Uzbekistan regulates artificial intelligence through two documents. The first is Law ZRU-1115, signed on 21 January 2026. It amends existing legislation to define AI, stops anyone from basing decisions about people’s rights on AI output alone, and fines companies that process personal data unlawfully with AI. The second is the set of Ethical Rules approved by Order No. 3787, in force since 17 June 2026, which spell out what developers, implementers, and users actually have to do. Uzbekistan hasn’t passed a standalone AI act, and its rules don’t sort systems into risk tiers or require conformity assessments. The framework is short and blunt, and it’s already enforceable. Below we walk through what each document requires, who it applies to, how it stacks up against the EU AI Act, and what a company using AI in Uzbekistan should do next. Uzbekistan AI Regulation at a Glance (TL;DR) Instrument Date What it does Who it binds Law ZRU-1115 Signed 21 January 2026 Defines AI in law, sets general rules for AI-built information resources and systems, bans legally significant decisions based only on AI, adds fines for unlawful AI processing of personal data State bodies, organizations, website owners, anyone processing personal data with AI Order No. 3787 (Ethical Rules) Registered 14 March 2026, in force 17 June 2026 Sets eight mandatory ethical principles and lists rights and obligations for developers, implementers, and users Individuals and companies developing, implementing, or using AI in Uzbekistan Law No. 1125 (Personal Data amendments) Adopted 26 March 2026 Limits data localization to biometric, genetic, and local telecom user data, and allows cross-border transfers under conditions Personal data operators, including AI providers AI Strategy until 2030 (RP-358) 14 October 2024 Sets national targets for AI adoption, infrastructure, and skills Government bodies What Is Law ZRU-1115? The law’s official title is a mouthful: “On making additions and changes to certain legislative acts of the Republic of Uzbekistan in connection with the regulation of relations arising from the use of artificial intelligence.” Put simply, it’s an amending law. Instead of creating a new AI code, it writes AI into laws that were already on the books. When It Was Signed and When It Took Effect The Legislative Chamber of the Oliy Majlis adopted the bill on 12 August 2025, and the Senate approved it on 1 November 2025. President Shavkat Mirziyoyev signed it on 21 January 2026. You can read the official text in Lex.uz, Uzbekistan’s national legislation database. The law set out the principles and the penalties. The day-to-day detail arrived later with the Ethical Rules, which came into force on 17 June 2026. For compliance planning, treat mid-June 2026 as the point when the whole framework started applying. Why Uzbekistan Amended Existing Laws Instead of Passing a Standalone AI Act Uzbekistan wants more AI, not less. Its national strategy sets numeric targets for adoption, investment, and local computing capacity, and a heavy EU-style act would have worked against them. So lawmakers kept it light. They defined AI, drew two hard lines (human control over decisions that affect people’s rights, and protection of personal data), and left the Ministry of Digital Technologies to fill in the rest through secondary rules. Businesses get less legal certainty, and the government gets to move faster. Which Laws ZRU-1115 Changes For businesses, two amendments matter most. The Law “On Informatization” (ZRU-560-II, 2003) now contains a legal definition of AI, a new article on using AI in information resources and systems, duties for website owners, and updated powers for the ministry in charge. The Code on Administrative Liability now includes an offense for processing and spreading personal data unlawfully using AI. The Legal Definition of Artificial Intelligence in Uzbekistan Under the amended Law “On Informatization,” AI is a set of technological solutions that imitate human cognitive functions, including learning on their own and solving problems, and that produce results on specific tasks comparable to what a person could do. That’s deliberately broad. It covers generative AI, machine learning classifiers, recommendation engines, and most agentic systems. The Ethical Rules add a narrower term, the AI system: software built on AI that can find, collect, store, analyze, process, evaluate, and use data, and make decisions on its own based on that data. If your product makes a decision from data, or shapes one, assume it counts. Key Rules Introduced by Law ZRU-1115 General Principles for Using AI in Information Systems and Resources The new article in the Law “On Informatization” starts from harm. Information resources created with AI, and information systems running on AI, must not harm people’s life, health, freedom, honor, or dignity, or violate their other inalienable rights. The standard is short and open-ended. It gives regulators something to enforce against without saying in advance what counts as harm. Principle-based rules like this deserve to be taken seriously precisely because the edges are undefined. Human Oversight: No Decisions on Rights and Freedoms Based Solely on AI Most coverage leads with this provision, and it’s easy to see why. When someone makes a legally significant decision that affects human rights and freedoms, they can’t rely only on conclusions produced by AI systems or AI-built information resources. AI can feed into the decision, but a person has to make it. That applies to loan denials, benefit eligibility, hiring rejections, licensing outcomes, and disciplinary action. In each case, someone needs to look at the AI output and own the final call. Insider Note: In AI governance engagements, teams rarely struggle to show that a review step exists. What they struggle to show is that the reviewer could disagree, and sometimes did. If a human clicks “approve” on every AI recommendation and nobody ever records an override, auditors will see automation with a signature on top. Build the override path and log when people use it, starting on day one. Powers of the Authorized State Body (Ministry of Digital Technologies) ZRU-1115 makes the Ministry of Digital Technologies the authorized state body for AI. Among its new jobs, it’s

Hardly any startup starts a compliance program because it wants one. It usually starts the week an enterprise buyer sends over a 200-question security questionnaire, the deal stalls, and it turns out nobody on a team of 20 engineers knows what a Statement of Applicability is. Managed cybersecurity compliance means handing that problem to an outside team. They scope the framework, put the controls in place, write the policies, run the GRC platform, and deal with the auditor until you have a report or certificate in hand. Below: what a managed service should include, how it’s different from buying software or hiring an MSSP, what it costs, how long it takes, and how to tell a good provider from a bad one. What Is Managed Cybersecurity Compliance? Managed cybersecurity compliance is an outsourced service in which a provider designs, implements, and maintains your compliance program against one or more frameworks, such as SOC 2, ISO 27001, HIPAA, or GDPR. You stay accountable for your own security, but the provider does the work that gets you audit-ready and keeps you there. You’ll also see it sold as Compliance as a Service. Managed Compliance vs. Compliance Automation Software Alone A GRC platform automates evidence collection and monitors your cloud accounts, identity provider, and devices for control failures. It doesn’t decide your audit scope, write a risk assessment that reflects your business, fix the failing controls, or answer the auditor’s follow-up questions. Somebody still has to own all of that, and in most startups it lands on the CTO by default. With a managed service, it lands on the provider. Managed Compliance vs. Managed Security Services (MSSP) An MSSP runs security operations: monitoring, detection, incident response, often through a Security Operations Center. A managed compliance provider runs the governance side: controls, policies, evidence, audits. There’s overlap, since every framework asks for monitoring and incident response. But an MSSP contract won’t get you a SOC 2 report, and a compliance engagement won’t watch your logs at 3 a.m. unless the scope says so. Where a vCISO or CISO-as-a-Service Fits In A virtual CISO is part-time security leadership. They set direction, make the risk calls, and take the awkward calls with a customer’s security team. Many managed services add a vCISO after certification, because somebody has to chair management reviews and sign off on risk treatment once the project team has gone. If a provider’s offer ends the day the certificate arrives, ask who plays that role in year two.   GRC platform alone MSSP Managed compliance Primary output Dashboards and automated evidence Threat monitoring and response Audit report or certification Who implements controls Your team Your team (security tooling only) Provider, with your engineers Policies and risk assessment Templates Not included Written for your business Auditor coordination Not included Not included Included Internal time required High Medium Low Why Startups Outsource Cybersecurity Compliance No In-House Security or GRC Headcount Most startups don’t hire a security person until somewhere around 50 to 75 employees, and a GRC specialist comes later than that. Bigger companies have the same problem. The 2025 ISC2 Cybersecurity Workforce Study found that 59% of security teams report critical or significant skills gaps, up from 44% a year earlier, and a third of respondents said their organizations can’t afford to staff security adequately. A Series A company is competing for the same people with a smaller budget. Enterprise Deals Blocked by Security Questionnaires Revenue is the usual trigger. A prospect’s procurement team asks for a SOC 2 Type II report or an ISO 27001 certificate, and the deal sits there until you produce one. Every week you spend working out compliance from scratch is another week the contract stays unsigned. Investor and Due Diligence Expectations Security now comes up in most due diligence processes, especially for companies that hold customer data, health data, or payments. A current report or certificate answers most of those questions in a single document, which a half-finished controls spreadsheet won’t. The Hidden Cost of Engineer-Led, DIY Compliance DIY compliance looks cheap because the cost is buried in engineering time. A senior engineer who spends a quarter configuring a GRC platform and chasing screenshots isn’t shipping product that quarter. The work also tends to stall around 70%. By then the easy integrations are connected, and what’s left is a pile of judgment calls nobody on the team has made before. Insider Note: The controls startups fail most often are rarely technical. They’re process controls that need a paper trail. Think quarterly access reviews that never happened, a former contractor who still has repository access, or vendor reviews that exist only as a sentence in a policy. A platform will flag all of these, but someone still has to go and do them. What a Managed Compliance Service Includes Scope varies a lot between providers, so compare offers line by line. A complete service covers everything below. Framework Scoping and Gap Assessment The provider confirms which framework you need, what is in scope (products, environments, teams, locations), and where you stand against the requirements today. Most of the savings in a compliance project come from good scoping. A narrow scope you can defend to an auditor means fewer controls to run and a smaller audit fee. Risk Assessment and Risk Treatment Both SOC 2 and ISO 27001 require a documented risk assessment. The provider runs it with your leadership, writes down the risks that matter to your business, and agrees a treatment plan with you. For ISO 27001 this feeds the Statement of Applicability, which is the first document an auditor reads. Policy and Procedure Development Expect a set of 15 to 25 policies covering access control, change management, incident response, vendor management, business continuity, and acceptable use. What matters is whether the policies describe what your company really does. Auditors check practice against policy, so a template promising weekly vulnerability scans you don’t run will turn into a finding. Compliance Platform Setup and Control Implementation The provider