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    IFRS audit and conversion of financial statements in Uzbekistan

    Conversion from Uzbek national accounting standards, preparation and consolidation of IFRS statements, accounting policies and audit under ISA — for mandatory and voluntary adopters

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    Service: IFRS audit and conversion of financial statements in Uzbekistan

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    IFRS in Uzbekistan and what the service covers

    IFRS Accounting Standards are international rules for preparing financial statements that investors and lenders can compare across countries. They are issued by the International Accounting Standards Board (IASB), an independent standard-setting body within the IFRS Foundation; according to the Foundation, companies in more than 140 jurisdictions are required to use them. In Uzbekistan, accounting entities may apply IFRS in the manner established by law, and the requirements for IFRS financial statements are set by the standards themselves (Articles 10 and 22 of the Law on Accounting). Locally, IFRS is called МСФО in Russian and MHXS in Uzbek.

    The rules on mandatory adoption changed on 17 December 2025, when paragraph 1 of Presidential Resolution PP-4611 lapsed — the provision that since 2021 had required joint-stock companies, commercial banks, insurers and large taxpayers to report under IFRS. IFRS reporting is now mandatory for joint-stock companies (Article 102 of the Law on Joint-Stock Companies and Protection of Shareholders' Rights) and for public interest entities (PIEs) on the Register maintained under Presidential Resolution PP-282 and the Regulation registered under No. 3736.

    Leader Audit runs IFRS engagements end to end: conversion of statements prepared under national accounting standards (NAS), preparation and consolidation of group statements, IFRS accounting policies, audit under International Standards on Auditing (ISA) and training for the finance team. Uzbek law treats the preparation of IFRS financial statements as a related service of an audit firm (Article 33 of the Law on Audit Activity, ZRU-677) and prohibits the firm from auditing an entity for a period in which it provided that service (Article 34). For each period we therefore act in one role only — we either prepare the statements or audit them.

    Who must report under IFRS in Uzbekistan in 2026

    • Joint-stock companies — they publish annual IFRS financial statements, after an external audit under ISA, at least two weeks before the annual general meeting of shareholders (Article 102 of the Law on Joint-Stock Companies)
    • Entities whose securities are listed on a stock exchange and publicly traded
    • Commercial and microfinance banks, microfinance and factoring organisations, mortgage refinancing and guarantee organisations, payment system operators and payment institutions
    • Investment funds and exchanges
    • Enterprises in which the state holds 50% or more of the charter capital, if for the last two consecutive calendar years their assets were at least 1 million BCV and their net revenue together with dividend income was at least 1 million BCV
    • Other commercial organisations that for the last two consecutive calendar years simultaneously had assets of at least 1 million BCV, annual net revenue of at least 1 million BCV and an average headcount of at least 500 employees

    Items 2–6 are the PIE criteria set out in Annex 1 to the Regulation approved by the Ministry of Economy and Finance and the Central Bank (registered No. 3736 on 27 December 2025, in force since 1 January 2026). The Regulation is published in Uzbek only; the list above is our translation. Entities that meet the criteria are added to the PIE Register by 1 July each year. BCV is the base calculation value set by presidential decree.

    What changed on 17 December 2025

    Until then, paragraph 1 of PP-4611 required joint-stock companies, commercial banks, insurers and legal entities classified as large taxpayers to keep their accounts under IFRS from 1 January 2021 and to prepare IFRS financial statements starting with the 2021 results. Presidential Resolution PP-282 of 15 September 2025 repealed that paragraph and introduced the status of public interest entity (PIE) for businesses whose type of activity and/or size of assets gives them a high social and economic impact and a wide range of stakeholders.

    That is why a company's status should be checked against the current criteria rather than the 2020 list, which many sources still cite — including, as of October 2026, the Uzbekistan profile on the IFRS Foundation website. The PIE Register is published on the Ministry of Economy and Finance page of the Government Portal: the version of 6 August 2026 lists 425 entities, all added in 2026. The Register applies the 1 million BCV threshold at a BCV of UZS 412,000, i.e. UZS 412 billion; at the BCV of UZS 440,000 in force since 1 September 2026 (Presidential Decree UP-115), the same threshold equals UZS 440 billion.

    Obligations of public interest entities

    • The Register is compiled by 1 July each year by the Ministry of Economy and Finance (by the Central Bank for the entities it supervises) and posted on the Government Portal and the Open Data Portal; an entity is notified of its inclusion within ten days. Assets, revenue and headcount are taken from the financial statements filed with the tax authorities for the two calendar years preceding the year of review.
    • IFRS accounting starts on 1 January of the year following inclusion in the Register — 1 January 2027 for entities added in 2026. IFRS financial statements are prepared and published together with the audit report for the next (second) year, unless the law sets an earlier date for the entity.
    • Annual IFRS statements are filed by 1 May of the year following the reporting year (deadlines follow Regulation No. 3567). Together with the audit report they are published on the entity's website and on the Unified Portal of Corporate Information at least two weeks before the annual meeting of shareholders or other supreme governing body, and no later than 15 June.
    • A PIE with subsidiaries or other controlled entities prepares consolidated group statements and its own separate statements. Under PP-282, any legal entity that prepares consolidated IFRS statements must also prepare separate IFRS statements.
    • The audit report is issued under the International Standards on Auditing; the audit requirements apply to statements for the years following the year of inclusion in the Register. The auditor must be on the Register of Audit Organisations and meet the statutory requirements for firms that perform statutory audits; a PIE chooses its auditor itself, while state customers follow public procurement law.
    • An entity that no longer meets the criteria stays on the Register for two more years and is removed if it still does not meet them during those two years.

    Voluntary adoption of IFRS

    Companies that are not required to apply IFRS may adopt it voluntarily. A legal entity that decides to switch in a reporting year notifies the tax authority through the taxpayer's personal account by 1 March of the following year, stating the transition date (PP-282, paragraph 6). Businesses that voluntarily prepare IFRS statements are exempt from filing financial statements under national accounting standards (PP-4611, paragraph 2): annual IFRS statements are filed by 1 May of the following year, while NAS statements, otherwise due by 1 March, are not filed (Regulation No. 3567, paragraphs 7 and 12).

    Voluntary adoption pays off when the IFRS statements have a specific reader:

    • a foreign investor, a buyer of a stake or the parent of an international group that compares the business with peers on the same basis;
    • lenders, especially international banks and financial institutions, which often make IFRS statements a condition of financing;
    • a stock exchange: once its securities are listed, a company becomes a PIE under the first criterion, so it is better to start the transition before the offering.

    First-time adoption and typical adjustments

    First IFRS statements are prepared under IFRS 1: a complete set covering the first IFRS reporting period and the preceding year, the same accounting policies for all periods presented, and disclosures explaining how the transition affected the reported financial position, financial performance and cash flows. In practice this means data for at least two years and an accounting policy approved before the calculations start.

    Annual IFRS statements filed in Uzbekistan comprise a statement of financial position, a statement of profit or loss and other comprehensive income, a statement of changes in equity, a statement of cash flows (indirect method) and notes (Regulation No. 3567, paragraph 11). The areas that usually take the most work:

    • property, plant and equipment and impairment (IAS 16 and IAS 36): an asset must not be carried at more than the amount recoverable through its use or sale;
    • receivables and other financial assets (IFRS 9): classification, measurement and an allowance for expected credit losses;
    • leases (IFRS 16): a lessee recognises a right-of-use asset and a lease liability for all leases with a term of more than 12 months, unless the underlying asset is of low value;
    • revenue (IFRS 15): recognised as promised goods or services are transferred to the customer, applying the five-step model;
    • deferred tax (IAS 12): recognised on temporary differences between the carrying amount of assets and liabilities and their tax base;
    • consolidation (IFRS 10): a parent that controls other entities presents the group as a single economic entity.

    What changes from 2027

    • On 1 January 2027, National Financial Reporting Standard (NFRS) No. 1 on presentation and disclosure in financial statements (registered No. 3923 on 13 August 2026), which replaces national accounting standard No. 1, and NFRS No. 2 on the basis of preparation, accounting policies and accounting estimates (registered No. 3810 on 11 April 2026) come into force. The national financial reporting standards are adopted under PP-282 and do not apply to public interest entities or budget organisations.
    • From 1 January 2027, PIEs apply the IFRS Sustainability Disclosure Standards and publish the sustainability report, with the audit report, together with their financial statements.
    • The IASB's IFRS 18 Presentation and Disclosure in Financial Statements replaces IAS 1 for annual reporting periods beginning on or after 1 January 2027 and introduces two defined subtotals in the statement of profit or loss — operating profit and profit before financing and income taxes. As of October 2026, IFRS 18 is not on Uzbekistan's list of recognised IFRS texts (Order No. 3400, as amended on 25 July 2026), so companies that also report to a foreign group should plan for both requirements.

    What the service covers

    Conversion from national standards

    We convert NAS statements to IFRS through a conversion worksheet: every adjustment comes with a calculation, a rationale and a reference to the standard, so it can be tested in the audit and repeated next year.

    IFRS financial statements

    A complete set — four primary statements and notes — including first-time IFRS statements under IFRS 1 with prior-year comparatives and disclosure of the transition effect.

    Group consolidation

    Consolidated and separate statements: the group perimeter based on control and elimination of intragroup transactions — for PIEs, holding companies and subsidiaries of foreign groups.

    IFRS accounting policy

    An accounting policy and a register of key judgements: useful lives, the expected credit loss model, discount rates and materiality.

    Audit of IFRS statements

    An audit under ISA and an audit report for publication, shareholders, a bank or an investor — provided we did not prepare the statements for that period.

    Training for the finance team

    We walk your accountants through the adjustments and the accounting policy using your company's own data, so the team can prepare the next statements itself or with less outside help.

    How an IFRS engagement runs

    1. 1

      Status and scope

      We establish whether the company must apply IFRS (JSC status, PIE criteria, deadlines) or is adopting voluntarily, who needs the statements and which role we take — preparer or auditor.

    2. 2

      Accounting policy and transition date

      We choose the transition date and accounting policies and document the key judgements. For voluntary adoption we prepare the notice to the tax authority, due by 1 March.

    3. 3

      Data collection

      We request what NAS records do not contain: lease contracts with payment schedules, customer payment histories, data for measuring assets and liabilities, and related-party information.

    4. 4

      Adjustments

      We build the conversion worksheet, calculate the adjustments and deferred tax and, where needed, consolidate the group.

    5. 5

      Statements and notes

      We prepare the statements and notes, agree judgements and disclosures with you, and hand over the working files and methodology for next year.

    6. 6

      Audit and publication

      If your team prepared the statements, we audit them under ISA; if we prepared them, we support the audit by another audit firm. For JSCs and PIEs — in time for the publication deadline.

    Why Leader Audit

    • An audit firm operating since 2013, with 220+ audit engagements completed
    • International CAP, CIPA, DipIFR (ACCA) certifications among lead specialists
    • Audits under International Standards on Auditing (ISA)
    • Adjustments documented the way an auditor tests them: calculation, rationale, reference to the standard
    • Separate roles: preparation and audit of the same period are done by different firms, as Article 34 of ZRU-677 requires
    • Confidentiality — NDA signed at the start
    • Fixed fee in the contract once the scope is assessed

    Pricing of IFRS services

    The fee is calculated after a diagnostic review and depends on the type of work (conversion, preparation, consolidation, audit), on whether these are first-time IFRS statements (which require prior-year comparatives), on the number of group entities, on the volume and complexity of transactions — leases, financial instruments, foreign-currency settlements — and on the state of the NAS accounts and the deadline. The fee is fixed in the contract. The first consultation is free.

    IFRS in Uzbekistan: frequently asked questions

    What is IFRS, in simple terms?

    IFRS Accounting Standards are international rules for preparing financial statements so that investors and banks can compare companies across countries. For example, under IFRS a lessee recognises leases longer than 12 months (other than leases of low-value assets) as a right-of-use asset and a lease liability, and revenue is recognised as goods and services are transferred to the customer. In Uzbekistan IFRS is called МСФО in Russian and MHXS in Uzbek.

    Which companies must report under IFRS in Uzbekistan in 2026?

    Joint-stock companies and public interest entities on the Register of the Ministry of Economy and Finance: listed companies, banks and the other financial organisations named in the criteria, investment funds, exchanges, large enterprises with a state share of 50% or more, and companies with assets and revenue of at least 1 million BCV each and at least 500 employees for two consecutive years. The PP-4611 list (JSCs, banks, insurers, large taxpayers) lapsed on 17 December 2025.

    Do foreign-owned subsidiaries in Uzbekistan have to use IFRS?

    Not because of foreign ownership as such. A subsidiary must report under IFRS if it is a joint-stock company or meets a PIE criterion — most often the size test: assets and revenue of at least 1 million BCV each and at least 500 employees for two consecutive years. The 2026 Register includes 27 enterprises with foreign capital (registered as joint or foreign enterprises), all of them under this size criterion. Other subsidiaries report under national standards and may switch to IFRS voluntarily.

    When does a company on the PIE Register start IFRS accounting?

    On 1 January of the year after inclusion: for the 2026 Register, on 1 January 2027. IFRS statements with the audit report are prepared and published for the next (second) year, unless the law sets an earlier date, no later than 15 June of the year following the reporting year.

    Can a company adopt IFRS voluntarily and stop filing national-standard statements?

    Yes. A company that decides to switch in a reporting year notifies the tax authority through the taxpayer's personal account by 1 March of the following year, stating the transition date (PP-282). It is then exempt from filing NAS financial statements (PP-4611) and files annual IFRS statements by 1 May. The exemption does not extend to tax returns.

    What is the difference between conversion and parallel accounting?

    Conversion restates finished NAS statements into IFRS through adjustments: it is cheaper to start and enough when IFRS statements are needed once a year. Parallel accounting records every transaction under both frameworks: it costs more to set up, but IFRS figures are available at any time — useful for quarterly reporting to a bank or a parent company.

    Can the same audit firm prepare IFRS statements and audit them?

    No. Preparing financial statements, including under IFRS, is a related service (Article 33 of ZRU-677), and an audit firm may not audit an entity for a period in which it provided that service (Article 34). If we prepare the statements, another firm audits them; if your team prepares them, we can audit them.

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