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.
Primary sources: NAPP · Central Bank of Uzbekistan · Ministry of Justice · State Tax Committee · lex.uz legislation portal · IT Park Uzbekistan · Project office for development of national digital technologies.
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.
State fees and monthly operating charges by licence category
NAPP collects no application fee, but each licence carries a one-off state fee on successful issuance plus a monthly operating charge. All figures are denominated in BEU, at the 2026 rate of UZS 412,000 per BEU (USD approximations use UZS 12,350/USD).
| Licence | State fee (initial, BEU) | Approx USD | Monthly operating (BEU) | Approx USD / month |
|---|---|---|---|---|
| Crypto-exchange | 73,400 | ~USD 2.45M | 740 | ~USD 24,700 |
| Crypto-depository | 7,000 | ~USD 234,000 | 5 | ~USD 170 |
| Crypto-store | 2,600 | ~USD 87,000 | 185 | ~USD 6,200 |
| Mining-pool | 1,900 | ~USD 63,000 | 100 | ~USD 3,300 |
Because BEU is recalibrated in Uzbekistan's annual state budget, operational compliance plans must refresh the UZS and USD equivalents each January. The crypto-exchange fee is the highest in the Central Asian region. Crypto-store and Mining-pool fees, by contrast, sit at a small fraction of the exchange tier and are the more practical entry points for first-time NAPP applicants.
Ongoing obligations and prohibitions
- Licence validity: NAPP crypto licences are issued for unlimited periods, subject to continuing compliance with the charter-fund, local-node, AML and reporting rules.
- Record retention: All transaction data must be retained on Uzbek-resident infrastructure for at least five years and made available to NAPP on request.
- Prohibited activities: Hidden mining (unreported mining outside the licensed pool framework) and anonymous crypto-asset operations are explicitly outlawed, identifying KYC must be in place for every client relationship.
- Resident-transaction rule: Uzbek residents may buy and sell crypto only through domestic licensed VASPs. Foreign CASPs serving Uzbek residents without a NAPP licence face penalties under the 20 April 2024 Criminal Code and Administrative Liability Code amendments; NAPP has run proactive inspections since 2024, with Binance among the operators fined.
- Supervisory reporting: Licensed VASPs file periodic reports on client onboarding, transaction volumes, reserves and incidents, and submit suspicious-activity and currency-threshold reports on an ongoing basis.
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.
What are the capital and state-fee requirements per licence?
The Crypto-exchange category is the one with a fully codified capital rule on the NAPP Service Providers page: charter fund ≥5,000 BEU (~UZS 2.06bn / ~USD 160,000) with 3,000 BEU (~UZS 1.24bn / ~USD 95,000) reserved on a separate Uzbek commercial-bank account. A state fee of 73,400 BEU (~UZS 30.2bn / ~USD 2.45M) is payable on successful licensing. Crypto-store, Crypto-depository and Mining-pool licences carry lower charter thresholds set by NAPP per category but require the same own-funds rule, no borrowed, pledged or externally attracted funds.
Which authority handles the application. NAPP or a project office?
NAPP is the sole licensor. Supervision was centralised under NAPP by Presidential Decree UP-5296 in 2020, replacing the earlier National Agency of Project Management project office. Since 2024 NAPP has additionally absorbed regulator status for capital markets, insurance and gambling. Applications are filed directly with NAPP ([email protected] or Tashkent office) with no intermediate agency.
Can foreign directors manage the licensed entity?
Yes, foreign directors are permitted and foreign founders face no ownership cap on VASP licensing. In practice NAPP expects at least one executive resident in Uzbekistan for day-to-day operational accountability, plus criminal-record and fit-and-proper checks on all directors, founders and beneficial owners. Employment of local AML and IT staff is expected for the on-the-ground compliance function.
Is a local office and physical substance required?
Yes. NAPP requires the trading platform's technical and software tools, servers, to be located physically inside the Republic of Uzbekistan. The licensed entity must be an Uzbek-resident MChJ (LLC) or AJ (JSC) with a registered office, and must hold trading and settlement accounts with Uzbek commercial banks. Data residency and a Tashkent operational presence are non-negotiable.
What AML/CFT obligations apply to licensed VASPs?
VASPs must run an AML/CFT programme aligned with FATF Recommendations, NAPP internal-control rules and Central Bank of Uzbekistan guidance, covering KYC, beneficial-ownership identification, sanctions screening, transaction monitoring, travel-rule compliance, and filing of suspicious-activity and currency-threshold reports. Criminal Code and Administrative Liability Code amendments in force 20 April 2024 introduced penalties for illegal crypto activity, including for foreign CASPs serving Uzbek residents without NAPP authorisation.
How does crypto-to-fiat conversion via Uzbek commercial banks work?
All fiat settlement for a licensed VASP runs through Uzbek commercial banks in UZS. Trading accounts at a licensed Uzbek commercial bank are mandatory, and the charter fund itself must be certified by such a bank. From 1 January 2026 the NAPP/CBU joint stablecoin sandbox additionally permits individually approved 1:1 fiat-backed stablecoins in the supervised payments environment. Retail crypto-fiat conversion outside licensed VASPs and outside approved banking channels is restricted.
What is the status of tokenised assets and NFTs?
The 27 November 2025 Presidential fintech decree establishing the 1 January 2026 stablecoin sandbox also outlines a forward framework for tokenised assets. Under current NAPP rules, issuance and organised secondary trading of crypto-assets fall within the Crypto-exchange / Crypto-store perimeter. Pure collectible NFTs are not separately licensed, but any NFT platform offering fractionalisation, yield or organised trading is captured by the NAPP regime and must be licensed.
What customer and suspicious-activity reporting is required?
Licensed VASPs file periodic supervisory reports to NAPP covering client onboarding, transaction volumes, reserves and incidents, and submit suspicious-activity reports and currency-threshold reports to the Uzbek financial-intelligence framework on an ongoing basis. NAPP also conducts periodic inspections, and from 2024 has run proactive inspections of foreign CASPs. Binance among those fined, to enforce the licensing perimeter.
Can a Uzbekistan-licensed VASP serve foreign clients only?
Yes. NAPP licensing is territorial and does not force a domestic-only client base; a licensed VASP can serve international clients subject to its own market-access and sanctions checks. Crucially, the reverse is not permitted: foreign CASPs cannot serve Uzbek residents without a NAPP licence, and the 2024 enforcement turn has made that restriction operational.
What are the annual fees and renewal terms?
NAPP charges no application fee. The principal cost is the 73,400 BEU state fee on successful crypto-exchange licensing (~USD 2.45M at the 2026 BEU value). The licence is held subject to continuing compliance with charter-fund, local-node, AML and reporting rules; material breaches trigger suspension or revocation. BEU values are recalibrated in the state budget, so operational compliance plans must refresh capital figures annually.
How much is the NAPP state fee for each licence type?
NAPP charges no application fee but collects a one-off state fee on successful licensing plus a monthly operating charge. At the 2026 BEU value of UZS 412,000: Crypto-exchange 73,400 BEU initial (~USD 2.45M) and 740 BEU per month (~USD 24,700); Crypto-depository 7,000 BEU initial (~USD 234,000) and 5 BEU monthly (~USD 170); Crypto-store 2,600 BEU initial (~USD 87,000) and 185 BEU monthly (~USD 6,200); Mining-pool 1,900 BEU initial (~USD 63,000) and 100 BEU monthly (~USD 3,300).
How long is a NAPP crypto licence valid and what records must be kept?
NAPP crypto licences are issued for unlimited periods, subject to continuing compliance with charter-fund, local-node, AML and reporting rules. All transaction records must be retained on Uzbek-resident infrastructure for at least five years and produced to NAPP on request. Hidden mining and anonymous crypto-asset operations are explicitly prohibited, every client relationship must pass KYC.
What recent reforms or decree updates affect licensing in 2026?
Three changes shape the 2026 picture: the Presidential fintech decree signed 27 November 2025 launching the NAPP/CBU stablecoin sandbox from 1 January 2026; the 2024 Criminal Code and Administrative Liability Code amendments penalising unlicensed crypto activity, including by foreign CASPs; and the 2024 expansion of NAPP's regulator role to capital markets, insurance and gambling. The VASP tax holiday is currently retained through 1 January 2028.