President Shavkat Mirziyoyev has signed a law that fundamentally changes the rules of the game in Uzbekistan’s digital sector (the full text of the signed law in Uzbek is attached below). The new version of Article 27¹ of the Law “On Personal Data” eliminates legal conflicts that for years blocked the entry of the world’s largest financial platforms, such as Apple Pay, Google Pay, and PayPal.
The end of “digital isolation”
Before the amendments, Uzbek legislation required foreign companies to localize all citizens’ personal data on servers within the country. For global IT giants, whose infrastructure is built on distributed cloud computing, this requirement was technically unfeasible and economically impractical.
The new law, which entered into force on March 27, 2026, shifts from total control to a selective approach. Now, only the following are subject to mandatory localization:
- Biometric and genetic data;
- Data of subscribers of local telecom operators.
All other categories of data — including payment information and account identifiers — are now officially allowed to be processed on foreign servers, provided that international security standards are observed.
Implementation of the “Washington promise”
This step became the logical conclusion of a process announced by the head of state in November last year. Speaking in Washington at a meeting with representatives of American business, Shavkat Mirziyoyev directly linked the legislative reform to the arrival of global payment systems.
“We are finalizing, together with our American partners, the work on updating the legislation. This will create opportunities for a new technological partnership, including the launch of global payment systems Apple Pay and Google Pay,” the president said at the time.
Experts note that the liberalization of cross-border data transfers was a key condition of the U.S. Department of State and American technology companies for deepening investment cooperation.
What does this mean for consumers and businesses?
The launch of Apple Pay and Google Pay in Uzbekistan means more than just the convenience of contactless payments via smartphone. For the country’s economy, this brings a number of systemic changes:
- Economic transparency: Integration with global systems stimulates a shift from cash to digital transactions, reducing the share of the shadow economy.
- Investor confidence: Removing barriers for PayPal opens the way for Uzbek freelancers and exporters to access the global e-commerce market (eBay, Amazon, Etsy).
- Technology transfer: As Mirziyoyev emphasized, payment systems will be followed by the creation of a network of digital academies and startup hubs with U.S. support.
| Data category | Requirement before March 2026 | Requirement after March 2026 |
|---|---|---|
| Biometrics | Localization in Uzbekistan | Localization in Uzbekistan |
| Financial transactions | Localization in Uzbekistan (de jure) | Storage abroad permitted |
| Social media / E-mail data | Localization in Uzbekistan (de jure) | Storage abroad permitted |
Remaining challenges: tokenization for wallets and a business decision for PayPal
Despite the legal barrier being lifted, the technical rollout of services may take time, requiring the completion of interbank and corporate procedures.
For the full launch of mobile wallets Apple Pay and Google Pay, the ball is now in the court of the Central Bank and commercial banks of Uzbekistan. As financial market analysts note, local banks will need to undergo technical certification and integrate tokenization systems into their processing centers — MDES by Mastercard and VTS by Visa. This process requires technological upgrades to each individual bank’s infrastructure.
The situation is different for PayPal. Technical integration is less complex here, as the service works directly with international payment system cards that are already serviced in the country. The key factor for PayPal will be the company’s internal business decision to enter the Uzbek market, as well as the adjustment of compliance procedures in line with Uzbekistan’s new legislation. If Apple Pay is implemented “bottom-up” by banks, PayPal requires a “top-down” decision from company leadership.
Nevertheless, the political will expressed in Tashkent and confirmed in Washington indicates that the arrival of digital giants in Uzbekistan is now a matter of months, not years.
Apple Pay, Google Pay, and PayPal in Central Asia
Uzbekistan was officially absent from the list of countries supported by PayPal (more than 200 regions), while neighboring countries, including Kazakhstan, Kyrgyzstan, Tajikistan, and Turkmenistan, were included. The reason lay in the strict interpretation of the data localization law.
As for Apple Pay and Google Pay, Apple and Google enter markets much more cautiously than PayPal, as they require deep integration with the banking system (tokenization).
At the same time, both systems operate in Kazakhstan — Apple Pay since 2018, Google Pay since 2021. In Kyrgyzstan, Google Pay was launched in November 2022, while Apple Pay has not yet had a full official launch. Google Pay is available in Tajikistan; the absence of Apple Pay in Dushanbe at the moment is more likely due to Apple’s economic priorities rather than legal restrictions. In Turkmenistan, these services are effectively not present.