Insights/Legal Briefing

Crypto-Asset Service Providers: Licensing in Uzbekistan

A practical guide to obtaining and maintaining a licence as a crypto-asset service provider in Uzbekistan under the NAPP regulatory framework.

Advizen Legal Practice
7 min read
12 pages
2025

Uzbekistan has established a dedicated licensing regime for businesses that deal in crypto-assets. The framework is administered by the National Agency for Perspective Projects (NAPP) and is set out in the Regulation on Licensing of Crypto-Asset Service Providers (reg. No. 3380, 15 August 2022). Only Uzbek-resident legal entities may obtain a licence — individuals and foreign companies are excluded.

01Four Types of Licences

A separate licence is required for each type of activity. The four licensed categories are:

  • Crypto exchange (крипто-биржа) — an electronic platform for buying, selling, and/or exchanging crypto-assets.
  • Mining pool (майнинг-пул) — a platform that consolidates computing power for the mining process.
  • Crypto depository (крипто-депозитарий) — a platform providing issuance, primary placement, and custody of crypto-assets.
  • Crypto shop (крипто-магазин) — a platform for the purchase and/or sale of crypto-assets.

All licences are issued for an unlimited duration. A licence cannot be transferred to another legal entity.

02How to Apply

Applications are submitted to NAPP's Licensing and Permitting Department by email (info@napp.uz), post, or in person at: 22 Nukus Street, Mirabad District, Tashkent. No fee is charged for reviewing the application.

The application package must include:

  • Application form stating the company's name, legal form, INN, registered address, place of business, bank details, and the type of licence sought.
  • Details of management (CEO and deputies) and all founders, disclosed through to the ultimate beneficial owner.
  • For foreign nationals in management or ownership: a criminal record certificate from the relevant foreign authority, apostilled or legalised, with a notarised translation into Uzbek.
  • For crypto exchanges only: a bank confirmation of charter capital contribution and reservation of the required amount.

NAPP checks the criminal record of Uzbek-national managers and founders itself. No documents beyond those listed above may be demanded from the applicant.

03Timeline

  • Expert panel review: up to 15 working days.
  • NAPP decision (grant or refuse): within 4 working days of the panel's conclusion — total maximum 20 working days from submission.
  • Applicant notified: within 1 working day of the decision.
  • Licence issued: within 3 days of state-duty payment.
  • If the state duty is not paid within 30 days of notification, NAPP may annul the licence decision.

If deficiencies are identified, NAPP issues a notice giving the applicant up to 30 working days to remedy them. The review clock pauses during this period. Once remedied, a re-review takes no more than 5 working days at no additional charge.

04Core Licensing Requirements

All four types of providers must comply with the following ongoing conditions:

  • Platform and all servers must be physically located on the territory of Uzbekistan.
  • All transaction data, user identification records, and business correspondence must be retained for five years.
  • Full compliance with Uzbekistan's AML/CFT laws and personal data protection legislation.
  • Advertising must carry mandatory risk warnings (including the risk of total loss of funds) and must not promise returns, mention bonuses, or depict minors.
  • No hidden mining and no operations involving anonymous crypto-assets.
  • Provide information to NAPP on request, free of charge.
  • Pay activity levies in full and on time.
  • Management and founders must be free of relevant criminal convictions and must not be linked to terrorism, money laundering, organised crime, or drug trafficking.
  • No offshore-registered companies in the ownership structure.

Additional requirements for crypto exchanges

  • Prices must be formed on the basis of supply and demand.
  • Minimum charter capital of 5,000 BRV (~USD 170,000) at the date of application, of which 3,000 BRV (~USD 102,000) must be held in a reserve account at a commercial bank in Uzbekistan.
  • Charter capital must be funded exclusively from the founders' own cash and property — no loans, pledges, or borrowed funds.

05Naming Restrictions

The company name and branding may not include the words "state", "government", "national", "Uzbekistan", or the full or abbreviated name of any Uzbek city, in any language or form.

06Licence Fees

One-time state duty (at licence issuance)

Fees are set in multiples of the Base Calculation Value (BRV = 412,000 UZS ≈ USD 34 at current rates):

  • Crypto exchange: 73,400 × BRV ≈ USD 2,496,000
  • Mining pool: 3,000 × BRV ≈ USD 102,000
  • Crypto depository: 7,000 × BRV ≈ USD 238,000
  • Crypto shop: 3,700 × BRV ≈ USD 126,000

Monthly activity levy (ongoing)

In addition to the one-time duty, licensed providers pay a monthly levy, due by the 10th of each month:

  • Crypto exchange: 740 × BRV ≈ USD 25,200/month
  • Mining pool: 100 × BRV ≈ USD 3,400/month
  • Crypto depository: 5 × BRV ≈ USD 170/month
  • Crypto shop: 185 × BRV ≈ USD 6,300/month

If a licence is issued before the 20th of a month, the levy is due in full for that month; if issued after the 20th, it accrues from the first of the following month. The levy is suspended from the first of the month following any suspension or cessation of activity.

07Suspension, Annulment and Hard Limits

NAPP may suspend a licence for up to 10 days where violations are found; longer suspensions require a court order (up to 6 months). Grounds for annulment by NAPP include: voluntary surrender, liquidation of the entity, or non-payment of the state duty. Annulment by court is required for more serious grounds including: systematic or single gross breach of licensing conditions, and use of forged documents.

The following are treated as single gross violations triggering annulment proceedings: hidden mining or operations with anonymous crypto-assets; persons with relevant criminal convictions in management or ownership; offshore companies in the ownership structure; use of borrowed funds to form charter capital; reduction of an exchange's charter capital below the required minimum; and servers located outside Uzbekistan.

Where a licence is annulled for gross violations or use of forged documents, no new licence may be issued for one year — and this restriction applies to any new entity created by the same founder or beneficial owner.

08How Advizen Can Help

The crypto licensing process in Uzbekistan involves substantial upfront fees, strict technical and compliance requirements, and ongoing regulatory obligations. Advizen's legal team assists clients in assessing which licence category applies to their business model, preparing the full application package, structuring the ownership to meet NAPP's requirements, and managing the relationship with the regulator after licensing.

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