What the law calls a platform
Law ZRU-792 “On Electronic Commerce” is dated 29 September 2022. It was published the next day and came into force three months after publication. Article 3 of the law defines an electronic trading platform as “an information system that allows goods (works, services) to be bought and sold remotely”. The law is quoted from its Russian text; the translation is ours, here and below.
The words “messenger”, “Telegram” and “social network” do not appear in it. Neither does a website with a shopping basket. The definition has two features: an information system, and selling at a distance.
A shop bot meets both. It is a program that answers questions, quotes a price and takes the buyer through to payment, while the buyer sees neither the seller nor the goods.
The whole law hangs on this definition. The same Article 3 defines electronic commerce as buying and selling, as part of business activity, under a contract concluded through an electronic trading platform. If a chat with a bot is not a platform, the law does not apply to it at all. On the wording, it fits. We found no case of a court or regulator applying the law to a Telegram bot, so from here on we take the cautious reading.
The seven items of an offer
Article 16 starts by saying what counts as an offer: a proposal addressed to one or more specific persons which shows that the sender intends to be bound by a contract with whoever accepts it. In e-commerce, it adds, the offer takes the form of an electronic document. As we read it, a bot’s reply to a particular buyer with a price, delivery and a payment method fits that description.
Then the law lists what the offer must contain:
- The seller’s name; for a self-employed person, their full name.
- Postal and email address, phone number.
- Licence or permit details, where the law requires one.
- How the contract is concluded, and how acceptance is sent and withdrawn.
- Whether and how the contract can be amended.
- Delivery and payment terms, and prices.
- A pointer to terms that become part of the contract by reference to an electronic document on a publicly accessible resource.
If a shop sells only through chat, item six turns up in the conversation on its own: price, delivery, how to pay. The other six do not find their way into the chat by themselves. They have to be built in.
Item seven suggests how to do that without a wall of text. The law itself lets part of the terms enter the contract by reference to a document, as long as the document is publicly available. The full terms of sale can be published once, on a page anyone can open. The chat then gives the link and says plainly that the order is placed on those terms.
Where in the chat the contract is made
Article 19 names three ways to accept. An electronic document confirmed with a digital signature. An electronic message which, in the law’s words, “expresses the consent of the e-commerce participant”. And carrying out the actions set out in the offer — paying, for instance. The contract counts as concluded when the seller receives the acceptance.
For a bot, two design decisions follow.
First, the dialogue needs one explicit point of consent. On our reading of Article 19, a buyer writing “I confirm the order” after a summary is acceptance by message. Without such a point, the payment itself may become the acceptance, and the terms it was made on will have to be pieced together from the chat after the fact.
Second, before that point the terms of the order should sit in a single message. If the price came up in the fifth message, delivery in the twelfth, and the return period never came up at all, the buyer is agreeing to something they never saw in full.
Article 21 adds two things. Contract terms must be written “in the state language”; other languages are allowed alongside it. So if the bot chats in Russian, the terms document it links to still needs an Uzbek version. And the terms may set out how personal data is used. A bot that asks for a name, a phone number and a delivery address receives that data either way, so a line in the script explaining why it is needed belongs there.
What the cashless payments decree changed
Presidential Decree UP-246 of 10 December 2025 sets a goal for 2030: “bringing the share of cashless payments made by the public in trade and services to 75 per cent”.
From 1 April 2026 the decree allows only cashless payment for a set of purchases. The list covers government services, electricity, gas and water, alcohol and tobacco, fuel and vehicle charging, property and certain vehicles. It also covers goods and services above a threshold. At first the threshold was 25 million soums. Decree UP-175 of 27 August 2026 replaced that figure with 400 times the base calculation value. Farm produce is exempt. The new wording has applied since 28 August.
For a shop whose orders run to a few hundred thousand soums, the threshold changes little. Point 3 matters more: from 1 July 2026, accepting payment through the unified QR code is mandatory for all legal entities in trade and services. The decree treats not using it as a breach of the trading rules.
Whether that requirement reaches sales made through a chat is not clear from the text of the point. But if the shop is registered as a legal entity, it should already have the QR code. It is more convenient when the QR code or a payment link arrives in the chat together with the amount, so the buyer does not have to ask for it.
How many people are online, and where Telegram is in those numbers
DataReportal’s Digital 2026 report counts 33.1 million internet users in Uzbekistan, 89.0% of the population, and 33.9 million cellular mobile connections. The data is mostly from October 2025. It is an estimate by an analytics aggregator, not official statistics.
The report puts social media user identities at 14.1 million, or 37.9% of the population. That is not a head count: the figure comes from the platforms’ advertising tools, and one person can hold several accounts. Instagram’s ad reach is the same 14.1 million, TikTok’s 2.59 million adults, Facebook’s 2.30 million.
Telegram is not mentioned in the report. We found no reliable figure for its audience in Uzbekistan, and we will not pass on estimates from second-hand retellings. The offer requirements are unaffected either way: they do not depend on audience size.
A bot script: six steps from price to payment
Put Articles 16, 19 and 21 into one dialogue and you get this sequence.
- Answer the price question. Price, availability, delivery, payment methods. On the last line, the seller’s name and a link to the terms of sale.
- Collect the order details. Size, quantity, name, phone, address. Before asking for the phone and address, one sentence on what they are for, with a link to the same document.
- A summary in one message. Item, price, delivery cost and time, payment method, how to withdraw the confirmation if the buyer changes their mind. Below it, the seller’s name, address, phone, email, and licence if one is needed.
- The point of consent. The bot asks for explicit confirmation and does not move to payment without it. On our reading of Article 19, the contract is concluded once the seller receives this message.
- Payment. The amount and payment method in a separate message: a link, a QR code or bank details. The figures in this message should not be written by the model.
- After payment. Confirmation goes to the seller; the buyer gets the delivery time and a contact for questions.
These six steps also work as a specification if the shop’s bot is built to order. We build chatbots for business like that ourselves, in Telegram and WhatsApp, on the client’s own logic.
Here is how it looks in our own product. Valli, our auto-responder for Telegram Business, is in pilot, and we checked this script against what it can do today.
What it covers. Valli takes prices, delivery and payment terms from the profile and catalogue that the owner fills in. While the profile is empty, it names no prices. The owner enters payment details once in the settings: a Payme or Click link, a card, a bank. When a client agrees to the price or asks where to pay, the model adds a service tag with the amount, and the payment details go to the client in a separate message, word for word from the settings. The model never retypes a card number. The client is asked to send a receipt or a screenshot, and the owner gets a notification that an invoice has been issued.
What it does not cover. Valli has no separate step with an order summary and the seller’s details, and no button for explicit consent. The owner can put the business name, contacts and a link to the terms into the payment details text, and they will reach the client verbatim. But they arrive with the invoice, after the client has already agreed to the price. Valli cannot take money or generate a QR code itself: it passes on what the owner has entered.
What we don’t know
This is not legal advice. Whether a shop’s Telegram bot is an electronic trading platform, and whether its messages amount to an offer in the form of an electronic document, is a matter of interpretation. We found no court or regulatory practice on the question.
We read the current version of ZRU-792 on lex.uz as of 13 September 2026. The 2025 and 2026 amendments do not touch Articles 3, 16, 19 or 21, but check the text yourself before changing your contracts.
The UP-246 threshold in soums depends on the base calculation value on the date of purchase, so we give the decree’s wording rather than a conversion. How the QR code point applies to chat sales and to sellers that are not legal entities does not follow from the text of the decree. There are no reliable statistics on Telegram’s audience in Uzbekistan. Valli is described as its code stands on 13 September 2026; that may change during the pilot.
If your sales run through chat and it is unclear at what moment the buyer agrees to the terms, describe that path in the quiz on the main page. Within 48 hours, free and with no intro call, we will take it apart and show which steps are missing.
