evidence and a list of the attached documents;
- confirmation that a copy of the complaint has been sent to the parties: at least to the customer, and to the platform as well if you are challenging its actions;
- the signature of an authorized person and the date. Anonymous complaints are not considered.
Our advice: state the lot number and cite the specific clause of the procurement documentation that was breached. Attach the protocol, screenshots of the lot page, your bid and your correspondence with the customer. A sample structure for the text:
To the Complaints Review Commission for public procurement. Complainant: "…" LLC, TIN …, address, email, phone. Lot No. …, customer …, protocol dated … . The procurement commission rejected our offer on the grounds of "…". This contradicts clause … of the procurement documentation, under which …; the supporting document was included in our bid (Annex 2). We request that the procurement commission's decision be set aside insofar as it rejected our offer. Annexes: 1) protocol; 2) copy of the bid; 3) screenshot of the lot page; 4) confirmation that a copy was sent to the customer. Director …, signature, date.
Both the customer and you are invited to the hearing; you can send a representative with a power of attorney, and the Commission may hold the hearing by video link. If you fail to attend without a valid reason, the complaint will be heard without you.
What the Commission can decide
If the complaint is upheld, the Commission can:
- prohibit the customer from unlawful actions or from continuing an unlawful procedure;
- partially or fully overturn its unlawful decisions, such as the rejection of your bid;
- decide to terminate the procurement;
- add a contractor to the Unified Register of Unscrupulous Contractors.
It is important to understand that overturning an unlawful decision does not mean the contract automatically goes to you. Usually it is a chance to get back into the procedure and be evaluated fairly. The Commission's decision is published and is binding on the customer and the platform; parties who disagree with it can go to court.
Can a complaint hurt you? The law sets no penalty for complaining, and the Commission adds to the register of unscrupulous contractors those who have breached their obligations, not those who complain. The real costs are time, sometimes a lawyer, and your relationship with that particular customer. So complain on the facts and in a calm, businesslike tone. The register itself is covered in a separate article.
Common mistakes
- Waiting for the "final results". By then the contract may already be signed.
- Complaining without evidence. "An insider company won" will not work. You need to show which requirement was breached and where that can be seen.
- Confusing losing with a violation. If the winner honestly offered a lower price or scored more points under the published criteria, there are no grounds.
- Bringing a contract dispute to the Commission. Late payment or disputes over acceptance of deliverables are contract performance issues, and they are settled in court.
- Staying silent while the documentation is under discussion. Since 1 January 2026, draft procurement documentation has been put up for public discussion for at least 2 working days. It is cheaper to challenge inflated requirements before bids are submitted than after.
When the Commission cannot help, and where else to turn
The Commission does not review procurement by private companies or by companies in which the state holds less than 50%. If a project is financed by an international bank, its own rules and complaint procedure may apply by law, so check the procurement documentation.
If there are signs of collusion or restriction of competition, you can turn to the Committee for the Development of Competition and Protection of Consumer Rights; if there are signs of corruption, to the Anti-Corruption Agency. Both are among the bodies that oversee public procurement. For example, according to the agency, the results of 18 procurements worth 21 billion sum were cancelled in January–April 2025. These channels do not replace a complaint to the Commission, but they can complement it.
The procedure may change: on 8 September 2026, the Legislative Chamber passed in first reading a bill on permanent regional complaints commissions. Before filing, check the current version of the law on lex.uz.
What to do right now
- Check the status of your bids every day: a protocol can be published at any moment.
- Save screenshots of the lot page and the documentation on the day you submit: they may be changed later.
- In a selection, file your objection within 2 working days, and file a complaint with the Commission straight away, without waiting for a reply to the objection.
- In a tender, request an explanation of the results immediately.
- Prepare a complaint template with your company details and a power of attorney for a representative in advance.
The best complaint is the one you never had to write: choose lots where your company clearly meets the requirements. The Tanlo catalog brings tenders from six platforms into a single search, the AI review shows the participant requirements before you bid, and new lots matching your filters are sent to Telegram. How procedures decided by price differ from those decided by a commission is explained in "Auction, tender, selection and e-shop", and how much money you need to take part is covered in "A 100 million sum tender: how much cash to keep on hand".
FAQ
How much does it cost to file a complaint about public procurement results?
Filing with the Complaints Review Commission under the Ministry of Economy and Finance is free: neither the public procurement law nor the state duty law provides for a fee. In court, the fee is 10 BRV (4.4 million sum with the BRV at 440,000); small businesses pay half.
How many days do I have to file a complaint?
The law sets no specific deadline, but in practice the window is short: there is no mandatory standstill period before the contract is signed, so it may be signed right after the protocol (the customer's deadline is 10 working days). In a selection, objections are accepted for 2 working days. File your complaint on the day of the protocol or the day after.
Will the procurement be stopped after a complaint?
Yes, but not instantly: within 3 working days the Commission notifies the customer and freezes the procedure for up to 10 working days. A decision is issued within 7 working days of the complaint being received.
How do I file a complaint electronically?
The participant's personal account on xarid.uzex.uz has a section «Отправить жалобу в комиссию» ("Send a complaint to the commission"), along with «Мои жалобы» ("My complaints") and the Commission's published decisions. A written complaint is submitted to the Ministry of Economy and Finance as the Commission's working body.
Can I complain about a corporate customer or about the platform?
Yes. By law, companies with a state stake of 50% or more and their subsidiaries are state (corporate) customers, and actions of the electronic system operator, such as xarid.uzex.uz or xt-xarid.uz, are appealed to the same Commission.
Sources
- Law of the Republic of Uzbekistan No. ZRU-684 "On Public Procurement" of 22 April 2021, Articles 18, 19, 23, 51–54, 62, 69, 75, 78, 79 (as amended 25 July 2026), lex.uz
- Regulation on the procedure for reviewing complaints in public procurement (Ministry of Justice reg. No. 3013 of 14 May 2018, as amended 28 December 2024), lex.uz
- Cabinet of Ministers Resolution No. 276 of 20 May 2022 — Regulation on public procurement procedures (paras. 99–103, 161), lex.uz
- Law of the Republic of Uzbekistan No. ZRU-600 "On State Duty" (rates for economic and administrative courts), lex.uz
- Presidential Decree UP-115 of 23 June 2026: BRV of 440,000 sum from 1 September 2026, lex.uz
- xarid.uzex.uz: personal account — «Отправить жалобу в комиссию» ("Send a complaint to the commission"), «Протоколы и решения комиссии по рассмотрению жалоб» ("Protocols and decisions of the complaints review commission") (checked 22 October 2026)
- Presidential Decree UP-259 of 26 December 2025 (public discussion of procurement documentation), lex.uz
- Law ZRU-1005 of 27 November 2024 (Ministry of Economy and Finance as the authorized body from 1 March 2025), lex.uz
- Gazeta.uz, 23 May 2025: Anti-Corruption Agency — results of 18 procurements worth 21 billion sum cancelled
- UzA, 8 September 2026: Legislative Chamber passes in first reading a bill on permanent regional complaints commissions
- Tanlo database: open lots by procedure type across all platforms (query of 22 October 2026)