Burdensome requirements for notification and prior approval
The lengthy and discouraging process of registering self-initiated NGOs is only the beginning in terms
of obstacles. After exhaustive time and money consuming administrative procedures and obtaining
the long-awaited certificate of NGO registration, many grassroots civil society organisations are
facing other barriers in the process of carrying out their statutory activities.
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Although the law ‘On
Non-Governmental Non-Profit Organisations’ forbids ‘interference by state bodies and their officials
in the activities of NGOs’ the Ministry of Justice obliges NGOs to inform them in advance about all
planned activities, including conferences, seminars, trainings, meetings, events, roundtables,
symposia and other forms of events due to take place in Uzbekistan or overseas.
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At the same time
these burdensome requirements do not apply to political parties and religious organisations which
also have NGO status.
For instance, if an NGO plans to hold an event on the territory of Uzbekistan without participation of
foreign nationals it should notify the local justice authority at least ten days before the event takes
place. If the planned event in Uzbekistan involves foreign citizens or is to take place on the territory
of a foreign state – notification should be sent at least 20 days before the event. There is a special
notification form consisting of 12 questions to be answered. This form can now be sent online
through the e-ngo.uz portal and the information to be provided in advance includes: the theme of
the event and the number of participants; the date and the venue; the basis for the holding and
sources of funding; attached copies of handouts; print, audio-visual and other materials; as well as
personal data of participating foreign citizens. NGOs must also notify officials about all their foreign
travel related to the activities of their NGOs and about visits of international guests to Uzbekistan.
All above mentioned onerous requirements in practice illustrate direct intervention of the
authorities in the activities of NGOs. The justice authorities also have the power to reject or stop
activities even if the formal requirements are fulfilled and all necessary documents have been
submitted. However, an NGO retains the right to appeal to the court if it is dissatisfied with the
decision of the judicial body to ban the event.
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Yusupov and Isakov, Regulations of NGOs: Control of Partnership?
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Law of the Republic of Uzbekistan, ‘About Non-Governmental Non-Profit Organizations’ dated April 14, 1999, LexUZ,
https://www.lex.uz/acts/10863; Order of the Justice Minister of the Republic of Uzbekistan, ‘On approval of the regulative procedure for
notification of planned activities of non-governmental non-profit organizations’ of June 1, 2018, LexUZ,
https://www.lex.uz/acts/3776151#3776168
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Decree of the Minister of Justice of the Republic of Uzbekistan, ‘On Approval of the regulation and procedures of notification of
planned activities non-government non-profit organisations’, dated June 1, 2018, LexUZ, https://www.lex.uz/acts/3776151#3776168
Spotlight on Uzbekistan
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