Marketing consent in Uzbekistan: the law and a checklist

Marketing consent in Uzbekistan is mandatory for advertising: Article 30 of the Law “On Advertising” (ZRU-776) permits advertising through telecommunications services only with the subscriber’s prior consent. The second layer is the Personal Data Act (ZRU-547): a recipient's phone and name are personal data, and a new purpose requires fresh consent. From 1 November 2026, under PP-265, promotional SMS need written or electronic consent, and promotional calls and messages over mobile networks are banned from 18:00 to 09:00. Before the first send you need five things: consent, a stated purpose, a one-step opt-out, a known contact source and a permitted send time. Breaches count as violations of both advertising and personal data law, with administrative offences under Articles 46-2 and 178-1 of the Administrative Code. In Zukko.AI consent is recorded in the customer record with a date and source, segments are built only from those who agreed, opt-out is built in, and the AI employee (AI agent) handles replies.

Does the law require marketing consent in Uzbekistan

For promotional messaging, yes. Two layers of rules apply. The first is about advertising: Article 30 of the Law “On Advertising” (ZRU-776 of 7 June 2022) allows advertising in the course of providing telecommunications services only with the subscriber’s prior consent (lex.uz). The second is about data: a phone number, a name and a purchase history are personal data, and processing them is governed by the Law “On Personal Data” (ZRU-547, lex.uz).

Neither Article 30 nor PP-265 names messengers: the rules speak of telecommunications services, SMS and mobile networks. Whether the requirement extends to promotional messages on Telegram, WhatsApp or Instagram is a question of interpretation — put it to a lawyer. The practical conclusion does not change: the recipient’s data is still processed under ZRU-547, and the platforms themselves restrict senders who get reported. Telegram, for one, temporarily limits an account after spam reports (telegram.org).

How segments, scheduling and delivery analytics work is on the Campaigns page.

What changes for promotional SMS and calls on 1 November 2026

Presidential Resolution PP-265 of 15 July 2026 (item 11) introduces a procedure that applies from 1 November 2026 (lex.uz):

• Promotional SMS only with consent. Legal entities and individuals may advertise goods, work and services by SMS only after obtaining the person’s written or electronic consent.
• A ban from 18:00 to 09:00. Promotional calls and notifications may not be distributed over telecommunications networks (mobile) during those hours.
• Registration of messaging services. Legal entities that provide promotional call and SMS delivery services may operate only after registering their information systems in the State Register of Personal Data Bases.
• Blocking at the subscriber’s request. Mobile operators must fully or partially block the promotional calls and notifications they distribute.
• Two bodies of law at once. Failure to comply counts as a breach of both advertising and personal data legislation.

For a business this means two practical changes: consent for promotional SMS has to exist in written or electronic form, and the schedule has to fit the 09:00–18:00 window. In Zukko.AI a campaign is scheduled for a chosen date and hour in the Tashkent time zone, but picking a permitted time remains the job of whoever launches it.

Spam or a lawful campaign: the difference

The difference is not the number of messages but the basis for sending, the declared purpose and whether the recipient can say no.

Pre-send checklist: what must be in place before the first message

Four things are needed before the first message: consent, a purpose, a way to opt out and the source of the contact. A fifth, the time of sending, is added on 1 November 2026. Each one needs evidence you can actually produce.

How to collect marketing consent

“Opt-in” is the market’s word for consent; the statutes do not use it. ZRU-547 (Article 21) does not prescribe a special form: consent is given in any form that makes it possible to confirm it was obtained. For promotional SMS the bar is higher from 1 November 2026 — written or electronic consent. So consent is collected in a way you can show later:

• A separate tick box at the entry point — in a website form, a chat or an order flow. The text beside it states the purpose: “I agree to receive promotional messages”.
• An entry in the customer record in the AI-CRM: date, source and channel — as a tag, for example.
• A segment built only from those who consented. In Zukko.AI a campaign audience is assembled from the CRM by tags, funnel stage and customer history.

Consent to process data for an order and consent to advertising are different purposes. Article 19 of ZRU-547 requires consent to be obtained again when the purpose of processing changes.

How to handle an opt-out

Opting out is the person’s right. Under Article 30 of ZRU-547 they may withdraw consent, and under Article 21 they do so in the same form in which it was given, or in writing. Article 17 lists withdrawal of consent among the cases in which personal data must be destroyed. From 1 November 2026 mobile operators must block the promotional calls and notifications they distribute when a subscriber asks.

The Law “On Advertising” does not describe a separate unsubscribe procedure, so the business chooses the method itself. The rule that works is one step: a reply with the word “stop”, a button or a link in every promotional message. The person who opted out is marked in the record and removed from the segment before the next send. In Zukko.AI unsubscribe is built in: the recipient opts out with a button or a command, and the system excludes them from later sends.

Where to keep the list and the consent evidence

After the ZRU-1125 amendment of 26 March 2026, Article 27-1 of ZRU-547 makes storage in Uzbekistan mandatory for three categories of data: biometric data, genetic data and data on users of telecommunications operators’ services (lex.uz). Other personal data may be stored and processed abroad if one of the conditions in the same article is met. An ordinary campaign list — name, phone number, order history — does not usually fall into the three categories, but the answer depends on your industry. The detail is in the article on personal data localisation under ZRU-547.

Keep the consent evidence where the contact lives — in the customer record, with the date and the source. Zukko.AI stores the data of customers from Uzbekistan on infrastructure inside the country; how access rights and the activity log work is on the Security page.

An honest word on guarantees: Zukko.AI claims no certification and gives no legal guarantees. The platform helps you keep consents, segments and the sending schedule in order; the legal assessment of your campaign comes from your lawyer.

What liability applies to messaging without consent

Article 49 of the Law “On Advertising” and Article 33 of ZRU-547 are worded alike: those guilty of a breach bear liability in the established procedure. The administrative offences are in the Code of Administrative Liability: Article 46-2, “Violation of personal data legislation”, and Article 178-1, “Violation of advertising legislation” (lex.uz). PP-265 adds that failing to meet the new requirements counts as a breach of both advertising and personal data legislation.

We do not quote fine amounts here: they are set in base calculation units and depend on the specific offence and the current wording of the code. Which rule applies to your campaign is for a lawyer to determine.

What the business gets

• Less legal risk — campaigns go out on consent you can evidence.
• Fewer complaints and channel restrictions — the recipient expected the message rather than being surprised by it.
• Sending at a permitted time — a campaign is scheduled, in the Tashkent time zone.
• A precise segment — an audience from the CRM by tags, funnel stage and history, with no hand-built lists.
• Ready for questions — the date and source of consent sit in the customer record.

How this works together with segments and channels is in the guide to bulk campaigns from a CRM.