When did escrow accounts become mandatory for real estate transactions in Uzbekistan?

Escrow accounts became mandatory in two stages. For shared construction (off-plan housing) agreements, the requirement came into force on January 1, 2026. For all other real estate transactions and qualifying vehicle sales (vehicles no older than 10 years, categories M, N, O, and G), escrow became mandatory from April 1, 2026.

How much does an escrow account cost for a property transaction in Uzbekistan?

The escrow fee is fixed regardless of the transaction value. Real estate transactions attract a flat fee of 206,000 UZS per transaction. Vehicle transactions attract a flat fee of 103,000 UZS. This represents a dramatic reduction from the previous percentage-based commission model.

What happens if a developer delays handover of an off-plan property in Uzbekistan?

If a developer delays the handover of a shared construction property by more than 6 months beyond the contractual date, the buyer acquires the right to terminate the agreement and recover all deposited funds in full. This exit right applies to funds held in escrow under the mandatory shared construction escrow framework effective January 1, 2026.

Are escrow funds protected if a developer faces insolvency in Uzbekistan?

Yes. Escrow funds are ring-fenced under Uzbek law. They cannot be arrested, suspended, or seized in connection with any claims against the developer. This means that even if the developer encounters financial difficulties or insolvency proceedings, the buyer's deposited funds remain protected and available for return.

Escrow Accounts in Uzbekistan: Legal Mechanics & Use Cases

Uzbekistan has introduced mandatory escrow accounts for real estate and vehicle transactions in two legislative waves. The first wave — targeting shared construction (off-plan housing) — came into force on January 1, 2026. The second wave extended escrow requirements to all real estate and qualifying vehicle transactions from April 1, 2026.

01Background: Why Escrow?

Prior to these reforms, buyers of off-plan apartments and other real estate transferred funds directly to developers and sellers with limited legal protection. The government's stated objective — articulated in the Presidential Decree on the 'Single Housing Lifecycle' concept — is to protect buyer funds, increase market transparency, and align Uzbekistan's property market practices with international standards.

02Part 1: Shared Construction Escrow (Effective January 1, 2026)

July 1 – December 31, 2025: parallel operation of the old and new systems; developers could use either model
From January 1, 2026: escrow-only model mandatory for all new shared construction agreements

Key Requirements for Developers

Developers must contribute a minimum of 30% of their own funds before project financing can be drawn
The interest rate on project financing is linked to the balance held in escrow — the higher the accumulated buyer deposits, the lower the effective rate
Escrow funds cannot be arrested, suspended, or seized in connection with claims against the developer; they are ring-fenced for buyer protection
If a developer delays handover by more than 6 months beyond the contractual date, the buyer acquires the right to terminate the agreement and recover all deposited funds in full

03Part 2: General Property and Vehicle Escrow (Effective April 1, 2026)

From April 1, 2026, escrow accounts became mandatory for all purchase and sale transactions involving real estate and vehicles not older than 10 years (categories M, N, O, and G). The mechanism is straightforward: the buyer transfers the transaction amount into an escrow account at the notary's partner bank at the time of signing. Funds are held until the ownership transfer is registered, then released to the seller.

Fee Structure

Real estate transactions: 206,000 UZS per transaction (fixed, regardless of value)
Vehicle transactions: 103,000 UZS per transaction (fixed)

For a property sold at 500,000 USD, the old 0.5% commission model would have cost approximately 2,500 USD. Under the new fixed-fee regime, the same transaction costs approximately 15 USD equivalent — a reduction of over 99%.

04Compliance Considerations and Key Risks

Understating Contract Price

Escrow funds must match the stated contract price and flow through a regulated bank, creating an evidentiary paper trail visible to tax authorities and financial intelligence units. Buyers who agree to declare a lower price expose themselves to potential liability under tax and anti-money laundering legislation.

Foreign Currency Transactions

Real estate transactions in Uzbekistan are denominated in Uzbek som. Parties negotiating in USD must account for exchange rate movements between agreement signing and registration completion, as the escrow amount is fixed in som at the time of deposit.

05Summary of Key Dates and Rules

January 1, 2026: escrow mandatory for all new shared construction agreements
April 1, 2026: escrow mandatory for all real estate and qualifying vehicle transactions
Developer minimum equity: 30% own funds required before project financing
Buyer exit right: 6-month delay triggers full refund right
Escrow fee (real estate): 206,000 UZS fixed
Escrow fee (vehicles): 103,000 UZS fixed