Enforcement of an Arbitral Award in Uzbekistan: Procedure and Risks

Author: Sergei Chesławowicz Belyavsky, director of the law firm "Economic Disputes," recommended arbitrator of the International Arbitration Court at the BelCCI, chairman of the "Economic Disputes" Arbitration Tribunal, specializing in economic and arbitration procedure, CIS matters, international commercial arbitration, international trade, corporate law, construction, IT disputes, and mediation

13.06.2026

For Belarusian and international companies, enforcing an arbitral award in Uzbekistan almost always means not only a legal but also a logistical task: one must obtain a writ of execution and achieve actual debiting of funds from the debtor's bank accounts. Uzbekistan has been a party to the 1958 New York Convention since 1996, which formally provides a favorable regime for the recognition and enforcement of foreign arbitral awards; in practice, however, the details of national procedural and enforcement law matter a great deal.

What does enforcement of an arbitral award mean under Uzbek law?

For a correct understanding of the procedure, it is important to distinguish several concepts. An international arbitral award is the final act of a permanent or ad hoc commercial arbitration issued in a dispute with a foreign element and subject to enforcement in national courts by virtue of the 1958 New York Convention and national legislation.

An exequatur is the judicial procedure for recognizing and permitting the compulsory enforcement of a foreign arbitral award on the territory of a particular state. In Uzbekistan, it rests simultaneously on the New York Convention and the Law of the Republic of Uzbekistan "On International Commercial Arbitration" of 16.02.2021 No. ZRU-674.

Enforcement proceedings are a separate stage after the exequatur, when, on the basis of the writ of execution issued by the court, the case is transferred to the enforcement authority for actual recovery: seizing funds in accounts, levying execution on property, and other actual enforcement measures. In Uzbekistan, these functions are carried out by the Bureau of Compulsory Enforcement under the Prosecutor General's Office, which has replaced the classical institution of bailiffs.

What is the legal basis for enforcing arbitral awards in Uzbekistan?

The basic international source is the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, which Uzbekistan applies to foreign and "non-domestic" arbitral awards. Article 3 of the Convention obliges national courts to recognize such awards and enforce them "in accordance with the rules of procedure of the territory where the award is relied upon." Article 5 contains an exhaustive list of grounds for refusal, including the absence of proper notice to a party, arbitrators exceeding the scope of the arbitration clause, and conflict with the public policy of the enforcing state.

At the national level, the key role is played by the Law of the Republic of Uzbekistan "On International Commercial Arbitration." Article 51 establishes that foreign and international arbitral awards are recognized as binding and enforced on the territory of Uzbekistan upon application by the interested party, and Article 52 reproduces, almost word for word, the main grounds for refusing recognition and enforcement that correspond to Article V of the New York Convention.

Procedural matters relating to the exequatur procedure and the issuance of a writ of execution are governed by the Economic Procedure Code of the Republic of Uzbekistan, which establishes the jurisdiction of economic courts over cases involving the recognition and enforcement of foreign arbitral awards and the procedure for reviewing such applications. In practice, the economic court at the debtor's location or the location of its property reviews the application, checks the documents, and, absent grounds for refusal, issues a ruling on recognition and enforcement, on the basis of which a writ of execution is issued for further proceedings at the Bureau of Compulsory Enforcement.

How does recognition of an arbitral award turn into a writ of execution?

After filing an application for recognition and enforcement of an arbitral award with an Uzbek economic court, the creditor attaches the original or a duly certified copy of the award and the arbitration agreement, as well as evidence of proper notice to the debtor and translations into the state language. These requirements follow from Article IV of the New York Convention and are reproduced in Uzbekistan's Law on International Commercial Arbitration.

The economic court checks only formal criteria: the existence of a valid arbitration agreement, the arbitration's jurisdiction, respect for the right to a defense, absence of conflict with Uzbekistan's public policy, and absence of parallel awards on the same dispute. If the outcome is positive, the court issues a ruling recognizing and enforcing the arbitral award. On the basis of this ruling, a writ of execution (a writ or other document established by law) is issued, which serves as the "pass" into the sphere of compulsory enforcement.

It is important to understand that at this stage the creditor still does not receive money: the court merely legitimizes the arbitral award on the territory of Uzbekistan. Actual enforcement begins from the moment the writ of execution is submitted to the Bureau of Compulsory Enforcement and enforcement proceedings are opened.

What are the features of the Bureau of Compulsory Enforcement in Uzbekistan?

The Bureau of Compulsory Enforcement under the Prosecutor General's Office of the Republic of Uzbekistan is a specialized state authority responsible for enforcing judicial acts, including judgments of economic courts and rulings recognizing foreign arbitral awards.

The Bureau has broad powers: it initiates a search for the debtor's assets, sends electronic requests and orders imposing seizure on bank accounts to banks, conducts on-site inventories of property, seizes vehicles and other high-value property, and controls deductions from current payments. Unlike the classical model of bailiffs, the Bureau is built as a centralized structure with a developed system of electronic data exchange with banks and registers, which potentially speeds up enforcement.

Enforcement proceedings are opened on the basis of the creditor's application and the original writ of execution. The head of the relevant territorial division of the Bureau issues a decision opening the proceedings, sets a deadline for voluntary compliance, and, once it expires, begins applying coercive measures.

How are a debtor's assets located and seized in practice in Uzbekistan?

After enforcement proceedings are opened in Uzbekistan, the main task is to locate the debtor's assets. As a general rule, the Bureau simultaneously sends requests to all banks in the country, uses access to electronic property registration databases, and may engage local authorities to verify the debtor's property status.

Seizing funds in bank accounts is the most effective tool. The seizure order is sent to the bank, which is required to immediately block the sum within the amount of the debt. Subsequently, the bank, on the Bureau's instructions, debits the funds in favor of the creditor. If the funds are insufficient, the Bureau may seize other property of the debtor, including vehicles, equipment, and inventory.

What objections can a debtor raise at the enforcement proceedings stage?

Substantive objections to the arbitral award itself (for example, an argument about the wrong applicable law or an incorrect assessment of evidence) must be raised at the exequatur stage. Once the economic court has recognized the arbitral award and issued the writ of execution, the Bureau of Compulsory Enforcement does not review the dispute on its merits and does not check the legality of the arbitrators' decision.

At the enforcement proceedings stage, the debtor typically relies on performance of the obligation (full or partial payment), the impossibility of performance for objective reasons, an installment arrangement concluded with the creditor, or asks the court to grant a deferral or installment plan for enforcement. These matters are decided by the economic court of Uzbekistan under the procedure established by the Economic Procedure Code, which permits changes to the terms and manner of enforcement in exceptional cases where immediate enforcement could lead to substantial adverse consequences for the debtor, without infringing the creditor's rights.

How do public policy and enforcement proceedings relate to each other?

The category of public policy traditionally appears at the stage of recognizing and enforcing an arbitral award. The economic court of Uzbekistan is entitled to refuse recognition if the content of the award clearly contravenes the fundamentals of the country's legal order and morality, relying on the provisions of Article 5 of the New York Convention and Article 52 of Uzbekistan's Law on International Commercial Arbitration.

The practice of Uzbek courts shows a tendency toward a narrow interpretation of public policy: it is not a matter of any error in the application of law, but of a gross violation of fundamental principles (for example, a ban on money laundering or terrorism financing). Court decisions on the enforcement of foreign arbitral awards indicate that economic courts are not inclined to substitute themselves for an appellate arbitration instance and do not review the dispute on its merits, limiting themselves to checking formal criteria.

After the ruling on recognition and enforceability enters into force and the writ of execution is issued, public policy is no longer used as an independent ground for intervening in the enforcement proceedings: the Bureau of Compulsory Enforcement enforces the judicial act as binding.

How should one interact with banks when enforcing an arbitral award in Uzbekistan?

Although the Bureau is the main subject of compulsory enforcement, it makes sense for a creditor to build parallel communication with the debtor's banks. Uzbek banks act on the basis of the Bureau's orders, but the creditor having information about specific accounts, currency, and turnover significantly speeds up the response.

A feature of the Uzbek system is the developed electronic interaction between the Bureau and banks, which allows accounts to be seized within a short time through centralized electronic requests. This is an advantage for the creditor, but only provided the Bureau has accurate information about the debtor, its details, and potential assets. Otherwise, the search for property may drag on, and actual enforcement of the arbitral award in Uzbekistan will take months.

A little-known fact about enforcement proceedings in Uzbekistan

A fact little known to Belarusian companies is that the functions of the compulsory enforcement authority in Uzbekistan are concentrated not within the court system but in a separate department under the Prosecutor General's Office — the Bureau of Compulsory Enforcement — and this structure actively uses electronic channels to access state and banking databases. This means that with a correctly executed writ of execution and precise information about assets, a creditor can achieve a freeze on funds significantly faster than in a number of other jurisdictions in the region. At the same time, any technical error in the translation, in the debtor's details, or in the writ of execution itself can block the operation of the entire system until the errors are corrected.

How does "Economic Disputes" LLC organize its work on enforcing awards in Uzbekistan?

Enforcing an arbitral award in Uzbekistan requires a combination of international legal expertise, knowledge of national procedural law, and established working relationships with local lawyers and enforcement authorities. For Belarusian and foreign clients, it is convenient when this is handled by a single team that understands the specifics of both Belarusian and Uzbek law and knows how to "translate" the arguments of the New York Convention into the language of the economic court and the Bureau of Compulsory Enforcement.

"Economic Disputes" LLC combines experience working with international arbitration institutions and practice in recognizing and enforcing foreign judgments and awards, as well as effective interaction with partner law firms in Central Asia, allowing it to support clients at every stage — from choosing an arbitration clause to actually receiving money in Uzbekistan.

The company specializes in complex economic and international disputes, including the recognition and enforcement of foreign judicial and arbitral decisions. The team of lawyers and specialists has 15–25 years of practical experience, is regularly recognized with professional awards, and speaks at industry conferences and forums. The company's director, Sergei Belyavsky, worked in the system of economic courts of the Republic of Belarus for over 20 years, including 10 years as a judge, and currently serves as a recommended arbitrator of the International Arbitration Court at the BelCCI and an arbitrator at other international arbitration institutions, author of five books and more than 1,500 publications on judicial and arbitration practice.

The company has formed a multidisciplinary team of specialists in arbitration, foreign trade contracts, work with foreign banks, and enforcement of judgments abroad.

"Economic Disputes" LLC works freely in Russian, English, and Polish and relies on an extensive partner network spanning more than 160 countries around the world — from Spain to China and Mongolia, from the United States to South Africa. For the convenience of international clients, the company has opened its own bank account with PKO Bank Polski, which significantly simplifies settlements and payment for services from abroad. Over the years, the company's lawyers have helped more than 2,000 clients, securing the return or savings of over 1.9 billion Belarusian rubles, and have received more than 100 positive reviews, which can be viewed on the website.

If you need to prepare and enforce an international arbitral award in Uzbekistan — from choosing an arbitration clause to actual recovery through the Bureau of Compulsory Enforcement — leave a request for a consultation on our website.