A Law You Cannot Fully Read
Published 2026-08-31 · EuroQuest International
Quick summary
- A much larger law. Law No. ZRU-987 was adopted on 31 October 2024 and expands the previous version from 51 articles to 172, covering both hard minerals and hydrocarbons.
- Local content arrived. The old law had no personnel, training or procurement articles. The new one carries four, at Articles 155 to 158.
- Personnel duties are specific. On a published professional summary, Article 155 requires all non-qualified workers to be Uzbek citizens, and caps foreign nationals at 20 percent per category in leadership and specialist roles.
- Procurement is a preference, not a set-aside. Article 157 requires preference for Uzbek goods and services where they are competitive on price, quality and delivery.
- And the honest caveat. The operative text of those articles is not publicly retrievable, so the numbers above are a law firm's reading rather than words quoted from the statute.
Something unusual happens when you try to research Uzbekistan's local content obligations. The official legislation database lists the law, its chapters and its article titles. Article 155 is named as local content in personnel. Article 156 is named as requirements for science and training. Articles 157 and 158 cover procurement and regional development. All four are visibly there. Open any of them for the text, however, and it does not render for a public reader. The commercial databases that do carry the wording put it behind a subscription.
That is a real situation rather than a research failure, and it is the honest starting point for anyone planning an entry. This guide sets out what can be established about the new Subsoil Law from sources that can be checked, what a published professional summary says about the personnel and procurement articles, what remains genuinely unknown, and how to plan around a duty whose exact shape is not yet quotable.
On this page
- What the new law is, and what it replaced
- The four local content articles
- What Article 155 requires on personnel
- What is still not knowable, and the traps around it
- Planning against a duty you cannot yet quote
- Frequently asked questions
What the New Law Is, and What It Replaced
The Ministry of Mining Industry and Geology recorded that the Law of the Republic of Uzbekistan No. ZRU-987 on Subsoil was adopted on 31 October 2024, and that it comes into force three months from the date of its official publication. The government news portal reports that date as 2 February 2025, attributing it to the legal publisher Norma.
The scale of the rewrite is the clearest single indicator of what happened. Counsel at GRATA International record that the law expands from 51 articles in the previous version to 172, and that it regulates the exploration and mining of both hard minerals and hydrocarbons. A statute does not more than triple in length without acquiring whole subject areas it did not previously address, and local content is one of them.
Why This Matters for a Gas Producer
Uzbekistan is a gas country, and the state's own figures make the point without anyone having to characterize the sector. In the first half of 2026 the National Statistics Committee reported production of 18.3 billion cubic meters of natural gas against 313.8 thousand tons of oil. Anyone approaching the market as an oil play has misread it before opening the law.
That shapes what the workforce obligations actually bite on: processing, pipelines, compression and field operations rather than a large drilling fleet. Reading the regime correctly starts with the same legal and regulatory framework work that any new jurisdiction demands.
The Four Local Content Articles
Uzbekistan's earlier framework was notably thin here. The 2001 Law on Production Sharing Agreements contains no personnel, training or local content article at all across its twenty-nine articles. The new Subsoil Law changes that by introducing a block of four, which the National Database of Legislation lists by title as follows.
| Article | Subject, as titled | Operative text publicly readable |
|---|---|---|
| 155 | Local content in personnel | No. Substance available only through a professional summary. |
| 156 | Requirements for science and training | No. Nothing describes it beyond the title. |
| 157 | Procurement of goods, works and services | No. Substance available only through a professional summary. |
| 158 | Regional development | No. Nothing describes it beyond the title. |
The distinction in that third column is the whole point of this guide. Two of the four can be described from a published source that names the article and states what it requires. The other two can only be confirmed to exist. Treating all four as equally known is how a planning assumption turns into a compliance surprise.
What Article 155 Requires on Personnel
The Legal 500 country comparative guide for Uzbekistan mining, contributed by the Tashkent firm Azizov Partners, states that Article 155 of the Law on Subsoil establishes mandatory local content requirements for personnel: 100 percent of the non-qualified workforce must be citizens of the Republic of Uzbekistan, and foreign citizens in leadership and specialist roles must not exceed 20 percent of the total number for each category.
Two features of that structure are worth noticing. The unqualified workforce is absolute rather than proportional, which removes any question of gradual replacement at that level. And the 20 percent ceiling is applied per category rather than across the workforce, so an operator cannot balance a heavy expatriate presence among specialists against a locally staffed leadership team. Anyone who has worked through the neighboring regime will recognize the per-category logic from our guide to in-country value in personnel in Kazakhstan.
The same guide records that under Article 157 subsoil users and their contractors must give preference to goods, materials and equipment produced in Uzbekistan, and to services provided by local persons and entities, provided they are competitive in price, quality and delivery terms. That proviso matters: it is a preference conditioned on commercial parity, not a mandatory set-aside, and it is closer to a procurement discipline than to a quota.
A trap worth naming
A figure of 80 percent circulates in discussion of Uzbek workforce obligations. It comes from the Law on Production Sharing Agreements, which sets a workforce quota of at least 80 percent Uzbek citizens on an average annual basis. That is a different statute with a different scope, and attaching it to Article 155 of the Subsoil Law would be wrong. Which instrument governs a given project depends on how that project is held.
What Is Still Not Knowable
Everything above rests on a professional summary. It names the article, states what it requires, and is published under identified authors at a reputable firm, which is a great deal better than an unattributed figure. It is still not the statute. Nobody outside a subscription can currently place the operative wording of Article 155 next to that summary and check it.
For Articles 156 and 158 there is not even that. The science and training article and the regional development article are confirmed to exist by title on the official database, and no public source found describes what either requires. The temptation at this point is to reason by analogy from Kazakhstan, whose subsoil code sets a training spend of one percent of extraction costs and a minimum share of in-country value in personnel. That analogy is unsupported. Two neighboring statutes addressing the same subject can differ completely in base, timing and scope, and our guide to the one percent training rule exists precisely because the Kazakh mechanics are specific rather than regional.
The Institutional Picture Is Clearer
Where the law is opaque on substance it is explicit on responsibility. The government portal lists seven bodies charged with implementation: the Cabinet of Ministers, the Ministry of Mining Industry and Geology, the Ministry of Energy, the Ministry of Ecology, Environmental Protection and Climate Change, the inspection for control in the field of mining and geology, the state institution Center for the Use of Mineral Resources, and local executive authorities.
That list is useful in itself. It tells an operator which doors the implementing regulations will come through, and therefore whom to ask what has actually been issued since the law took effect.
Planning Against a Duty You Cannot Yet Quote
The practical answer is not to wait for certainty, because the obligation is already in force. It is to build the workforce and procurement plan against the structure the law uses, which is known, while treating the exact thresholds as provisional until counsel supplies the operative text.
That means categorizing roles now, since a per-category ceiling is worthless without a defensible categorization. It means keeping the evidence trail that every local content regime eventually asks for. And it means budgeting for a training commitment whose size is not yet public, which is uncomfortable but more honest than budgeting zero. Structured training and development planning is the part that can proceed regardless.
Checklist for an entry under the new law
- Obtain the operative text of Articles 155 to 158 through local counsel. Do not plan from summaries alone.
- Ask which implementing regulations the seven named bodies have issued since the law took effect.
- Establish which instrument governs your project, since a production sharing agreement brings a different workforce quota from a different statute.
- Categorize every role now, because the personnel ceiling is applied per category rather than across the payroll.
- Budget a training commitment even though its size is not yet public, and revise it when the text arrives.
- Do not import Kazakh or Azeri thresholds by analogy. Neighboring regimes are not interchangeable.
This is the closing piece of a six-part look at workforce and training obligations across the Caspian, and the three countries make an instructive set. Kazakhstan legislates in detail and publishes the text. Azerbaijan negotiates the duty into each production sharing agreement, as we set out in our guide to training under an Azerbaijan production sharing agreement. Uzbekistan has now legislated, but the text is not yet public. Teams working across the region train together in Istanbul, the most practical hub for Caspian delegates, and in Dubai, Kuala Lumpur, Amman, and Vienna, where the comparison usually proves more useful than any single country's rules.
An obligation you cannot quote is still an obligation. The professional answer is to say exactly how far the evidence goes, and to plan for the rest rather than to invent it.
Frequently Asked Questions
What did Uzbekistan's new Subsoil Law replace?
It replaced the previous version of the Law on Subsoil. Law No. ZRU-987 was adopted on 31 October 2024 and, on the Ministry of Mining Industry and Geology's statement, comes into force three months from official publication; the government news portal reports the date as 2 February 2025. The change of scale is the striking part. Counsel at GRATA International record that the law expands from 51 articles in the previous version to 172, and that it regulates exploration and mining of both hard minerals and hydrocarbons.
Does it impose local content requirements on personnel?
Yes, and this is new relative to the older regime. The Legal 500 country guide for Uzbekistan mining, contributed by the Tashkent firm Azizov Partners, states that Article 155 establishes mandatory local content requirements for personnel: 100 percent of the non-qualified workforce must be citizens of Uzbekistan, and foreign citizens in leadership and specialist roles must not exceed 20 percent of the total number for each category. That is a professional summary rather than the statutory wording, because the operative text of the article is not publicly retrievable.
Why can the article text not simply be read?
The National Database of Legislation publishes the law's structure and article titles, but the body text of the later articles does not render for a public reader. Commercial legal databases that do carry the operative text place it behind a subscription. The result is that Articles 155 to 158 can be confirmed to exist, by title, on the official database, while their exact wording cannot be quoted from a public source. That is a real constraint on planning, and it is more useful to say so than to fill the gap with assumption.
What does the law say about procurement?
The same Legal 500 guide records that under Article 157 subsoil users and their contractors must give preference to goods, materials and equipment produced in Uzbekistan, and to services provided by local persons and entities, provided they are competitive in price, quality and delivery terms. The competitiveness proviso matters: this is a preference rule conditioned on commercial parity, not an absolute set-aside. A separate 80 percent workforce quota that circulates in discussion of Uzbekistan comes from the Law on Production Sharing Agreements, a different statute, and should not be attached to the Subsoil Law.
How should an operator plan around the uncertainty?
Treat the obligations as real and the numbers as provisional. Build the workforce plan against the categories the law uses rather than against a single headline percentage, obtain the operative text through local counsel rather than relying on secondary summaries, ask which implementing regulations have been issued by the seven bodies named as responsible, and keep the evidence trail that any local content duty eventually demands. Operators experienced in Kazakhstan will recognize the pattern, but should resist assuming the Kazakh mechanics carry across.
Plan the Obligation Before the Text Arrives
EuroQuest International delivers energy, oil and gas management programs covering local content regimes across the Caspian, workforce planning, procurement obligations and compliance evidence, in Istanbul, Dubai, Kuala Lumpur, Amman, and Vienna.
Explore Energy, Oil and Gas Management Programs