Legislative Updates in the Field of Artificial Intelligence and Personal Data Regulation – Uzbekistan – April 2026
Amendments and Additions Introduced to the Law “On Personal Data”
On 26 March 2026, the Law of the Republic of Uzbekistan (“Uzbekistan”) “On Amendments and Additions to the Law of Uzbekistan ‘On Personal Data’” No. 1125 (the “Law No. 1125”) was adopted.
Below is an overview of the key amendments and additions to the regulation of personal data.
The Revised Procedure for Storage of Personal Data of Citizens of Uzbekistan
Pursuant to the Law No. 1125, the revised version of the Law “On Personal Data” introduces a substantially new approach to the storage of personal data of citizens of Uzbekistan. Previously, all personal data of citizens of Uzbekistan were subject to mandatory storage within the territory of Uzbekistan. Under the new rules, mandatory localization applies only to the following categories of personal data:
- biometric data of individuals,
- genetic data of individuals,
- data of individuals users of local telecommunications services in Uzbekistan.
With respect to other categories of personal data, their storage and processing outside the territory of Uzbekistan is permitted, provided that one of the following conditions is met:
- the foreign state is recognized as ensuring an adequate level of personal data protection,
- the operator adopts and complies with standard contractual clauses or binding corporate rules that meet the requirements approved by the authorized state body,
- the operator complies with international standards in the field of personal data management and storage, as approved by the authorized state body.
At the same time, the list of foreign states ensuring an adequate level of personal data protection is determined by the Cabinet of Ministers of Uzbekistan. As of the date of publication of this overview, the list has not yet been approved by the Cabinet of Ministers of Uzbekistan.
Rules on the Processing of Personal Data for Personal Purposes Clarified
Pursuant to the Law No. 1125, the revised version of the Law “On Personal Data” clarifies that it does not apply to the processing of personal data by an individual for personal and household purposes. At the same time, the provision stating that personal processing should not be related to professional or commercial activities has been removed.
Thus, the requirement to separately assess whether that processing is connected to professional or commercial activities has been eliminated, leaving the personal or household nature of the processing as the primary criterion.
Scope of Exceptions from the Application of the Law “On Personal Data” Expanded
Furthermore, the revised version of the Law “On Personal Data” clarifies that not only the processing of personal data constituting state secrets, but also of the information related to defense and national security is exempt from its scope.
New Initiatives in Regulating the Use of Artificial Intelligence in Uzbekistan
On 21 January 2026, the Law of Uzbekistan “On Amendments and Supplements to Certain Laws of Uzbekistan in Connection with Artificial Intelligence Regulation” No. ZRU-1115 (the “Law No. 1115”) was adopted.
Below is an overview of the key amendments introduced by the Law No. 1115 concerning the regulation of relations arising from the use of artificial intelligence.
Introduction of the Definition of “Artificial Intelligence”
Pursuant to the Law No. 1115, amendments and additions were made to a number of regulatory legal acts. In particular, the Law of Uzbekistan “On Informatization” No. ZRU-560-II dated 11 December 2003 (the “Law No. 560-II”) was supplemented with the definition of artificial intelligence (“AI”), which is defined as a set of technological solutions enabling the simulation of human cognitive functions (including self-learning and problem-solving) and producing results in the performance of specific tasks comparable to the results of human intellectual activity.
Measures for the Development of AI
The Law No. 1115 establishes provisions aimed at further development of AI in Uzbekistan. In particular, amendments to the Law No. 560-II designate the creation of the necessary conditions for the implementation and development of AI as the main area of state policy development, as well as the establishment of the legal, technological, and economic foundations for this development.
In addition, the Ministry of Digital Technologies of Uzbekistan, acting as the specially authorized state body, has been vested, inter alia, with the following functions:
- creating conditions for attracting investment in the AI sector,
- developing technical infrastructure for data processing of state bodies based on AI technologies,
- organizing training, retraining, and advanced professional development of specialists in the field of AI.
Procedure for the Use of AI in the Creation of Information Resources and Operation of Information Systems
In accordance with the Law No. 1115, the Law No. 560-II was supplemented with an additional article regulating the use of AI in the creation of information resources and operation of information systems. Information resources created using AI, as well as information systems operating based on AI technologies, shall not cause harm to individuals, their life, health, freedom, honor, dignity, or violate other inalienable rights.
Furthermore, when making legally significant decisions affecting human rights and freedoms, it is prohibited to rely exclusively on conclusions generated by information resources and systems created using AI technologies.
Restriction on the Dissemination of Publicly Available Information Using AI Technologies
Pursuant to the amendments to the Law No. 560-II, owners of websites and/or website pages, as well as other information resources (the “Information Resources”), including bloggers, are obliged to prevent the use of their Information Resources, on which publicly available information is posted on the global Internet, for the unlawful processing of personal data using AI technologies.
A key innovation is the explicit prohibition not only of the unlawful processing, but also of the subsequent dissemination of personal data using AI technologies in mass media, telecommunication networks, or on the Internet.
Administrative Liability for Violations of Personal Data Legislation Using AI Technologies
In accordance with the Law No. 1115, the Code of Uzbekistan on Administrative Liability was supplemented with provisions establishing administrative liability for the unlawful processing of personal data using AI technologies, as well as their dissemination in mass media, telecommunication networks, or on the Internet.
The above violations are punishable by an administrative fine ranging from fifty to one hundred base calculation units (approximately USD 1,690 – 3,380) with confiscation of the instruments of the administrative offense.
Rules on the Use of AI Technologies and Systems Defined in Uzbekistan
On 14 March 2026, the Minister of Digital Technologies of Uzbekistan issued Order No. 3787 “On Approval of the Rules of Ethics for the Development, Implementation and Use of Artificial Intelligence-Based Solutions” (the “Order No. 3787”), which will enter into force on 17 June 2026.
Below is an overview of the key provisions of the Order No. 3787 governing the development, implementation and use of AI technologies and systems.
Ethical Rules Approved and Key AI Concepts Defined
Pursuant to the Order No. 3787, the Rules of Ethics for the development, implementation and use of AI-based solutions (the “Ethical Rules”) have been approved. The purpose of the Ethical Rules is to ensure the safe use of AI systems operating based on AI technologies, as well as to protect human rights, freedoms and legitimate interests.
The Ethical Rules, inter alia, establish definitions of key terms. In particular, the “Ethical Rules” are defined as a set of fundamental rules and requirements establishing safety and ethical standards for the development, implementation and use of AI-based solutions in relation to AI technologies, AI systems, and AI participants (the “Participants”), referring to natural and legal persons engaged in the development, implementation and use of AI technologies and systems within the territory of Uzbekistan.
The Participants are required to strictly comply with the Ethical Rules when using AI technologies and systems. Furthermore, the Participants should not treat decisions made by AI technologies and systems as final decisions.
In addition, the Ethical Rules define the concept of “AI systems”. The AI systems are understood as software developed based on AI technologies and capable of performing data search, collection, storage, analysis, processing, evaluation and use, as well as making autonomous decisions based on the data.
Key Principles for the Use of AI and Compliance Requirements Established
The Ethical Rules establish a number of key principles that are mandatory for compliance by the Participants, including:
- lawfulness,
- priority of protecting the interests of the individual, society and the State, as well as the environment,
- transparency and intelligibility,
- accountability, responsibility for outcomes, and oversight,
- fairness and non-discrimination,
- openness and transparency,
- information security,
- reliability and safety.
The Ethical Rules also elaborate on the content of these principles.
In particular, under the principle of intelligibility, decisions or actions carried out by AI technologies and systems should be understandable to AI participants. This includes ensuring that the logic of operation, key algorithmic criteria, decision-making processes and data sources are transparent and explainable.
Users should be informed about the rules governing the use of AI technologies and systems, the purposes for which their use is permitted or prohibited and should also be notified that AI-based decisions or outputs are not always accurate and may be used for advisory or informational purposes.
Under the principle of accountability, responsibility for outcomes and oversight, the Participants are responsible for the consequences of the development, implementation and use of AI technologies and systems, within the scope of their actions. All decisions made using AI technologies and systems should remain under human control, be subject to human review, and the final decision should be made by a human.
Under the principle of reliability and safety, AI technologies and systems should operate consistently and accurately, with the likelihood of minimizing errors. Secure storage of data input into AI technologies and systems should also be ensured.
Particular attention should be paid to the fact that it is not permitted to rely exclusively on the conclusions of information systems and information resources operating on the basis of AI technologies when making legally significant decisions affecting human rights, freedoms and legitimate interests, as well as decisions in the field of healthcare (including disease diagnosis, determination of treatment methods, analysis of medical images, patient data management, etc.).
Rights and Obligations of Developers and Implementers of AI Technologies and Systems Established
Pursuant to the Ethical Rules, the following rights and obligations of developers and implementers of AI technologies and systems are established:
- to develop and implement AI technologies and systems in compliance with the Ethical Rules,
- to protect ownership rights and intellectual property rights in AI technologies and systems,
- to submit proposals for improving the Ethical Rules, etc.
At the same time, developers and implementers of AI technologies and systems are assigned, inter alia, the following obligations:
- to ensure transparency and intelligibility of AI algorithms,
- to prevent potential bias in AI technologies and systems,
- to ensure the protection of personal data and restricted information,
- to provide clear and accessible information on the capabilities, limitations and potential risks of AI technologies and systems,
- to inform users about the rules governing the use of AI technologies and systems, the purposes for which their use is permitted or prohibited, and to notify them that AI-based decisions or outputs are not always accurate and may be used for advisory or informational purposes,
- to ensure human oversight over AI systems, the possibility of human review, and that final decisions are made by a human,
- not to use AI technologies and systems for purposes contrary to the legislation of Uzbekistan or capable of causing harm to individuals, society, the state, or the environment,
- to develop and publish user guidelines for the use of AI technologies and systems, etc.
Rights and Obligations of Users of AI Technologies and Systems Established
Pursuant to the Ethical Rules, users of AI technologies and systems are granted, inter alia, the following rights:
- to receive information on the rules governing the use of AI technologies and systems, the purposes for which their use is permitted or prohibited, and that AI-based decisions or outputs are not always accurate and may be used for advisory or informational purposes,
- to use open, transparent and secure AI technologies and systems,
- to obtain explanations regarding the algorithms of AI systems,
- to act independently when using AI technologies and systems,
- to submit proposals to developers and implementers of the AI systems for correction of identified deficiencies, etc.
At the same time, users of AI technologies and systems are subject, inter alia, to the following obligations:
- to comply with the rules and conditions governing the use of AI technologies and systems,
- to use AI technologies and systems properly,
- to ensure the protection of personal data and restricted information,
- not to infringe the copyrights of other users,
- to comply with the Ethical Rules,
- not to cause harm to the interests of individuals, society and the State, as well as the environment, etc.
Contacts:
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Zafar VakhidovPartner, Vakhidov & PartnersUzbekistan / Kazakhstan |
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Kamila Sharipova Senior Associate, Vakhidov & Partners Uzbekistan |
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Dilshodbek Egamberdiev Associate, Vakhidov & Partners Uzbekistan |