Uzbekistan's New International Commercial Court: What Does It Mean for Arbitration in Central Asia?

On 13 July 2026, Uzbekistan adopted a new Constitutional Law establishing the Tashkent International Financial Center as a special jurisdiction with its own legal regime (“Constitutional Law”). The Law creates a special jurisdiction in the Uzbek capital where the common law of England and Wales and principles of equity apply, English is the official language, and the Tashkent International Commercial Court (“TICC”) is established with supervisory and enforcement functions in international arbitration. From the standpoint of arbitration, the TICC matters in two capacities: it is the supervisory court for arbitrations falling within its jurisdiction, and a specialized forum for the recognition and enforcement of arbitral awards, whether made in the Centre or abroad.

This Blog covered the launch of the Astana International Financial Centre's judicial institutions in 2017 and asked "Why arbitrate at the Astana International Financial Centre?" in 2018. Eight years on, the AIFC's International Arbitration Centre is reported to be handling close to 300 arbitrations a year. The question is no longer whether the model works in the region, but what Tashkent's version adds and where the open questions lie.

From Arbitration Law to Jurisdiction

Uzbekistan adopted its first Law on International Commercial Arbitration in February 2021, drafted with Asian Development Bank assistance and recorded by UNCITRAL as legislation based on the Model Law. The Tashkent International Arbitration Centre ("TIAC") was established in 2018 and has been building a regional caseload since. What was missing was the judicial layer: a specialised, English-speaking forum with credible independence to supervise arbitrations and enforce their results. In his December 2022 address to Parliament, President Mirziyoyev announced that practical work on an international commercial court had begun. The author argued in January 2023 that such a court should hear disputes submitted by party agreement, cases governed by foreign law, cross-border insolvency, investment and corporate disputes involving foreign investors, and applications to recognize international arbitral awards. The author suggested that its proceedings should be in English, and its bench should combine national and foreign specialists. Article 29 of the new Constitutional Law reflects each of these elements.

The Court's Design

The TICC comprises two instances, first instance and appeal, and the appellate merits decision is final. The Chief Justice is appointed by the President upon nomination by the TIFC Council. Judges of any nationality may be appointed, including permanent, ad hoc and specialised judges with expertise in international commercial law, finance, capital markets, arbitration, insolvency, restructuring, technology and digital assets. Proceedings are conducted in English, with translations available on a party's request.

Its exclusive subject-matter jurisdiction covers, inter alia, civil and employment disputes between TIFC persons, disputes arising from activities in or regulated by the Centre, insolvency of TIFC participants, and disputes transferred by party agreement. Importantly, it also covers challenges to the acts and omissions of the Centre’s own bodies, including the regulatory, licensing, supervisory, disciplinary and enforcement decisions of its Financial Services Authority. Personal jurisdiction extends to anyone who consents. The opt-in mechanism that transformed the DIFC Courts after Dubai's 2011 jurisdictional reform is present in Tashkent from day one.

Two structural guarantees deserve emphasis. Articles 12 and 14 contain a de-escalation rule. Where conduct by TIFC persons within the Centre would formally attract administrative or criminal liability under national legislation on currency, customs, tax, competition, crypto-assets or trading rules, but is in substance a commercial dispute or market misconduct capable of resolution within the Centre’s framework, the competent TIFC body applies civil, economic and regulatory measures as the first-order response. No TIFC body may then refer the file to national authorities, though genuine crimes remain with law enforcement. In the author’s view, for a region where the criminalisation of commercial disputes remains a genuine investor concern, this may be one of the Law’s most significant provisions. Second, judgments are issued in the name of the Republic of Uzbekistan and are enforceable nationwide through the ordinary enforcement machinery. The Law on Enforcement of Judicial Acts was amended to list TICC decisions and the Registrar's writs among enforceable instruments. A court whose judgments cannot be enforced through the host state’s domestic enforcement machinery is of limited practical value; Uzbekistan has provided such a mechanism in the founding statute.

What Is in It for Arbitration?

Article 29 of the new Constitutional Law makes the TICC a supervisory court for arbitration in three scenarios: where the seat is in the Centre; where the arbitration is administered by TIAC and the parties have agreed to the TICC's supervisory role; and where the parties have otherwise opted in. Its exclusive jurisdiction covers interim and conservatory measures, appointment of and challenges to arbitrators, jurisdictional questions, procedural assistance, setting aside, and recognition and enforcement of awards.

The enforcement provision goes further: the TICC may recognise and enforce arbitral awards regardless of the state or jurisdiction in which they were rendered, subject to Uzbekistan's treaty commitments — echoing Regulation 45(1) of the AIFC Arbitration Regulations. Uzbekistan has been a New York Convention state since 1995, but enforcement has until now run exclusively through the national economic courts, in Uzbek, with the familiar frictions of translation and judicial unfamiliarity with transnational practice. The TICC creates, for the first time, an English-language enforcement forum for foreign awards inside Uzbekistan, staffed by judges selected for arbitration expertise.

For TIAC, the implications are strategic. A TIAC arbitration seated in the Centre, supervised by the TICC and enforceable nationwide through it, becomes an integrated court-and-institution model similar to the architecture that has supported the growth of the AIFC’s International Arbitration Centre. A configuration this author discussed in a 2024 interview on this Blog.

The Open Questions

Candour requires acknowledging what the Law leaves unresolved.

First, the dual enforcement track. An award creditor may now choose between the national economic courts and the TICC. Choice is welcome, but divergent approaches to Article V of the New York Convention between the two tracks would create uncertainty. Early, well-reasoned TICC enforcement jurisprudence — and dialogue with the Supreme Court — will be essential to keep the standards convergent.

Second, the bench. The Law permits judges of any nationality; it does not prescribe the mix. At Paris Arbitration Week, the AIFC Court's leadership defended an exclusively foreign bench as the foundation of investor trust. The author takes a different view, and the Uzbek statute ultimately supports it: a court that combines eminent foreign judges with the strongest national specialists builds trust and transfers capacity, rather than outsourcing credibility indefinitely. Which philosophy Tashkent adopts in its first appointments will say much about the project's ambitions.

Third, the rules. The Centre's bodies have twelve months to adopt the regulations needed for activation — including the TICC's procedural rules, fee schedules and registry practice directions, which the Chief Justice may issue without further approval. Until those texts are published (in English, in the official register — an unpublished regulation has no legal force), counsel cannot yet advise on the mechanics. The drafting of the court rules will be the real test of whether the TICC learns from the DIFC, ADGM and AIFC courts, and from the SICC, which sits inside Singapore’s own judiciary but shares what matters here: an international bench, English-language proceedings, purpose-built rules and arbitration-support docket.

Fourth, the caseload problem. Every new international commercial court begins empty. The opt-in jurisdiction, the FSA-review docket and the arbitration-support functions are deliberate sources of caseload, and a further constitutional law adopted in August 2026 extends the Court’s jurisdiction, from January 2027, to disputes of participants in the Enterprise Uzbekistan digital technology Centre. The TICC is being built as a shared court for Uzbekistan’s special regimes, not a single-center one. Even so, the experience of peer institutions suggests patience: credibility compounds slowly, judgment by judgment.

Conclusion

In 2021, Uzbekistan gave itself a modern arbitration law. In 2026, it has given itself the court to match, a supervisory and enforcement forum for international arbitration, not an English-law enclave but a common law forum inside its own constitutional order. For arbitration users, the practical takeaways are immediate: a new seat option with English-language supervision, a new enforcement route for foreign awards, and a statutory wall between commercial disputes and criminal process. Whether Tashkent becomes a genuine dispute resolution hub or merely a well-drafted statute will be decided in the next twenty-four months — in judicial appointments, court rules and first decisions. Central Asia's arbitration map has been redrawn twice in a decade.

The author has publicly advocated for the establishment of an international commercial court in Uzbekistan and participated in academic discussions accompanying the reform. He is not acting as counsel in any matter before the institutions described.