GILS Mining: Uzbekistan

Mining

Uzbekistan

1. What is the nature and importance of the mining industry in your country? What are the target minerals? Which regions are most active?

Uzbekistan’s mining industry is one of the country’s most important and strategic industries. Uzbekistan is one of the world’s largest producers of gold (ranked 10th) and uranium (ranked 5th). Uzbekistan also produces copper, silver, coal, phosphate, molybdenum, potassium, tungsten, lead, zinc and other minerals.

According to the Annual Report (2023) by the Ministry of Mining Industry and Geology of the Republic of Uzbekistan, the most important, active and strategic mining regions are:

• “Navoi MMC” JSC – product volume for 2023 alone amounted to 67 trillion sums ($5.5 billion), with a growth rate of 103.8%. The company produced 91.3 tons of gold and 20.4 tons of silver.
• “Almalyk MMC” JSC produced industrial products worth 31 trillion sums ($2.5 billion). They produced 148.5 thousand tons of copper, 17.4 tons of byproduct gold, 161 thousand tons of silver, and 785 tons of molybdenum. “Navoiuranium” SE produced industrial products worth 6.7 trillion sums ($600 million). The production of uranium concentrate increased by 11% compared to the output in 2022.
• “Uzbeksteel” JSC produced a total of 9.2 trillion sums (1 028.5 million tons) worth of industrial products. Among these products, 780.1 thousand tons of long steel products were produced, including 248 thousand tons of steel balls were manufactured.

2. What are the principal laws that regulate the mining industry? What are the principal regulatory bodies that administer those laws? Were there any major amendments in the past year?

The mining industry in Uzbekistan is primarily governed by the Law on Subsoil and other relevant legal acts such as the Law on Licensing and Permits and the Tax Code.

As per Article 10 of the Law on Subsoil, the bodies implementing the state policy in the field of subsoil use and protection are:

• Cabinet of Ministers of the Republic of Uzbekistan;
• Ministry of Mining Industry and Geology of the Republic of Uzbekistan;
• Ministry of Energy of the Republic of Uzbekistan;
• Ministry of Ecology, Environmental Protection and Climate Change of the Republic of Uzbekistan;
• Inspectorate for Control in the Sphere of Mining and Geology under the Ministry of Mining Industry and Geology of the Republic of Uzbekistan;
• State Institution “Subsoil Use Center” under the Ministry of Mining Industry and Geology of the Republic of Uzbekistan.

A major amendment was made with the adoption of the new Law on Subsoil on October 31, 2024, which came into force on February 2, 2025.

3. What classification system does the mining industry use for reporting mineral resources and mineral reserves? (How does this system compare to generally recognized international systems such as the CIM Standards (Canada), the JORC Code (Australia) and the SAMREC Code (South Africa)?

Until recently, the old classification system was used when reporting mineral resources and mineral services, however, Uzbekistan has started to gradually transition to JORC system from 2019 and all ore deposits were recalculated in accordance with the internationally accepted standards of the Code for Reporting of Exploration Results, Mineral Resources and Ore Reserves (JORC Code). 

It is worth noting that the state institutions were the first to start using the JORC system in 2019. Later, the Decree of the President of the Republic of Uzbekistan stipulated that starting from 2020, the introduction of international standards for the preparation of reports on the results of geological exploration and approval of mineral reserves in accordance with the JORC Code, as well as training and certification of qualified specialists of the Ministry of Mining and Geology of the Republic of Uzbekistan will be carried out with the involvement of leading foreign consulting companies and experts.

As an example, since the beginning of 2019, Almalyk MMC JSC has been cooperating with SRK Consulting (UK), one of the world's most reputable companies in this area, with which it is implementing three projects - Almalyk, Angren and Khandiza. The project “Almalyk” envisaged the work on revaluation of reserves of “Oliy Ziyo” deposit.

During this time a lot of work has been done to convert the reserves in accordance with the international classification of the JORC Code and their growth in these fields. More than two years of analysis was carried out, starting from historical geological data up to the present day. This is about a hundred years: from the 30s of the last century to the present. 2008 so-called historical wells were analyzed, which is more than 667 thousand linear meters. Since 2019, more than 470 new boreholes, or more than 206 thousand linear meters, have been drilled here, about 114 thousand samples have been taken, and analyses have been carried out in independent international laboratories that meet modern world standards. The results of the drilling program were successful.

4. To what extent does the state control mining rights in your jurisdiction? Can those rights be granted to private parties and to what extent will they have title to minerals in the ground? Are there large areas where the mining rights are held privately or which belong to the owner of the surface rights? Is there a separate legal regime or process for third parties to obtain mining rights in those areas?

According to the Article 9 of the Law on Subsoil, the state shall perform the following functions in the field of subsoil use and protection:

• assistance and regulation of investments in the mining industry, organization of geological exploration of subsoil, regulation of mineral extraction, development of other subsoil objects, regulation of subsoil use;
• ensuring legality, openness and transparency, impartiality and environmental safety in the development and disposal of mineral resources, monitoring of subsoil use and regular publication of data, as well as implementation of social protection within the framework of investment projects;
• ensuring compliance with the terms of subsoil use within the framework of issued permits, implementation of state control in the field of subsoil use and protection, as well as taking measures to prevent actions that contradict the law.

In this regard, as per Article 6 of the Law on Subsoil, subsoil and all minerals naturally occurring in the subsoil are the state property of the Republic of Uzbekistan, are subject to rational use and are protected by the state. This right of ownership applies regardless of any right or property of any person to land and water. Subsoil plots cannot be the subject of purchase and sale, donation, inheritance, contribution, pledge and cannot be alienated in any other form. The state has the right to issue permits for the use of subsoil plots, including for reconnaissance work on minerals, geological study and extraction.

Moreover, in accordance with Article 7 of the Law on Subsoil, the right of ownership of a permit for the right to use subsoil may be alienated, including by sale, pledge or other security. The right of ownership of minerals extracted in the manner prescribed by law belongs to individuals and legal entities that have the right to use a subsoil plot. The right of ownership of illegally extracted minerals belongs to the Republic of Uzbekistan.

5. What information and data are publicly available to private parties that wish to engage in exploration and other mining activities?

Firstly, the Subsoil Use Center ensures public access to key information under Article 26 of the Law on Subsoil. This includes data regarding the issuance of subsoil use permits, as well as information on the transfer, reissuance, suspension, termination, and annulment of such permits. Moreover, information is disclosed on measures taken to eliminate the consequences of subsoil use, including the form and amount of security provided, its validity period, and the issuing organization. Data on annual expenditures incurred by subsoil users, the local content share in goods, works, and services procured, as well as funds allocated for training of local personnel, scientific research, and socio-economic support for the local population, is also publicly accessible. Furthermore, the State Subsoil Fund, maintained by the Subsoil Use Center, serves as a centralized repository of geological data. It includes both used and unused subsoil plots and technogenic mineral formations, with records maintained in the form of the state cadaster of subsoil, state monitoring, and statistical reporting, according to Article 20 of the Law on Subsoil. This fund is integral to the unified information system covering subsoil use and protection across the country.

The Subsoil Cadaster Database consolidates all geological, geophysical, geochemical, hydrogeological, and other relevant data concerning potential, active, and suspended mineral extraction areas. It also integrates information on state monitoring, resource balance sheets, mapping materials, and economic indicators related to subsoil use rights. Historical data is also preserved to ensure continuity and accessibility. In addition, the Registry of Primary Geological Information, managed by the Ministry of Mining Industry and Geology, is another key source. It functions as a searchable system that stores primary geological data obtained during subsoil studies. This registry includes geological data on both natural and artificial media and is populated with information submitted by the holders of geological data, according to Article 22 of the Law on Subsoil.

By means of Article 23 of the Law on Subsoil, while geological information derived from government-funded studies belongs to the state, and that received from subsoil users remains their property, the law stipulates that such private data, once submitted in reports to the Subsoil Use Center, enters into perpetual possession and use by the state.

However, according to Article 26 of the Law on Subsoil, geological data generated from state programs or upon expiration of permits becomes publicly accessible, subject to confidentiality safeguards where applicable.

Additionally, as per Article 26 of the Law on Subsoil, detailed geological data from the State Subsoil Fund may be used for auctions, tenders, or granting of rights based on presidential or governmental acts. These data can be sold at a state-determined price, provided that they are derived from state-funded surveys, are not subject to confidentiality obligations, and are released under a confidentiality agreement.

Apart from that according to the paragraph 9 of the Resolution of the Cabinet of Ministers of the Republic of Uzbekistan “On measures to further improve the procedure for issuing permits for the right to use subsoil areas” No.133 dated March 25, 2022, model conditions for the use of subsoil plots are also posted on the official website of the Subsoil Use Center.

6. What mining rights may private parties acquire? How are these acquired (eg, first come, first considered; first come, first served; discretionary or competitive bidding)? What obligations does the rights holder have? If exploration or reconnaissance licenses are granted, does such tenure give the holder an automatic or preferential right to acquire a mining license or more senior tenure? What are the requirements to convert to a mining license?

As per Chapter 2 of the Resolution No. 133 permits to use subsoil are given for the following purposes:

• geological study;
• mining of minerals;
• use of man-made mineral derivatives;
• use of subsoil areas for the construction and operation of underground structures for purposes not related to the extraction of minerals;
• establishment of protected geological objects;
• collecting samples of rare rock raw materials, paleontological remains and other geological collectibles.

Mining rights granted on a basis of subsoil use permit. As a rule, a permit is issued separately for each type of subsoil use specified above. Although the regulator uses the definition of permit it has the same meaning and purpose as a license (hereinafter a permit or license). 

In this regard, according to paragraph 7 of Chapter 2 of the Resolution No. 133, permits are issued based on the results of auctions, tenders or consideration of the applicant’s application on a “first come, first served” basis (direct negotiations of legal entities). By means of paragraph 28 of the Chapter 3 to the Resolution No. 133, a list of conditions that must be met to obtain a permit is posted on the official website of the Subsoil Use Centre. However, depending on the type of the subsoil use, the license may include other obligations.

The required documents and procedure for issuance of the permit vary according to the means of application and the purposes of the obtained soil.

7. What is the regime for the renewal and transfer of mineral licenses? (Describe the renewal and transfer rights with respect to exploration, reconnaissance, exploitation and mining licenses and the level of government discretion. Is government consent required to transfer a license or with respect to change of control of the license holder or its parent? What notices, filings or approvals are required in relation to the transfer of mineral rights or mining businesses?)

According to Article 110 of the Law on Subsoil, a subsoil user may apply for the renewal of a license during the final year of its validity by submitting a formal application to the Subsoil Use Center. The applicant must prove their legal capacity and present the required documentation, including a completed application form as prescribed by the Center. For exploration licenses, the renewal application must also include a 50% reduction in the number of cadastral blocks specified in the original license, supported by a detailed map showing the areas retained and relinquished.

For exploitation licenses, whether for the extraction of solid minerals or hydrocarbons, the renewal application must include evidence supporting the ongoing relevance of the project’s core parameters, confirmation of work completed or planned under the approved work program, and evidence of past operations. Specifically, mining operations must have been conducted for at least 2 out of the last 10 years, and hydrocarbon extraction activities must have been carried out for at least 8 out of the last 10 years. In addition, an updated development project (if necessary), a preliminary decommissioning or closure plan, and a projected minimum expenditure budget must be submitted.

The Subsoil Use Center must notify the applicant of the approval or refusal of renewal within 15 business days. If the license expires during this period, its validity is automatically extended until the review is completed. Renewals are formalized through the issuance of a new license in accordance with the general procedure for granting licenses.

Renewal may be denied if:

• the requested renewal term violates specific legal provisions;
• the application was not submitted within the required timeframe;
• legal or technical requirements for renewal were not fulfilled; or
• there are significant unresolved breaches of license conditions. In case of refusal, the license remains valid until its original expiration date.

Transfer of mineral licenses is stipulated by Article 111 of the Law on Subsoil Use. A license holder may assign its rights under an exploration or exploitation license – including using them as collateral – provided the transferee undertakes to comply with all license conditions. However, licenses awarded through an auction cannot be transferred within two years of issuance.

Prior to a proposed assignment of rights, a change in control of the license holder or its beneficial owner, or the use of license rights as collateral or other security, the licensee must submit detailed information about the counterparty (e.g., the transferee, new controlling entity, or pledgee) to the Subsoil Use Center at least 30 days in advance. The submission must meet the requirements applicable to an original license application. The Center has 20 business days to approve or deny the proposed transfer. Approval is contingent upon verification that the incoming party is not prohibited by law from holding such licenses and possesses the necessary financial and technical capacity. Upon approval, the license is re-issued in accordance with the procedures applicable to original license grants.

Where rights are pledged to a financial institution lacking the technical capacity to fulfill license obligations, the Center must ensure the creditor is a stable financial institution. In such cases, the creditor may only assume the licensee’s rights if it has the requisite financial and technical qualifications. If the creditor designates a nominee to exercise enforcement rights, that nominee must also be approved under the same rules. The re-issued license must indicate the name of the approved pledgee or other secured party. Following approval, the new licensee inherits all rights and obligations under the license, including, for exploration licenses, the exclusive right to obtain an exploitation license. The previous license holder’s rights and obligations are thereby extinguished.

8. What is the typical duration of mining rights? Is there a requirement to relinquish a portion of the mining rights to the government after a certain number of years? (Can mining rights be extended or renewed, and under which conditions? Can mining rights be revoked or cancelled anticipatively by the government, and on which grounds?)

In accordance with Chapter 4 of the Resolution No. 133, the right to use subsoil resources is:

(a) for geological research – for up to five years;

(b) for the extraction of minerals and the use of man-made mineral deposits:

• when a permit is initially issued – for a period of ten years, with a guarantee of its extension later, taking into account the period of exploitation of the mineral deposit or technogenic mineral formations, upon submission of feasibility studies within the established deadlines;
• after the submission of the feasibility study – for the period specified in the feasibility study for the exploitation of the mineral deposit or technogenic mineral formations;

(c) to collect samples of rare stone raw materials, paleontological remains and other geological collection materials – for a period of up to two years;

(d) use of subsoil areas for the construction and operation of underground structures for purposes not related to the extraction of minerals, including for the underground storage of oil, gas, gas condensate, other substances and materials, and for the storage and disposal of waste – for an indefinite period of time;

(e) for the establishment of protected geological objects – for indefinite use.

The period of subsoil use is specified in the permit and is counted from the date of issuance of the permit for the right to use subsoil plots. The term of subsoil use may be extended until the end of the term of subsoil use upon the application of the subsoil user to the Subsoil Use Centre, provided that the subsoil user fulfills the conditions established in the permit and completes geological exploration of the subsoil, as well as when it is necessary to commission mineral deposits, exploit technogenic mineral formations, or carry out liquidation or conservation work on mineral extraction enterprises.

9. Is there any distinction in law or practice between the mining rights that may be acquired by domestic parties and those that may be acquired by foreign parties (eg, is the ownership of mining rights by foreign parties restricted or prohibited in any fashion? is it necessary or desirable for a foreign party to have a domestic partner)?

Generally, there is no distinction, and foreign individuals and legal entities can directly hold mining rights in Uzbekistan. Uzbekistan has managed to build a powerful mining industry over the past 40 years, thanks to rich uranium and gold deposits. Most of the subsoil deposits are being developed by two major state-owned mining companies or by joint ventures with these companies (Navoi Mining Metallurgical Combine JSC (NMMC) and Almalyk Mining Metallurgical Combine JSC (AMMC)). Thus, in practice, priority in providing mining rights with respect to large deposits of strategic minerals, such as gold, silver, copper and uranium are given to these companies. At the same time, the government continues to seek and attract foreign investors employing innovative technologies and best practices, and there are multiple examples of successful cooperation with large Western and Asian companies, including B2Gold, Orano Mining, JOGMEC, MTA and Calik Holding, etc.

10. What are the principal business structures used by private parties carrying on mining activities (eg, branches, corporations, partnerships, joint ventures and trusts)?

The Law on Subsoil contains no restrictions with respect to the business structures that may be used for the purpose of conducting mining activities in Uzbekistan and it allows any form of legal entity (whether local or foreign) to acquire mining rights in Uzbekistan. The two most commonly used business forms in Uzbek mining activity are the limited liability company (LLC) and joint-stock company (JSC). Additionally, the Law on Subsoil allows for a LLC and a JSC to each be used for either joint ventures or 100 per cent foreign-owned subsidiaries.

11. What duties, royalties and taxes are payable by private parties carrying on mining activities? Are these revenue-based or profit-based?

The Tax Code specifies several special taxes payable by subsoil users, including mining companies, in addition to general taxes such as corporate income tax – 15%, VAT – 12%, social tax – 12%, excise and customs duty, tax on petrol and other mandatory duties, as follows:

• Subsoil-use tax (gold – 7%; silver – 7%; copper – 7%; zinc – 7%; uranium – 8%, and coal – 4%) is calculated on the value of the mineral resources produced and is payable on a quarterly basis for small entities and on a monthly basis for other types of entities. The value of the mineral resources for purposes of subsoil-use tax is generally determined using the average weighted sales price for the reporting period, as per Article 405 of the Tax Code.

The main fiscal obligation applicable to subsoil users is the Subsoil Use Tax, which is imposed on the volume of extracted minerals and is calculated as a percentage of the value of the extracted resource, according to Article 448 of the Tax Code. The rates vary depending on the type of mineral. Notably, the Subsoil Use Tax is revenue-based, as it is levied on the gross value of the extracted minerals rather than on net profit. 

Moreover, according to Article 451 of the Tax Code, subsoil users are required to maintain separate accounting for each licensed site, which ensures transparency in calculating the taxable base. Profit-based taxation, such as corporate income tax, applies on the net profit of the company after allowable deductions; however, the dominant fiscal burden specific to the mining sector remains revenue-oriented. Lastly, if a production sharing agreement (PSA) regime applies, the taxation structure may be contractually defined and differ from the general rules outlined in the Tax Code.

12. What is the environmental review and permitting process for a mining project? How long does it normally take to obtain the necessary permits?

There are several types of environmental licenses and permits subsoil users must obtain before carrying out their activities. The Law on Environmental Expertise, which will come into force on August 25, 2025, requires subsoil users, prior to financing works on construction of mining projects, to obtain a conclusion on environmental assessment from the specialized department of the State Committee of the Republic of Uzbekistan on Ecology and Environmental Protection as to compliance of the intended activity with ecological requirements and that measures undertaken by the subsoil user on environmental safety ensure the sufficiency and feasibility of efficient use of mineral resources. 

According to Article 15 of the Law on Environmental Expertise, the term of the state environmental expertise should not exceed twenty-five working days. Depending on the complexity of the object of the state environmental expertise, the term of its conduct may be extended by a specially authorized state body for a period not exceeding three months. Also, the term of the state ecological expertise shall be calculated from the working day after full payment of the cost of the state ecological expertise.

When conducting a state environmental expertise, the following activities are carried out:

• verification of compliance of the submitted materials with the requirements of legislation in the field of environmental protection and rational use of natural resources;
• analyzing the reliability and completeness of information on the environmental and social consequences of planned and (or) planned or ongoing economic and other activities;
• verification of the validity of the assessment of the impact of biological, chemical substances and technologies on the natural environment;
• verification of the correctness of assessment of the level of environmental hazard associated with the consequences of realization of the planned and (or) planned or implemented economic and other activities;
• identification of sufficiency and validity of measures to ensure environmental safety requirements;
• checking the validity of draft environmental standards.

Under Article 13 of the Law on Environmental Expertise, to conduct the state environmental expertise, the customer (initiator) shall submit:

• for projected facilities – materials of environmental impact assessment, containing draft environmental impact statement, environmental impact statement, and in cases stipulated by the legislation – environmental impact statement;
• for operating facilities – draft environmental standards, environmental impact statement, prepared when establishing the case of impact of the facility on the environment and human health. In this case, the customer (initiator) has the right to additionally submit environmental audit materials;

The draft environmental impact statement shall be submitted prior to the beginning of financing of the object of the state environmental expertise and prior to the approval of the feasibility study of the object of the state environmental expertise.

13. What is the closure and remediation process for a mining project? What performance bonds, guarantees and other financial assurances are required?

Under Chapter 9 of the Resolution No. 133, the right to use subsoil plots may be restricted, suspended, or terminated early by a court upon the application of the competent authority, which is the Subsoil Use Center or the Ministry of Ecology for waste-related use. These actions are based on the findings of state control bodies overseeing geological study, use, and protection of subsoil. Use for purposes unrelated to mineral extraction, such as construction of underground facilities, is excluded.

For information, restriction of use may be imposed for up to three months if safety risks arise or if subsoil use regulations and conditions are violated. Suspension of rights may be imposed for up to six months, during which all types of operations must cease, except for measures aimed at maintaining safety and preventing harm.

Early termination of subsoil use rights is allowed in cases of serious violations, such as failure to commence operations within a year, breach of essential terms (e.g., failure to register the plot, comply with environmental standards, meet planned extraction volumes, or fulfill social and investment obligations), threats to public health or the environment, repeated failure to pay required fees, or persistent violations. If the right is terminated, the user is obliged to restore the land and natural sites for future use, and to start conservation or liquidation of the mine and related infrastructure.

In the event of a legal entity’s dissolution, a special commission (or the management committee under the Law on Production Sharing Agreements) must determine the procedure for finalizing operations. The subsoil plot is transferred to the balance sheet of the permitting authority. When a right is restricted or suspended, the Subsoil Use Center must notify local authorities, the Ministry of Ecology, the Tax Committee, the Inspectorate for Mining and Industrial Safety, and the relevant legal entity within three working days.

14. What were the biggest mining news events over the past year in your jurisdiction and what were the implications? What are the current trends and developments in your jurisdiction's mining industry (legislation, major cases, significant transactions)?

Uzbekistan plans to implement 76 projects for the extraction and processing of rare metals worth $2.6 billion in the next three years. It is also planned to create technology parks in the Tashkent and Samarkand regions, rich in molybdenum and tungsten. (https://president.uz/ru/lists/view/7930)

Japan’s ITOCHU has acquired a minority stake in Nurlikum Mining, a joint venture between state-owned Navoiyuran and France's Orano to mine uranium at the South Dzhengeldi deposit in Uzbekistan. The deposit is expected to continue producing uranium for more than a decade, with peak annual output of up to 700 tonnes. Exploration work is also planned to double the company’s resource base. (https://www.gazeta.uz/ru/2025/03/13/itochu/)

Additionally, the new Law on Environmental Expertise is expected to come into force on August 25, 2025 (https://lex.uz/docs/7397289), as was mentioned previously. The new law expands and clarifies the provisions of the previous one, introducing additional mechanisms for environmental impact assessment and strategic environmental assessment. It includes not only environmental expertise, but also environmental impact assessment (EIA) and strategic environmental assessment (SEA), which is in line with international standards and practice. It expands public participation mechanisms, including mandatory public hearings, publication of information on the results of hearings, and consideration of citizens’ opinions when making decisions.

Over the past several years, the government has been actively attracting foreign investment in the mining industry, and it is expected that the market presence of foreign mining companies in Uzbekistan will significantly grow in the coming years.

Applicable law

• Tax Code of the Republic of Uzbekistan dated December 30, 2019 (Tax Code);
• Law of the Republic of Uzbekistan “On Subsoil” No. 3РУ-987 dated October 31, 2024 (Law on Subsoil);
• Law of the Republic of Uzbekistan “On Environmental Expertise, Environmental Impact Assessment and Strategic Environmental Assessment” No. 3РУ-1036 dated February 24, 2025 (Law on Environmental Expertise);
• Law of the Republic of Uzbekistan “On licensing, authorization and notification procedures” No. 3РУ-701 dated July 14, 2021 (Law on Licensing and Permits);
• Resolution of the Cabinet of Ministers of the Republic of Uzbekistan “On measures to further improve the procedure for issuing permits for the right to use subsoil areas” No.133 dated March 25, 2022 (Resolution No. 133).

Authors: 

Javokhir Urinov, Associate

Yuliya Pak, Associate