How Uzbekistan Pushes to Become Dispute Resolution Hub

Uzbekistan is becoming a leading international venue for resolving commercial and investment disputes. This is reflected not only in the development of a modern dispute resolution infrastructure, but also in the growing confidence of international businesses in Uzbekistan as a neutral and reliable jurisdiction.

Diana Bayzakova, Director of the Tashkent International Arbitration Centre (TIAC) at the Chamber of Commerce and Industry of Uzbekistan, discusses the establishment of the Tashkent International Commercial Court (TICC), its interplay with TIAC, the role of state courts, the advantages of arbitration, and Uzbekistan’s prospects as a venue for resolving international disputes.

Businesses choose Uzbekistan

An increasing number of foreign businesses are turning to TIAC to administer their cross-border disputes with no connection to Uzbekistan, reflecting TIAC’s growing reputation as a trusted and neutral venue for commercial dispute resolution. TIAC was established under the Presidential Resolution No. 4001 in November 2018 as part of the investment climate reforms initiated by the President of the Republic of Uzbekistan, Shavkat Mirziyoyev.

As an example, recent international commercial cases administered by TIAC include a commercial dispute between a South Korean company and a Kazakh company, as well as a commercial dispute between a Russian company and a Singaporean company. In 2024–2025, around 25%, or one quarter, of the cases administered by TIAC involved disputes in which both parties — both the claimant and the respondent — were companies not registered in Uzbekistan. In 2026, this trend became even more pronounced. During the first half of the year, more than 60% of the cases registered with TIAC between 1 January 2026 and 30 June 2026 involved disputes in which both claimant and respondent were companies registered outside Uzbekistan.

For us, this is one of the strongest indicators of trust. It reflects a broader transformation in how Uzbekistan is perceived internationally — not merely as a destination for trade and investment, but as a trusted, neutral and internationally credible venue for the resolution of commercial disputes.

In recent years, Uzbekistan has undertaken large-scale reforms of its judicial system. Considerable efforts are being made to ensure that it meets the needs of both domestic and foreign businesses. At the same time, it is important to understand the characteristics of each dispute resolution mechanism. Where a dispute is brought before the national courts of Uzbekistan or any other jurisdiction, it will ordinarily be determined in accordance with the applicable domestic law.

Investors should have choice

Court proceedings in Uzbekistan are conducted in the state language; however, submissions may also be accepted in Russian. At the same time, English remains the predominant language of international commerce, widely used for negotiating, drafting and performing cross-border contracts, while English law continues to be one of the most familiar, predictable and widely chosen legal systems for foreign investors and their legal advisers.

This is precisely why establishing the Tashkent International Commercial Court (TICC) will complement the existing dispute resolution infrastructure. TICC will operate in English, with international judges and on the basis of English common law principles. Such a court will provide investors with another familiar option. Businesses may be able to choose among national courts, TIAC, or referral of their disputes to an international commercial court, i.e. the TICC.

These institutions will not compete with one another. On the contrary, they form a single ecosystem in which investors can choose the most appropriate dispute resolution mechanism depending on the nature of the contract, the applicable law, the location of the assets and other relevant circumstances.

Main advantage of arbitration is enforcement of awards

One of the key differences between state courts and international arbitration lies in the ability to enforce an arbitrator’s final judgment, or an arbitral award in legal language, outside the country where it was issued. Even judgments rendered by the U.S. or English courts cannot always be enforced without difficulty in another jurisdiction or country. At present, there is no universal or widely accepted international treaty for enforcing court judgments comparable in scope to the system for enforcing arbitral awards.

Uzbekistan has mutual legal assistance treaties with a number of countries, including the CIS states and China. However, these arrangements cover only a limited number of jurisdictions. If the respondent’s assets are situated in France, Germany, England, the United States or another country with which Uzbekistan has no treaty providing for the reciprocal recognition and enforcement of judgments, enforcing an Uzbek court judgment may be significantly more difficult.

International arbitration operates under a different regime largely governed by the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards.

More than 170 countries are parties to this Convention. As a result, a TIAC award, for example, can be enforced in virtually all major commercial jurisdictions worldwide — from Turkey and Saudi Arabia to Australia and the United States. This cross-border enforceability is one of the greatest advantages of arbitration over court litigation.

We are already aware of a TIAC award that has been recognised in Russia. Enforcement proceedings involving our awards are also underway in Kazakhstan, China and Poland. The duration of the enforcement process depends on the jurisdiction concerned. For example, proceedings in Poland may take around a year, as per information received from the relevant parties, whereas similar matters are considered significantly faster in Uzbekistan.

Pro-arbitration approach has taken shape in Uzbekistan

International arbitration cannot exist in isolation from the national judicial system. Once an arbitral award has been issued, it may require compulsory enforcement, and this procedure is carried out through the national courts. At this stage, the court does not review the merits of the dispute or reconsider the arbitrator’s findings. Instead, it verifies compliance with procedural requirements: whether the parties were properly notified, whether a valid arbitration agreement existed, and whether other procedural requirements of the arbitration proceedings were observed. For this reason, it is critically important for every arbitration centre that national courts adopt a pro-arbitration approach. National courts recognise and enforce arbitral awards and therefore form an integral part of an effective commercial dispute resolution system.

Such a practice has already become firmly established in Uzbekistan. The country’s national courts have played a pivotal role in fostering a modern, arbitration-friendly legal environment by consistently supporting international arbitration and upholding the principles of the New York Convention. Such an approach will provide businesses with the confidence that arbitral awards will be recognised and enforced in a predictable, impartial and efficient manner. Indeed, in terms of judicial support for arbitration, Uzbekistan today compares favourably with, and in some respects surpasses, many more established jurisdictions.

To date, 100% of TIAC awards submitted to the Uzbek courts for enforcement have been enforced, including an arbitral award against a company in which the state holds an ownership interest. This is particularly significant because a persistent misconception remains that arbitral awards cannot be enforced in Uzbekistan against state-owned entities or companies with state participation. Uzbek judicial practice demonstrates precisely the opposite.

Uzbek courts have recognised and enforced not only TIAC awards, but also awards rendered by foreign arbitral institutions, including an arbitral award exceeding US$13 Mln against Uzbekneftegaz. Despite attempts to challenge the award, the Uzbek courts have recognised and enforced it. Cases such as this illustrate that an effective arbitration ecosystem depends not only on access to modern arbitral institutions such as TIAC, but also on a judiciary that understands and supports the arbitral process. Continuous professional dialogue and practical alignment between national courts and arbitral institutions are essential to ensuring that arbitral awards can be recognised and enforced efficiently and predictably.

This cooperation extends beyond legal principles to practical aspects of case administration. For example, TIAC uses a hybrid postal notification system for serving procedural documents — the same system used by Uzbekistan’s national courts. It not only provides proof of delivery but also records the contents of every envelope sent. While this may appear to be a minor procedural detail, it can prove decisive at the enforcement stage, where the court must be satisfied that the parties were properly notified and that due process requirements have been met.

Language, applicable law and specialist arbitrators

Arbitration gives parties something that no national court in any country can offer: the freedom to shape the dispute resolution process. The parties are free to choose the language of the proceedings — whether Uzbek, Russian, English or any other language — and TIAC appoints arbitrators who combine proficiency in the chosen language with the expertise required for the dispute.

Equally, the parties in arbitration proceedings are free to choose the applicable law. It need not be the law of Uzbekistan. TIAC has administered, and continues to administer, disputes governed by English, Dutch, Russian, Kazakh law, as well as international conventions and other legal systems.

Parties may also select arbitrators with recognised expertise in the relevant industry. TIAC has appointed arbitrators from England, the United States, Hong Kong, Singapore, Russia and many other jurisdictions, bringing together the linguistic, legal and industry expertise required to resolve each dispute in its proper commercial and technical context.

This is particularly valuable in sectors such as construction, oil and gas, energy, infrastructure, technology, where disputes frequently involve highly specialised technical and commercial issues. Unlike judges in national courts, who cannot always develop expertise across every specialised field, arbitrators may be selected for their extensive experience in the relevant industry — from construction and energy to sports law and even the nuclear sector. This allows disputes to be resolved with a deep understanding not only of the applicable legal principles, but also of the commercial and technical realities that underpin them.

Award is issued within eight months

Another significant difference between arbitration and court litigation is that arbitral awards are final. There is no appeal in arbitration on the merits of the dispute. In state courts, a case may pass through the court of first instance, the appellate court, the cassation court and may go even further. These multiple stages inevitably affect the overall duration of dispute resolution.

According to TIAC’s internal analysis, the average time from the filing of a claim or request for arbitration to the issuance of a final arbitral award is approximately 8 (eight) months. For comparison, the average duration of arbitration proceedings is approximately 11.7 months in Singapore, around 16 months in London, and up to 26 months in Paris. At the same time, eight months should not be regarded as an excessively long period.

Since an arbitral award is final, every procedural requirement must be observed with the utmost care. One of the most time-consuming stages is often notifying a respondent located outside Uzbekistan. In some cases, a party refuses to accept documents or deliberately avoids participating in the proceedings. The arbitration centre must take every necessary step to ensure that the award will not encounter enforcement difficulties at a later stage.

Arbitration is a product of the parties’ agreement

The dispute can be referred to arbitration only if the parties have agreed to do so and have included the relevant arbitration clause in their contract. Arbitration is based on the parties’ mutual agreement.

In some cases, companies voluntarily inform us that they have included a TIAC arbitration clause in their contracts. In some projects, TIAC may also participate in discussions concerning the dispute resolution clause by explaining the features of arbitration and the administration by TIAC, enabling the parties to make an informed choice of dispute resolution mechanism and arbitral institution.

Based on the contracts known to TIAC, the aggregate value of agreements containing a TIAC arbitration clause exceeded US$2 billion in 2025. This figure reflects only those contracts in respect of which TIAC has received confirmed information. The actual value is likely to be significantly higher, as parties are under no obligation to notify the Centre when they include a TIAC arbitration clause in their contracts.

There have also been instances where parties have amended existing contracts to designate TIAC as their arbitral institution. In some cases, the parties have agreed, by way of a supplementary agreement, to replace institutions such as the Singapore International Arbitration Centre (SIAC) or the ICC International Court of Arbitration with TIAC. Such a change is possible only by mutual agreement of the parties, making it a particularly strong expression of their confidence in the institution.

Arbitration cannot be low-cost, but costs can be reduced

TIAC has never aimed to position itself as an institution offering low-cost arbitration; rather, it has sought to ensure that the work of qualified international arbitrators is remunerated in accordance with international standards.

This approach helps attract highly qualified professionals and ensure the quality of arbitral decisions. At the same time, TIAC’s cost structure allows parties to achieve significant savings compared with the world’s leading international arbitration centres, while preserving that value.

TIAC does not charge an administrative fee. The only payment made directly to the centre is the registration fee for filing a claim, currently $950. As a result, the remaining costs consist of the arbitrator’s fees. Parties may either use TIAC’s standard schedule of costs or agree on an alternative method for calculating the arbitrator’s remuneration, such as a fixed fee or an hourly rate.

In one of the latest cases that TIAC administers with a claim value of around $65 mln, the state court fee for filing that claim with the Uzbek economic court would have amounted to 2% of the claim value, or circa $1.3 mln. Under TIAC’s standard schedule of costs, the arbitration cost would have been significantly lower, around $150,000. But parties have agreed to remunerate an arbitrator based on a fixed hourly fee of $500, thereby reducing the overall arbitration costs severalfold.

On average, the absence of an administrative fee enables parties to reduce total arbitration costs in TIAC by an average of 30–50% compared with proceedings in London, Paris, or Singapore, while benefiting from the same high-quality case administration.

Confidentiality remains one of the key advantages

Unlike state court proceedings, arbitration is generally confidential. Accordingly, TIAC may publish an arbitral award only with the parties’ consent. Awards are usually published in anonymised form: with all information capable of identifying the parties removed, while preserving the tribunal’s legal reasoning. This provides businesses with the necessary level of confidentiality while also allowing the legal community to understand how arbitral practice is developing.

Uzbekistan has every opportunity to become an international dispute resolution hub

By 2030, I envisage Uzbekistan as one of the world’s modern jurisdictions and a leading international centre for the resolution of commercial and investment disputes.

It should be a venue chosen not only for disputes involving Uzbek parties, but also for regional and international disputes with no connection to Uzbekistan. All the signs suggest that the country has already embarked on this journey.

The task now is to build on this momentum by further strengthening Uzbekistan’s position and increasing international awareness of its dispute resolution infrastructure among businesses, investors and the global legal community, both within the country and abroad.

The establishment of the Tashkent International Commercial Court, the continued development of TIAC, and the ongoing modernisation of the national judiciary are not separate initiatives. Together, they form the foundations of a single, coherent dispute resolution ecosystem.

The most important objective is to maintain the pace of reform implementation. Over the past several years, Uzbekistan has undertaken an extraordinary transformation to reach the position it occupies today. The results are already evident: an increasing number of foreign companies are entrusting our jurisdiction with the resolution of disputes that have no connection to Uzbekistan. The challenge now is to consolidate and deepen that confidence, establishing Uzbekistan as a trusted neutral venue for international dispute resolution for decades to come.