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Uzbekistan Tightens Licensing Rules for Crypto Market: New "Reasonable Judgment" Mechanism

2026-03-24 12:05
Designed by Freepik
Since 2026, updated rules for issuing permits to participants in the digital asset market have come into force in Uzbekistan. The National Agency for Prospective Projects (NAPP) can now assess applicants not only by formal criteria but also based on "reasonable judgment," which may serve as grounds for license denial.

What "Reasonable Judgment" Means

This is a tool that allows NAPP to evaluate a company based on:

  • data from supervisory activities;
  • information from individuals and legal entities;
  • reports from international organizations;
  • information from government bodies and foreign regulators;
  • materials from open sources.

The actual substance of the company's activities now outweighs formal indicators. If a negative reasonable judgment is issued, it becomes an official basis for license denial.

Why This Matters

Previously, formal compliance with requirements was sufficient. Now, the regulator will more thoroughly examine the actual operations, the business reputation of beneficiaries, and even information from open sources. Any negative data may influence the decision.

What Other Stricter Requirements Were Introduced

Earlier draft amendments already included:

  • stricter requirements for the reputation of beneficiaries;
  • the obligation to warn clients about the risk of total loss of investments.

These provisions are now in effect and are complemented by the "reasonable judgment" mechanism.

Risks for License Applicants

Denial may result from:

  • negative information about beneficiaries found in open sources;
  • data received from foreign regulators;
  • supervisory data or complaints from counterparties.

How TechCount Can Help

Obtaining a license in the digital asset market requires not only thorough document preparation but also an understanding of the regulator's approach. TechCount Uzbekistan experts are ready to:

  • conduct a preliminary assessment of your company and beneficiaries for compliance with the new requirements;
  • prepare a complete set of documents considering the "reasonable judgment" criteria;
  • advise on reputational risks and business transparency;
  • offer legal support for obtaining the license and during subsequent operations.

Contact us — we will help you navigate the licensing process without risks and in full compliance with the new rules.