Electronic Prescription in Uzbekistan: Legal Regulation and Market Transformation

Introduction of the “Electronic Prescription” System in Uzbekistan:

Legal Regulation, Transformation of the Pharmaceutical Market, and Prospects for Development

1. Introduction

The introduction of the “Electronic Prescription” system in Uzbekistan represents a comprehensive change to the model of prescribing, recording, and dispensing medicines. On the surface, the reform may be perceived merely as the replacement of the paper prescription form with its electronic equivalent. However, a deeper analysis shows that the digitalization of prescription circulation affects fundamental characteristics of the pharmaceutical market: it restructures information flows between the physician, the pharmacy, and the regulator, eliminates traditional tools for promoting medicines, and creates a centralized data array that opens up new opportunities for state oversight.

This article proceeds from the thesis that the electronic prescription system is a mechanism of structural transformation of the pharmaceutical market, and not merely a tool for the digitalization of document flow, and that this transformation gives rise to independent issues of regulatory and competition law, to which the current legislation of the Republic of Uzbekistan responds only partially.

The legal basis of this system is formed by a number of normative acts, including: Law of the Republic of Uzbekistan No. 611-II “On Electronic Document Circulation” of 29 April 2004 (hereinafter - the “Law on Electronic Document Circulation”); Law of the Republic of Uzbekistan No. 415-I “On Medicines and Pharmaceutical Activity” of 25 April 1997 (hereinafter - the “Law on Medicines”); Law of the Republic of Uzbekistan No. 547 “On Personal Data” of 2 July 2017 (hereinafter - the “Law on Personal Data”); the Code of the Republic of Uzbekistan “On Administrative Liability” of 1 April 1995 (hereinafter - the “Code on Administrative Liability”); Resolution of the President of the Republic of Uzbekistan No. 308 “On Additional Measures to Improve the Rating of the Republic of Uzbekistan in the United Nations E-Government Survey” of 14 September 2023 (hereinafter - “Resolution No. 308”); Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 570 “On Additional Measures to Further Accelerate the Digitalization of the Healthcare System” of 8 September 2025 (hereinafter - “Resolution No. 570”); Order of the Ministry of Health of the Republic of Uzbekistan No. 3758 “On Approval of the Instruction on the Procedure for Using the Modules ‘Electronic Outpatient Clinic,’ ‘Electronic Hospital,’ ‘Electronic Medical Record,’ and ‘Electronic Prescription,’ Created in the ‘Electronic Healthcare’ Information System of the Ministry of Health of the Republic of Uzbekistan” of 24 December 2025 (hereinafter - “Order No. 3758”); Order of the Minister of Health of the Republic of Uzbekistan No. 3277 “On Approval of the Regulation on the Procedure for Prescribing Medicines in Medical Organizations, Issuing Prescriptions Using International Nonproprietary Names, and on the Receipt, Storage, and Use of Medicines by Patients” of 1 July 2020 (hereinafter - “Order No. 3277”); Order of the Minister of Health of the Republic of Uzbekistan No. 3725 “On Approval of the Procedure for the Phased Implementation of the ‘Electronic Prescription’ System” of 15 December 2025 (hereinafter - “Order No. 3725”).

2. Legal Nature of the Electronic Prescription

The implementation of the electronic prescription presupposes that the prescription is generated exclusively within the healthcare information system, certified by the medical practitioner’s electronic digital signature, and transmitted to the unified digital environment. Under Article 7 of the Law on Electronic Document Circulation, an electronic document signed with an electronic digital signature is deemed equivalent to a paper document signed by hand. In this way, the legislator ensures the legal equivalence of the electronic prescription to the traditional paper form, which is a necessary precondition for transferring prescription circulation into digital form.

It should be noted that Order No. 3725, which was applied within the pilot project in the city of Tashkent and certain regions, will be recognized as no longer in force. At the same time, the legal basis for the system’s operation will not change, since it is established at the level of Resolution No. 570. The Ministry of Health has further clarified that the electronic prescription system continues to operate and is subject to further development, notwithstanding the forthcoming repeal of Order No. 3725. This repeal is aimed at eliminating duplication and inconsistencies between subordinate legislative acts, as well as at consolidating the regulation of the system at the level of the Government. Shifting the system’s regulatory foundation from a departmental order to an act of the Cabinet of Ministers increases the stability and hierarchical status of the regulation, which is significant for the legal certainty of market participants.

3. Integration of Healthcare System Participants

The implementation of the system supposes the integration of medical and pharmacy organizations into a unified information infrastructure. Pursuant to paragraph 2 of Resolution No. 570, the implementation of information systems in healthcare institutions is carried out with integration of the “Electronic Outpatient Clinic,” “Electronic Hospital,” “Electronic Medical Record,” and “Electronic Prescription” modules. The procedure for using these modules is set out in detail in Order No. 3758. A procedure is being introduced for the mandatory, integrated transmission of the necessary information to the “Electronic Prescription” module upon the issuance and sale of prescription medicines.

Pharmacy organizations obtain access to prescription data through the system and dispense the medicine on the basis of electronic data. In this way, a unified digital chain is formed: physician — information system — pharmacy — dispensing of the medicine. The fundamental significance of this architecture lies in the fact that the movement of the prescription becomes observable at every stage, and the information asymmetry between market participants and the regulator is substantially reduced.

4. Impact on Patients and Transparency of Prescribing

The implementation of the electronic prescription system eliminates the need to use a paper prescription form, which could previously be lost, damaged, or drawn up with errors. Information on the prescribing of a medicine is stored in the electronic system and integrated with the patient’s medical record, which ensures the preservation of data and the formation of a history of prescriptions.

An additional element of transparency is the issuance of prescriptions using the international nonproprietary name (INN). This approach is provided for by the Regulation on the Procedure for Prescribing Medicines, approved by Order No. 3277. The use of the INN is aimed at standardizing the prescribing of medicines and reducing the dependence of therapy choice on a particular trade name of the product. From the standpoint of the present study, this provision is of particular significance: the requirement to prescribe by INN weakens the link between the prescription and a specific brand and thereby directly affects the competitive environment, shifting the point at which a specific medicine is selected from the physician to the moment of dispensing and to the patient.

The integration of the electronic prescription with the electronic medical record is of practical significance for: repeat visits by a patient; monitoring of chronic diseases; assessing the compatibility of previously prescribed medicines; and reducing the risk of duplicate therapy or erroneous prescribing of medicines. At the same time, the implementation of the electronic prescription is accompanied by more stringent requirements for patient identification upon receipt of medicines. Since a medicine is dispensed on the basis of data contained in the information system, pharmacy organizations must ensure that the medicine is dispensed correctly in accordance with that data.

5. Protection of Personal Data

The operation of the electronic prescription system involves the processing of a significant volume of patients’ personal and medical data. In this regard, Article 5 of the Law on Personal Data acquires particular significance, as it establishes such basic principles as respect for the constitutional rights and freedoms of the individual and citizen; the lawfulness of the purposes and methods of processing personal data; the accuracy and reliability of personal data; the confidentiality and security of personal data; the equality of the rights of data subjects, owners, and operators; and the security of the individual, society, and the state.

The integration of the electronic prescription with the electronic medical record increases the importance of mechanisms for access differentiation, storage of medical information, and protection of data against unauthorized use. Since access to prescription data is granted to both medical and pharmacy organizations, the key issue becomes the limits of such access: the volume of data disclosed to a pharmacy organization upon dispensing a medicine must be proportionate to the purpose of processing and must not exceed the information necessary for the proper dispensing of the medicine. The absence of detailed regulation of the access-differentiation model at the level of a normative act creates a zone of legal uncertainty.

6. Impact on the Pharmaceutical Market, Competition, and Marketing

For manufacturers, distributors, and other participants in the pharmaceutical market, the implementation of the electronic prescription system means a substantial increase in the transparency of the structure of prescribing and dispensing of medicines. The digitalization of prescription dispensing gives the regulator the ability to analyze data on the prescribing and sale of medicines. In particular, the integration of the “Electronic Prescription,” “Electronic Medical Record,” and other components of the “Electronic Healthcare” system, provided for by Resolution No. 570, forms a unified data array on the movement of prescription medicines.

Centralized data collection enables state authorities to: analyze the structure of medicine consumption by region, disease category, and product category; track the dynamics of prescribing for particular groups of medicines; identify statistically anomalous patterns in the prescribing and dispensing of medicines; and strengthen control over the circulation of prescription medicines, including antibiotics, hormonal products, and other medicines requiring heightened regulatory oversight.

The implementation of electronic prescriptions potentially strengthens monitoring of compliance with legislative requirements on the advertising and promotion of medicines. Since information on prescriptions is recorded in a centralized system, the regulator gains an additional tool for assessing the possible influence of marketing activity on the structure of prescriptions.

It is precisely at this level that the central thesis of the present study manifests itself. The traditional promotion model, based on individual influence over the prescribing physician and on linking the prescription to a specific trade name, loses its effectiveness under conditions in which the prescription is issued by INN (Order No. 3277) and each prescription is recorded in an observable system. Competition shifts toward such factors as price, availability, and the presence of the product in the pharmacy chain at the moment of dispensing. At the same time, a question arises as to the limits of the regulator’s use of the accumulated data: the centralized array of prescription information is not only a tool of oversight but also a potentially sensitive resource from the standpoint of competition law, which requires clear rules governing the access to, aggregation of, and use of such data.

7. Legal Risks and Liability

The transition to electronic prescriptions does not exclude, and in a number of cases increases, liability for violation of the rules on dispensing medicines. The centralized recording of the fact of prescribing and dispensing a medicine substantially increases the likelihood of detecting violations of the prescription-dispensing procedure, since the digital trail of transactions becomes available for subsequent monitoring and analysis by the regulator.

Article 165-1 of the Code on Administrative Liability directly governs liability for violation of the established procedure for the retail sale of prescription medicines. Administrative liability arises for: the sale of prescription medicines without a proper prescription or in violation of the established procedure (including electronic cases); and violation of the rules on the retail sale of medicines outside pharmacies and their branches.

For violation of the procedure for the retail sale of prescription medicines not containing potent substances, a fine of 5 to 10 base calculation values (BCV) is provided; for violation of the retail sale of medicines containing potent substances, the fine is 50 to 100 BCV. For a practical assessment of the scale of these sanctions: as of June 2026, one BCV amounts to 412,000 soums, which is equivalent to approximately USD 35.

8. Limitations and Practical Risks of Implementation

Despite its undeniable advantages, the implementation of the system described is associated with a range of legally significant limitations and practical risks. First, a pronounced technical dependency arises, in which system failures may block the dispensing of medicines, creating preconditions for violation of the licensing requirements for the continuity of pharmaceutical activity.

Second, the concentration of sensitive personal data and information constituting medical confidentiality gives rise to heightened information-security risks; the requirements for their protection go beyond the ordinary corporate standard.

Finally, the systemic changes transform the market model itself: traditional marketing promotion tools are eliminated, in particular direct arrangements with physicians and pharmacy chains, which, together with the transparency of prescribing and record-keeping, inevitably intensifies price competition, reducing margins for players that previously operated under conditions of information asymmetry.

9. Further Development of the Electronic Prescription System

Although the main elements of the system have been put into operation, work on its improvement continues. According to information received from representatives of the Ministry of Health of the Republic of Uzbekistan, state authorities are considering the further expansion of the system’s functional capabilities and its integration with other state information resources.

One of the priority areas is the integration of the electronic prescription system with the information systems of the tax authorities. It is anticipated that such integration will ensure the automated exchange of information on the sale of medicines, increase the transparency of prescription-dispensing transactions, and strengthen state control over the circulation of medicines.

The Ministry of Health plans a further phased expansion of the system: at the next stage, the implementation of electronic prescriptions is expected to be carried out on a pilot basis in selected districts of each region of the Republic of Uzbekistan. This approach will make it possible to test the system’s operation under various conditions, identify possible technical and organizational problems, and ensure the gradual adaptation of medical organizations, pharmacy institutions, and patients to the new digital mechanisms. The further development of the system will be accompanied by the adoption of additional normative and methodological documents aimed at clarifying the procedure for the operation of electronic prescriptions, expanding the list of medicines covered by the system, and improving the mechanisms of inter-agency information interaction.

10. Conclusion

In the long term, the electronic prescription system may become not only a tool for the digitalization of document flow but also a mechanism for transforming the model of regulating the circulation of medicines. The centralized recording of the prescribing and dispensing of medicines creates conditions for the development of risk-based oversight, the strengthening of control over prescription dispensing, and a more detailed analysis of medicine-prescribing practices.