Overview
Uzbekistan licences crypto activities through NAPP — the National Agency of Perspective Projects — under a statutory framework introduced by Presidential Decree PP-3832 of 3 July 2018 and consolidated through subsequent NAPP regulations. Four licence categories operate (Exchange, Store, Depository, Mining-pool), each with charter-fund and infrastructure requirements specified in BEU (basic estimated units). The 2026 stand-out features are a statutory 20-working-day decision SLA from NAPP and a 0% crypto tax on VASP turnover until 1 January 2028.
Local-node infrastructure is mandatory — service providers must operate the trading platform on servers physically located in Uzbekistan. Foreign founders are permitted with no ownership cap on VASP licensing. Banking with Uzbek commercial banks is required for trading and settlement.
The regulator — NAPP
NAPP is the sole licensor of Virtual Asset Service Providers in Uzbekistan. Since 2024 it also absorbed regulator status for capital markets, insurance and gambling under broader financial-services consolidation. The current consolidated NAPP Regulation on Crypto-asset Activities was issued in 2022 with material amendments through 2024 and a 2024 enforcement turn — proactive inspections of foreign CASPs serving Uzbek residents (Binance among those fined), and Criminal Code plus Administrative Liability Code amendments in force 20 April 2024 introducing penalties for illegal crypto activities.
Licence categories
| Licence | Scope |
|---|---|
| Crypto-exchange | Full exchange / multilateral trading venue |
| Crypto-store | Retail buy/sell outlet (non-multilateral) |
| Crypto-depository | Custody of client crypto-assets |
| Mining pool | Organised pool-mining operator |
Capital and local-node infrastructure
Charter-fund requirements are expressed in BEU. The confirmed 2026 BEU value is UZS 412,000 (set from 1 August 2025).
| Requirement | BEU | Approx UZS | Approx USD |
|---|---|---|---|
| Minimum charter fund (paid-up, own resources only) | ≥ 5,000 BEU | ~UZS 2.06 bn | ~USD 160,000 |
| Of which reserved on separate commercial-bank account | 3,000 BEU | ~UZS 1.24 bn | ~USD 95,000 |
Borrowed, pledged or externally attracted funds are prohibited for charter-fund formation; certification of the charter fund by a licensed Uzbek commercial bank is part of the application pack.
Mandatory local-node infrastructure: NAPP requires the trading platform's technical and software tools to be located on servers physically inside the Republic of Uzbekistan. Plan data-residency from day one.
2026 stablecoin sandbox
A Presidential decree plus NAPP/CBU joint implementing regulation launches a stablecoin sandbox from 1 January 2026. Only stablecoins backed 1:1 by recognised fiat or stable assets, individually approved by NAPP, can be used in the supervised payments environment.
Trading accounts with Uzbek commercial banks are mandatory. Settlement is in UZS plus approved stablecoins under the 2026 sandbox. The banking relationship is the operational backbone — secure it before completing the application pack.
High-level checklist (Crypto-exchange)
- Uzbek-resident legal entity — MChJ (LLC) or AJ (JSC). Foreign founders permitted.
- Charter fund of ≥ 5,000 BEU paid up from own resources only (no borrowed funds).
- Reserve 3,000 BEU on a separate commercial-bank account.
- Bank certification of charter fund by a licensed Uzbek commercial bank.
- Local-node infrastructure — servers physically located in Uzbekistan; ISO/IEC 27001-aligned IT controls.
- AML/CFT programme aligned with NAPP and CBU requirements; KYC, transaction monitoring, SAR/CTR filings.
- Trading account with an Uzbek commercial bank for UZS settlement.
- Internal governance — risk management, market-conduct policies, customer-protection rulebook.
- Application to NAPP; statutory decision within 20 working days on a complete file.
- Post-licensing: NAPP supervisory reporting, periodic inspections, ongoing AML compliance.
Process and timeline
| Stage | Duration |
|---|---|
| Entity setup (MChJ/AJ) plus local founders/directors | 1–2 months |
| Charter-fund deposit, bank certification, local infrastructure build | 2–4 months |
| Application pack — AML, KYC, policies, IT audit | 2–3 months |
| NAPP statutory review | 20 working days |
| Total realistic | 5–9 months |
NAPP charges no application fee.
Taxation
- VASP profit tax: standard 15–20% does not apply to registered VASPs on crypto-related turnover until 1 January 2028.
- Mining pools: income and profits from licensed mining pools and solar-powered farms are tax-exempt within the same horizon.
- VAT: crypto-related VASP services are zero-rated until 2028.
- Individuals: income from crypto (trading, mining, staking, salary-in-crypto, airdrops) exempt from personal income tax. No wealth tax, no inheritance tax, no customs duty.
FAQ
Why 1 January 2028?
The current VASP tax holiday horizon. The decree creating it sets that end date; renewal would need fresh legislation. Plan economics with that cliff in mind.
Can foreign nationals own the licensed entity?
Yes. There is no foreign ownership cap on Uzbek VASP licensing — a structural difference from sectors with statutory caps elsewhere in Uzbek law.
What does the local-node rule mean in practice?
The trading platform's servers must be physically located in the Republic of Uzbekistan. International cloud is permissible only for non-trading workloads; production trading runs on Uzbek-resident infrastructure.
How does Uzbekistan compare with Kazakhstan?
Kazakhstan via the AIFC is a free-zone common-law regime with permanent 0% AIFC tax through 2065. Uzbekistan is a domestic regime with a finite 0% horizon to 2028 — but lower entry capital and a faster statutory SLA.
What does the 2026 stablecoin sandbox cover?
Stablecoins 1:1-backed by recognised fiat or stable assets, individually approved by NAPP, usable in the supervised payments environment from 1 January 2026.