Invoice that cannot be printed
In Uzbekistan, you can no longer issue paper invoices: since 2020, invoices are issued only in electronic form. However, “electronic” here does not mean a PDF sent by email—it is a document within the state system that the other party is required to sign with their digital signature.
Because of this, the e-invoice acquires a property that paper invoices did not have: it can **get stuck**. You issued it, but the counterparty didn’t sign it—and the document effectively doesn’t exist. Let’s examine who is required to issue it, how much time the buyer has, what has changed since January 2026, and how costly an error can be.
Who is required to issue an e-invoice?
The obligation does not apply to everyone, but only to specific categories. If you belong to one of them, they simply won’t accept the paper version from you.
The most common misconception among small companies is: "We're small, so we can stick to the old ways." Business size doesn't matter—what matters is your VAT status.
- All VAT payers—regardless of ownership structure and size.
- Individual entrepreneurs who have switched to VAT voluntarily or compulsorily.
- Import and export operations for specific categories of foreign economic activity.
- Transactions with non-residents.
Ten days that are forgotten.
The supplier-issued e-invoice must be confirmed by the buyer with their electronic signature within **10 calendar days**, or it must be rejected with a specific reason stated.
Calendar days, not working days. New Year holidays, weekends, and the accountant's vacation are all included in this period.
Practical consequence: it’s not enough to issue a document and forget about it. Someone needs to monitor what happens with the issued e-invoices; otherwise, at the end of the quarter, you’ll find that some are still unsigned, but you already need to close the period.
What has changed since January 1, 2026?
Automatic license verification has been introduced. If you sell goods in licensed business activities, you can now issue an electronic sales invoice only after the system confirms that the seller has a valid license or permit.
Previously, the absence or expiration of a license would only be detected during an inspection, i.e., after the fact. Now, it blocks the document at the time of issuance—you simply won’t be able to process it.
What this means in practice is that the license validity has become an operational parameter, not just a piece of paper in a folder. An expired license stops today's shipment, not "someday later."
How much does a violation cost?
Violation of the rules for using e-invoices is provided for in Article 175¹ of the Code on Administrative Offenses: **3–7 MCI** for the first violation within a year and **7–10 MCI** for subsequent ones.
The basic calculation unit in 2026 is 412,000 soum. Thus, the first violation will cost approximately 1.2–2.9 million soum, and a repeat offense will cost 2.9–4.1 million.
As always with texts like these: amounts and rates change, so before relying on anything, check the current version of the code or consult your accountant. Don’t take this article at face value either.
Where does it break down in practice?
Technically, the e-invoice system operates through electronic document management operators, among whom roaming is in effect—meaning your counterparty may be using a different operator, and that’s perfectly normal.
The problems don’t arise within the system itself, but at the interface with your accounting. The document is created by a person who retrieves data from where you manage goods and services: from 1C, a warehouse management system, a spreadsheet, or a CRM.
Typical failure points: a counterparty is entered without an INN or with an incorrect one; an item lacks a code and unit of measurement from the classifier; there is a discrepancy between what was shipped and what appears in the document; no one checks unsigned e-invoices until the end of the month.
- The counterparty's TIN is the key for matching. The name won't help if the TIN is incorrect.
- Positions must be entered with a code and unit of measurement from the classifier, not estimated in "pieces."
- A regular report on "sales without e-invoices" and "e-invoices without signatures" is needed—otherwise, they will be brought up during the reporting period.
- The license validity period should be displayed where it’s visible, not stored in a folder.
Frequently asked questions
Who is required to issue e-invoices in Uzbekistan?
All VAT payers, regardless of ownership structure and size, individual entrepreneurs who have switched to VAT voluntarily or compulsorily, as well as import-export transactions in certain categories of foreign economic activity and transactions with non-residents.
How much time does the buyer have to sign the e-invoice?
Ten calendar days—calendar, not working days. Within this period, the buyer either confirms the document with their electronic signature or rejects it, specifying a concrete reason.
What has changed in the ESF since January 1, 2026?
When selling goods under license-required activities, an electronic sales document can only be issued after the system automatically verifies that the seller has a valid license or permit. An expired license now immediately blocks the issuance of the document, rather than being flagged during verification.
What is the fine for violating the rules of using e-invoices?
Under Article 175¹ of the Code on Administrative Responsibility, penalties range from 3 to 7 Basic Calculation Units (BCU) for the first violation within a year and from 7 to 10 BCU for subsequent violations. With a BCU of 412,000 soum in 2026, this amounts to approximately 1.2–2.9 million soum for the first violation. The amounts and provisions should be verified against the current version of the code.