Violations in Public Procurement in Uzbekistan

Publication date: 28.06.2025

Public procurement in the Republic of Uzbekistan is regulated by the Law “On Public Procurement” (ZRU-684 of 22.04.2021). This law defines the legal framework for procurement activities, establishes principles of transparency, competition, and inadmissibility of corruption, as well as provides for control mechanisms. However, practical application shows that various violations arise in the procurement process, undermining the efficiency of budget spending and public trust in the system.

Violations in the field of procurement represent actions or omissions by procurement system actors that contradict established legal norms and principles. They may occur:

At the planning stage (e.g., artificial splitting of procurements);
During procedures (collusion of participants, excessive requirements, corruption);
At the contract execution stage (evasion of obligations, supply of low-quality goods).

An important feature is that such violations often have a complex nature, combining corruption with managerial incompetence.

Main Types of Violations

Category	Content	Consequences
Corruption-related	Personal gain by officials, collusion of participants, falsification of documents	Loss of competition, inflated prices
Procedural	Violation of deadlines, illegal restriction of competition, inclusion of discriminatory conditions	Exclusion of bona fide participants
Financial	Procurement without confirmed financing, exceeding limits, artificial splitting	Violation of budget discipline
Qualification-related	Admission of unreliable contractors, participation of affiliated entities	Non-fulfillment of obligations
Informational	Concealment or distortion of data, restriction of access to information	Violation of the transparency principle

Classification by Procurement Stages

Planning — lack of justification for needs, splitting of volumes.
Announcement and admission — excessive requirements, limiting the number of participants.
Tender procedure — prior collusion, submission of low bids followed by refusal.
Contract conclusion — imposition of additional conditions, violation of proportionality.
Contract execution — delivery of substandard goods, evasion of obligations, falsified reporting.

Mechanisms for Preventing Violations

The law provides for a set of measures to reduce violations:

creation of a Unified Register of Contracts and a Register of Unreliable Suppliers;
mandatory disclosure of information on a special portal;
disqualification of participants in case of violations;
ethical rules of conduct for officials;
control and monitoring by authorized bodies.

Liability and Sanctions

Contractors included in the register of unreliable suppliers lose the right to participate in procurement for 2 years.
Officials may face disciplinary, administrative, or criminal liability depending on the nature of the violation.
A public customer may bear property liability for damages caused by unlawful actions.

The public procurement system of Uzbekistan is based on international standards of transparency and competition. However, violations in its implementation indicate the need for continuous monitoring, strengthening of anti-corruption measures, and professionalization of staff. Comprehensive application of the control and transparency mechanisms provided by law is the key condition for effective and fair spending of public funds.

Violations in Public Procurement, Legal Norms, and Sanctions

Type of violation	Content	Law article	Possible sanctions
Corruption and collusion	Giving/receiving remuneration by officials; prior collusion of participants; falsification of documents	Art. 13, 42, 46, 48	Exclusion from procurement; inclusion in the Register of Unreliable Suppliers (2 years); criminal liability (bribery, fraud)
Conflict of interest	Participation of affiliated persons, involvement of close relatives in the commission and among participants	Art. 14, 42, 46	Removal from procedure; disciplinary measures against commission members; exclusion from procurement
Restriction of competition	Inflated qualification requirements, unlawful conditions in documentation, discrimination of participants	Art. 7, 10, 34, 46	Recognition of procurement as invalid; liability of the customer; administrative sanctions
Financial violations	Procurement without confirmed financing; splitting procurement into parts; exceeding limits	Art. 29, 46	Termination of procurement; disciplinary or material liability of officials
Informational violations	Concealment of information; distortion of data; restriction of access to the portal	Art. 9, 27, 31, 46	Cancellation of procurement; internal investigation; disciplinary and administrative liability
Tender-related violations	Submission of low bids followed by refusal; artificial limitation of the number of participants	Art. 42, 46	Exclusion from procurement; inclusion in the Register of Unreliable Suppliers
Violations during contract conclusion	Signing contracts with an ineligible participant; changing terms without grounds	Art. 34, 47	Invalidity of the contract; fines; refusal of payment (via Treasury)
Violations during contract execution	Supply of low-quality goods, refusal of obligations	Art. 24, 48	Inclusion in the Register of Unreliable Suppliers; retention of guarantee sums; imposition of penalties and fines
Ethical violations	Acceptance of gifts or material benefits by commission members or the customer	Art. 45	Disciplinary and criminal liability; exclusion of the violator from procurement