Financial statement audit in Uzbekistan: what is tested and how it ends

What is audited: the financial statements

The composition of the annual financial statements is set by the Regulation on the deadlines for submitting financial statements, their structure and content (reg. No. 3567 of 04.11.2024); budget organisations, insurers, commercial banks and non-bank credit organisations are excluded from its scope. The auditor expresses an opinion on the statements as a whole, but tests each statement, the notes and the links between them.

• Under NAS (national accounting standards) — balance sheet, statement of financial results, statement of equity, cash flow statement, notes, calculations and explanations (para. 9).
• Small enterprises and micro-firms — balance sheet and statement of financial results (para. 10).
• Under IFRS — statement of financial position, statement of profit or loss and other comprehensive income, statement of changes in equity, statement of cash flows (indirect method) and notes including material accounting policies (para. 11).
• Companies preparing IFRS statements do not submit NAS statements (para. 12).
• From 1 January 2027, NFRS No. 1 “Presentation and Disclosure in Financial Statements” takes effect for legal entities other than public interest entities and budget organisations; it replaces NAS No. 1.

Standards: what “reliable financial statements” means

The law defines auditing standards as the International Standards on Auditing (ISA) issued by the International Auditing and Assurance Standards Board of the International Federation of Accountants (Article 9 of ZRU-677). Under ISA 200, the auditor’s objective is to obtain reasonable assurance that the financial statements as a whole are free from material misstatement, whether due to fraud or error. Reasonable assurance is a high, but not absolute, level of assurance.

Two practical points follow. An audit is based on sampling: the auditor determines materiality and risk areas and tests what could distort the statements rather than every journal entry. And reliability in the law means a level of accuracy that allows objective conclusions about the financial position and results to be drawn from the statements (Article 32), not the absence of any error at all.

Who must have the financial statements audited

Article 35 of ZRU-677 requires an annual audit from joint-stock companies, banks and other credit organisations, insurers, agricultural cooperatives, funds, exchanges and companies with a state share. A commercial organisation outside these categories must be audited when, based on the year’s results, any two of three criteria are met: book value of assets above 100,000 BCV (UZS 44 billion at a BCV of UZS 440,000), revenue above 200,000 BCV (UZS 88 billion), average annual headcount over 100 people. BCV is the base calculation value used across Uzbek legislation.

Public interest entities (PIEs) have a separate regime: the Ministry of Economy and Finance — and for organisations supervised by the Central Bank, the Central Bank itself — include them in a register every year by 1 July. Their IFRS statements are audited by an audit organisation that meets the requirements for mandatory audit, the report is prepared under ISA, and the audit requirements apply to statements for the years following the year of inclusion in the register (Regulation reg. No. 3736, in force from 1 January 2026).

How the audit is carried out

• Engagement acceptance: independence check under Article 34 of ZRU-677, a contract setting out the subject, deadlines and list of documents.
• Planning: understanding the business and the accounting policy, calculating materiality, mapping risks.
• Interim procedures: testing controls and transactions for the months already passed, observing the year-end stock count.
• Substantive procedures: confirmations from banks and counterparties, cut-off testing of revenue and expenses, estimates and provisions, tax calculations.
• Disclosures and subsequent events: reviewing the notes and what happened after 31 December.
• Discussion with management: misstatements identified and ways to correct them before the report is issued.
• Auditor’s report: numbered, signed on every page by the auditors and the head of the audit organisation, with the audited statements attached (Article 39).

Deadlines: which dates the regulations set

How long the audit itself takes depends on the volume of transactions and the state of the books, but the framework is set by regulatory dates:

• annual statements for the previous year are submitted by 1 March inclusive if prepared under NAS, and by 1 May inclusive if prepared under IFRS (para. 7 of Regulation reg. No. 3567);
• in a mandatory audit, the tax authorities receive a copy of the report no later than 15 days after the audit is completed and in any case by 15 June inclusive (Article 35 of ZRU-677);
• public interest entities publish their statements with the auditor’s report at least two weeks before the annual general meeting and no later than 15 June (para. 9 of Regulation reg. No. 3736);
• the company responds to the auditor’s written information on violations no later than 30 days from the date of receipt (Article 37 of ZRU-677).

Types of auditor’s report

The law leaves the form and content of the report to the auditing standards (Article 39 of ZRU-677). ISA 705 establishes three types of modified opinion; if there are no grounds for modification, the opinion is unmodified.

• Unmodified — the financial statements are prepared, in all material respects, in accordance with the applicable framework.
• Qualified — misstatements are material but not pervasive; or sufficient evidence could not be obtained and the possible effect is material but not pervasive.
• Adverse — misstatements are both material and pervasive.
• Disclaimer of opinion — sufficient evidence could not be obtained and possible misstatements could be both material and pervasive.

What the company receives at the end

• The auditor’s report with the statements attached — for the tax authorities, banks, shareholders and investors.
• Written information on identified violations of accounting legislation: the auditor must send it to management and those charged with corporate governance (Article 29).
• Explanations of the opinion expressed and advice on correcting deficiencies — this is the company’s right (Article 37).

What drives the cost

• Reporting framework: IFRS requires more disclosures and estimates than NAS
• Number of material estimates: provisions, impairment, fair value
• Consolidation and the number of legal entities in the group
• First-year audit: opening balances and comparatives are tested additionally
• Quality of the books and availability of documents
• The date by which the report is needed

Typical mistakes before an audit

• No year-end stock count: under NAS No. 19 it is mandatory before the annual statements, and without it balances are hard to confirm.
• Balances with counterparties are not reconciled — differences surface when confirmations are requested.
• The accounting policy differs from the methods actually used.
• The audit is entrusted to an organisation that kept or restored the books or prepared the statements during the audited period — Article 34 of ZRU-677 prohibits this for both mandatory and voluntary audits.
• Counting on a “report without an audit”: such a report is recognised as knowingly false by a court decision (Article 40).