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Uzbekistan has moved from policy commitment to binding obligation on sustainability reporting, with specific deadlines now in force for dozens of state-linked companies under a framework anchored in three separate legal instruments issued between late 2025 and mid-2026.
The broadest mandate flows from Cabinet of Ministers Resolution No. 221, signed on 4 May 2026, which requires 22 state enterprises undergoing transformation — excluding banks and financial-sector organisations — to publish annual sustainability disclosures in line with the IFRS S1 and IFRS S2 standards developed by the International Sustainability Standards Board. Sixteen of those enterprises must produce their first report covering the 2026 financial year; the remaining six are required to report for 2027.
The same resolution extends its reach to companies in which the state holds more than fifty percent of the charter capital, or holds a larger stake than any other single shareholder or participant.
Energy sector on an earlier clock
Eight energy companies and the state asset manager AO UzAssets face an even tighter schedule under Presidential Decree No. UP-22, issued on 16 February 2026. Their action plan requires an ESG report based on ISSB standards for the 2025 financial year to be prepared during 2026. The named energy companies are UzbekNefteGaz, Teplovye Elektricheskiye Stantsii, Natsionalnyye Elektricheskiye Seti Uzbekistana, Yashil Energiya, Khududgaztaminot, UzbekGidroEnergo, UzTransGaz and Regionalnyye Elektricheskiye Seti. Where the decree does not specify a publication date, companies are directed to follow either the standards’ own timing requirements or, where applicable, the deadlines set in Resolution No. 221.
Nearly 450 publicly significant organisations from 2027
A third layer of obligation covers what Uzbek law designates as publicly significant organisations. Presidential Resolution No. PP-282, dated 15 September 2025, requires these entities to adopt ISSB standards from 1 January 2027. As of October 2026, the register of publicly significant organisations contained 449 enterprises, with eligibility criteria set jointly by the Ministry of Economy and Finance and the Central Bank.
A joint order from the Ministry of Economy and Finance and the Central Bank board — No. 3736, dated 27 December 2025 — specifies that ISSB-compliant reports must be published no later than two weeks before the annual general meeting, and in any case no later than 15 June of the year following the reporting period. On that basis, the first reports covering 2027 are due by 15 June 2028.
Where a single company falls under more than one requirement — for instance, a state enterprise in transformation that is also a publicly significant organisation — it must apply whichever deadline falls earliest.
Voluntary track for listed companies
Resolution No. 221 also establishes a voluntary reporting track, open from the 2027 reporting year, for at least 50 companies whose securities trade on the Republican Stock Exchange Toshkent. The criteria for selecting those companies are to be defined before 1 January 2027.
What the standards require
IFRS S1 sets general requirements for disclosing sustainability-related risks and opportunities that could reasonably affect a company’s cash flows, access to financing or cost of capital. IFRS S2 addresses climate-specific risks and opportunities. Both standards organise disclosure requirements around four blocks that mirror the Task Force on Climate-related Financial Disclosures framework: governance, strategy, risk management, and metrics and targets. Disclosures must form part of the general financial report and be published simultaneously with it for the same reporting period. Companies are also directed to use SASB industry standards when identifying material risks and selecting sector-specific indicators.
First-year relief provisions
The ISSB standards include transition provisions for first-time reporters. In the initial year, a company may limit its disclosures to climate-related information only, omit comparative prior-period data, retain an existing greenhouse-gas calculation methodology even if it differs from the GHG Protocol, and decline to disclose Scope 3 emissions. The sustainability report may also be published after the financial statements — either alongside the half-year report or, if no half-year report exists, within nine months of the financial year-end — provided this does not conflict with national requirements.
The transition relief does not, however, defer the underlying data-collection task. Companies subject to the earliest deadlines need to be gathering emissions figures, documenting climate risks and opportunities, and establishing internal controls capable of supporting independent assurance before they can make an unqualified statement of compliance with IFRS S1 and IFRS S2.
Uzbekistan’s move places it among more than 45 jurisdictions that have adopted or are moving toward IFRS Sustainability Disclosure Standards, a group that the IFRS Foundation says collectively accounts for roughly 60 percent of global GDP and a similar share of global greenhouse-gas emissions. The Ministry of Economy and Finance formalised the country’s relationship with the Foundation through an agreement signed in April 2026.