Mandatory audit in Uzbekistan: who must, deadlines, fines and cost

The Article 35 list — verbatim

Part one of Article 35 of ZRU-677 as currently in force (our English rendering). Agricultural cooperatives were added by Law No. ZRU-995 (in force from 12 February 2025), the item on companies with a state share is worded as amended by ZRU-1025 (in force from 8 May 2025), and the item on charitable, public and other funds as amended by ZRU-1083 of 21 August 2025 (the official text of this item is in Uzbek; the Russian text on lex.uz is an unofficial translation). The rule sets no minimum size of the state share. “The following organisations are subject to mandatory annual audit:”

• joint-stock companies;
• banks and other credit organisations;
• insurance organisations;
• agricultural cooperatives;
• investment and other funds accumulating funds of legal entities and individuals, and their trustees managing investment assets;
• charitable, public and other funds (except public funds that had no cash turnover on bank accounts during one calendar year) whose sources are contributions from legal entities and individuals;
• business entities whose charter fund (charter capital) includes a share owned by the state;
• exchanges;
• commercial organisations that simultaneously meet two of the following conditions based on the results of the reporting year: book value of assets above one hundred thousand times the base calculation value, revenue from sales of products (works, services) above two hundred thousand times the base calculation value, average annual headcount above one hundred people.

Thresholds for commercial organisations in UZS

A commercial organisation that does not fall into the other categories of the list must be audited under Article 35 only if, based on the reporting year’s results, any two of the three conditions are met at the same time. Exceeding one threshold, even by a wide margin, does not create the obligation. Public interest entities included in the register have a separate requirement: their IFRS financial statements are audited under Regulation reg. No. 3736.

Example: revenue of UZS 95 billion and 120 employees with assets of UZS 30 billion — two conditions, so the audit is mandatory. Assets of UZS 50 billion with revenue of UZS 60 billion and 80 employees — one condition, so on this ground the audit is not mandatory. The thresholds are set in BCV, so their UZS equivalent rises with every BCV increase and compliance needs checking annually. At a BCV of UZS 440,000 (Presidential Decree UP-115):

• balance-sheet assets — more than UZS 44 billion (above 100,000 BCV);
• annual revenue from sales of products, works and services — more than UZS 88 billion (above 200,000 BCV);
• average for the year — more than 100 employees.

When to submit the report: 15 days and 15 June

The law sets two dates at once: a copy of the auditor’s report is submitted to the tax authorities within 15 days after the audit is carried out, but no later than 15 June of the year following the reporting year. For the 2026 financial statements the deadline is 15 June 2027. Evasion means that the annual statements have not been audited by 15 June and there is no auditor’s report.

Joint-stock companies, insurers, banks, public funds and other organisations required to do so by law also publish their annual financial statements together with the auditor’s report no later than two weeks before the annual general meeting (Article 26 of the Law “On Accounting”).

What is audited is the annual financial statements already prepared, and these are filed no later than 1 March under NAS (national accounting standards) and 1 May under IFRS (para. 7 of Regulation reg. No. 3567; this Regulation does not apply to banks, non-bank credit organisations, insurers and budget organisations). So it makes sense to sign the contract before year-end: observation of the stock count and some procedures take place before 31 December, leaving time for corrections before June.

Liability for failing to have an audit

Sanctions apply in two steps: first to the official, then to the company (amounts at a BCV of UZS 440,000).

• Official — a fine of 5 to 10 BCV, i.e. UZS 2.2–4.4 million (Article 179¹ of the Code of Administrative Responsibility, “Evasion of mandatory audit”).
• Company — a fine of 100 BCV (UZS 44 million) if, even after the administrative penalty imposed by the tax authorities, the audit has not been carried out by the end of the calendar year; if the company does not pay voluntarily, the case is heard by the economic court (Article 35 of ZRU-677).
• Paying the fine does not release the company from the mandatory audit — it still has to be carried out.
• A “report without an audit” is no way out: it is recognised as knowingly false by a court decision (Article 40 of ZRU-677), and the auditor faces a fine of 10–15 BCV, or UZS 4.4–6.6 million (Article 179 of the Code of Administrative Responsibility).

Who may perform a mandatory audit

An audit organisation may operate from the date of its inclusion in the Register of Audit Organisations (Article 27 of ZRU-677), the Register is open to the public (Article 41), and the organisation must show the client its auditors’ certificates and liability insurance policy on request (Article 29). Article 35 admits to mandatory audits organisations that meet these conditions:

• at least two auditors on staff, each with at least three consecutive years of continuous experience or an international accountancy certificate;
• external quality control has found no violations of the legislation on auditing activity;
• for audits of banks — at least two auditors on staff certified to audit banks;
• in addition, the restrictions of Article 34 common to any audit apply, including: during the audited period the organisation did not set up, keep or restore your books, did not prepare your financial statements and did not act as your audit committee (revision commission); neither it nor its auditors are your founders or shareholders, and you are not its creditor or insurer; it has not audited you for more than seven consecutive years.

How the audit is carried out

• Assessment and contract: company structure, volume of transactions, accounting policy, results of the previous audit — these determine the scope of work, the team and the fee.
• Planning under International Standards on Auditing: materiality, risk areas, sampling, request schedule.
• Interim stage before year-end: understanding controls, testing transactions, observing the stock count.
• Final stage after the annual statements are filed: confirmations from banks and counterparties, testing revenue, expenses, tax calculations and disclosures.
• Dealing with findings: the company reviews the information on violations, informs the auditor in writing of the results within 30 days and remedies the deficiencies in accounting, reporting and tax calculations (Article 37).
• Auditor’s report: a numbered document signed on every page by the auditors and the head of the audit organisation, with the audited financial statements attached (Article 39); a copy goes to the tax authorities.

Documents for the audit

• Annual financial statements, trial balances, general ledger
• Accounting policy and orders amending it
• Charter, decisions of shareholders or participants, information on ownership shares
• Bank statements, cash documents, ledgers for the main accounts
• Contracts with key customers and suppliers, reconciliation statements
• Stock-count sheets and variance sheets at year-end
• Annual tax returns, tax audit reports
• Auditor’s report and management letter from the previous audit, if there was one

Cost: what the fee is made of

There is no single price list: the fee reflects the team’s time, which is driven by the factors below. The fee is quoted after a preliminary assessment and fixed in the contract together with the scope of work.

• Volume of transactions: number of bank accounts, counterparties, warehouses, lines of business
• Structure: branches, subsidiaries, consolidated financial statements
• Reporting framework: IFRS has more estimates and disclosures than NAS
• Industry: manufacturing and inventories, construction, exports, banking or insurance specifics
• State of the books: unreconciled balances and a missed stock count add procedures
• First audit with a new audit firm: opening balances are tested additionally
• Timing: starting in May for a 15 June deadline requires a larger team

Typical mistakes

• Checking only one indicator against the thresholds — the obligation arises only when two of the three are met.
• Engaging an audit firm that kept or restored the books or prepared the financial statements for the same period.
• Skipping the year-end stock count — balances are then hard to confirm, which affects the auditor’s opinion.
• Putting off the contract until May — there is not enough time for corrections before 15 June.