Explainer · Updated: October 7, 2026 · 10 min read

Uzbekistan's procurement blacklist: what gets you banned for 2 years

A single failed deal with a state customer can lock a company out of all public procurement in Uzbekistan for two years. The tool for this is the Unified Register of Unscrupulous Contractors — the country's procurement blacklist. We went through the law, the regulation on the register and the public list on xarid.uzex.uz itself. Here is what gets a supplier listed, who decides, how to check yourself and your partners, and what to do if you end up on it.

Tanlo count based on the public list "Insofsiz ijrochilarning yagona reyestri" on xarid.uzex.uz, downloaded 7 October 2026.

What the register of unscrupulous contractors is

It is the state blacklist of suppliers. It is established by Article 48 of the Law "On Public Procurement" (ZRU-684), and that article has not changed since 2021. The procedure is set out in the Regulation on forming the register (registration No. 3599), in force since 18 April 2025.

Under the regulation, the register is kept by the Ministry of Economy and Finance. But Presidential Decree UP-17 of 4 February 2026 transferred the ministry's procurement powers to the new Agency for Industrial Cooperation and Public Procurement. Since July 2026 companies have been listed by orders of the Agency's director — this is visible in the entries themselves.

There is one consequence, and it is harsh. Having no entry in the register is a mandatory requirement for any bidder (Art. 36). If there is an entry, the procurement commission or the platform operator disqualifies the company (Art. 42). The ban covers every platform and procedure: the e-shop, auctions, selection of best offers and tenders.

Four reasons to get listed

The list of grounds in the law is closed: under the regulation, the commission considers only these. The register includes:

1. A winner who refused to sign the contract or evaded it. Separately, the law prohibits dumping — bidding an artificially low price and then refusing to sign or perform (Art. 46).
2. A contractor found guilty of non-performance or improper performance. Force majeure is an exception.
3. A bidder who submitted false or forged documents, hid affiliated parties bidding in the same lot, or failed to disclose a conflict of interest.
4. A contractor convicted by a court of fraud, forgery or corruption. In practice these are sentences against managers and founders, and not only for those offences: the article most often cited in the public list is Art. 167 of the Criminal Code (embezzlement).

Who puts a company on the register, and how

The regulation provides three routes:

• Automatically. If a winner refuses or evades the contract, the e-system operator passes the data on and the entry appears without a hearing or notice. It can only be challenged in court.
• By decision of the Complaints Review Commission. If it upholds a complaint, it may list the contractor (Art. 79). Complaints are reviewed within 7 working days, and the entry is made the same day.
• By Agency decision on an application. Applications may come from the customer, state inspection bodies — or any individual or legal entity, including a competitor.

On an application, the decision is taken within 15 days, based on the conclusion of a working commission of at least 7 members. You must be notified at least 3 days before the hearing and have the right to attend or submit written explanations. The commission checks only one thing: whether a ground from the closed list exists. If not, or if the documents are unreliable, listing is refused. Notice of listing is sent the same day, in writing or to your account on the platform.

Prices rose or the exchange rate jumped — is that force majeure?

Almost certainly not. A business is liable for non-performance unless it proves that performance was prevented by force majeure. Article 333 of the Civil Code expressly excludes breaches by your own suppliers, unavailability of goods on the market and lack of funds.

The Chamber of Commerce and Industry issues force majeure certificates under a closed list (Regulation approved by Cabinet Resolution No. 231 of 7 June 2023): natural disasters, war, blockade, import or export bans, sanctions, epidemics and major accidents. Price or currency rises are not on it, and on the Article 333 grounds the Chamber must refuse.

What is left:

• Raising the price is almost impossible. An additional agreement is allowed only if it does not change essential terms, and the law names a price increase as one of them (Art. 34).
• You can agree to terminate. Termination by mutual agreement (Art. 382 of the Civil Code) is not in itself a ground for listing — that requires a finding of guilt. But if the customer records it as non-performance, it becomes a dispute, so keep all correspondence in writing.
• Price the risk in up front. If the goods are imported or the price depends on the exchange rate, account for it before bidding, not after winning.

How long the ban lasts and how to get off the register

Two years from the date of listing, whatever the ground. Then the company is removed automatically and notified the same day.

Early removal is possible only through the courts: Article 48 gives the right to appeal. After a court decision the company is removed within one working day. Neither the law nor the regulation says which court to go to or what the filing deadline is, so contact a procurement lawyer straight away. If you were not notified of the hearing 3 days in advance, as the regulation requires, that is a procedural breach and an argument in court.

While the entry is in force, new bids are rejected at any stage (Art. 42). The law does not provide for terminating contracts already signed — they must be performed, or penalties and new claims will follow.

What the public list shows: 45 entries

The list is published on xarid.uzex.uz under "Unified Register of Unscrupulous Contractors". On 7 October 2026 it had 45 entries. Going by the dates, 35 are active and 10 already removed — but for almost all the "removed" ones the dates appear to be wrong (more below). By listing date, 14 entries appeared on 11 September 2025 and another 22 between June and September 2026. In April 2025, according to anhor.uz, the list contained no companies at all.

7 of the 34 entries give only a criminal case number, without the text of the sentence.

What matters for an ordinary supplier:

• Six of the seven "contract" entries involve one customer, Navoiyazot JSC. Each has an economic court ruling that the supplier failed to perform. The order is: court first, register second.
• Conflict of interest is not just about big bribes. In one case the chief accountant of a children's school owned 100% of a supplier run by his brother. In another, a company failed to disclose that its founder was the brother-in-law of an official at the state body it signed two contracts with, worth 173 million soums in total. Both companies were listed on 4 September 2026.
• One altered paper. A bidder changed the number and validity date of a sanitary certificate attached to its bid. That was enough.
• The public list contains not a single entry for refusing to sign a contract. All 45 rest on court or inspection decisions, although the regulation provides for automatic listing for refusals. We could not verify where such entries are shown — so a company's absence from the public list is not a guarantee that it is not on the register.

What walking away from a won tender costs

Two years without state contracts is not the only loss:

• The bid deposit is forfeited and goes to the customer (Cabinet Resolution No. 276; for selection and tenders also Art. 63 and 70 of the law). In the e-shop the deposit is 3% of your offer, in auctions 3% of the starting price. In selection and tenders the procurement commission sets it: up to 3% and up to 5% respectively. In the e-shop and auctions the deposit stays blocked until the contract is fully performed.
• Dumping costs more. Auctions and the e-shop have a separate rule: if you go 20% or more below the starting price (auction) or the offer chosen by the customer (e-shop), an additional deposit equal to the full difference is required, capped at 100 BRV (44 million soums) for lots up to 2,500 BRV and 1,000 BRV (440 million soums) for larger ones. BRV is the base calculation amount; since 1 September 2026 it equals 440,000 soums.
• Penalties once the contract is signed. Unless the contract says otherwise, the Law on the Contractual and Legal Framework of Business Entities sets a penalty of 0.5% of the unperformed part per day for late delivery, works or services, capped at 50% of its value. Poor-quality goods carry a 20% fine. Paying penalties does not release you from compensating losses. Read the liability section of the draft contract before you bid.

For a full breakdown of bidding costs, see "How much money you need to bid in 2026".

How to check a company in the register

1. Open xarid.uzex.uz/info/unfair-executor. Access is free, no registration needed.
2. Search by taxpayer number (INN/STIR), not by name. Names are spelled inconsistently — MCHJ or MChJ, different quotation marks, line breaks.
3. Look at the decision number and date and the name listed. Listing and removal dates may contain errors (see above).
4. Check not only yourself but also subcontractors and consortium partners before putting them in your bid.

A new company won't help. Formally an entry is made by taxpayer number, but in practice the register is tied to people. The regulation requires publishing the names of the manager and beneficial owner, and the public list already contains two pairs of companies listed under a single sentence against the same person. A new company of the same people can be disqualified for affiliation (Art. 42), and hiding that link is itself a ground for listing (Art. 48).

How to stay off the register: a checklist

• Calculate your costs before bidding, not after. Bid only a price at which you can actually perform. This is the main protection against refusal and dumping accusations.
• Sign the contract on time. In every procedure the system generates the contract, but it counts as concluded only once both parties sign it with an e-signature (Cabinet Resolution No. 276, para. 9). In selection and tenders this must happen within 10 working days of the winner being determined. An unsigned contract is evasion, with all the consequences. Keep your e-signature valid and don't miss notifications in your account.
• Keep e-shop offers up to date. If the customer picks your offer and the price is stale or the goods are gone, backing out counts as a winner's refusal.
• Never attach "adjusted" papers. Certificates, conclusions and licences must be valid and genuine — inspectors check the numbers.
• Disclose connections. If relatives of the customer's staff are among your founders or managers, or you are linked to another bidder in the lot, say so up front.
• Document the customer's fault. If the contract fails because of the customer (site not provided, payment delayed, specification changed), send dated letters. You will most likely have to prove you were not at fault, and dated correspondence is your main evidence.
• Got notice of a hearing? Attend with documents or submit written explanations in advance.

Less rush means less risk. Tanlo pulls tenders from all six platforms into one feed and sends new lots to Telegram, and AI analysis of tender documents shows requirements and deadlines right away — leaving time to do the maths before bidding, not after winning.

Foreign bidders should also read "Can a foreign company take part in Uzbekistan's public procurement?".

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