Why bids get rejected in public procurement in Uzbekistan and how to avoid it

When the law requires a bidder to be disqualified

The procurement commission or the operator of the electronic procurement system disqualifies a participant if (Law of the Republic of Uzbekistan “On Public Procurement” No. ZRU-684, Art. 42):

• it is listed in the Unified Register of Unscrupulous Contractors. Companies are put on it for two years if they refused a contract, failed to perform it, submitted false documents or concealed affiliation (ZRU-684, Art. 48);
• it has overdue tax debt (taxes and fees). The law sets no minimum amount;
• insolvency proceedings (bankruptcy) have been opened against it;
• it doesn’t meet the qualification, technical and commercial requirements of the procurement documents;
• it offers an employee of the customer or of another government body a reward, a job or anything else of value in order to influence a decision;
• it engages in anti-competitive conduct or has a conflict of interest in breach of the law, or affiliation is found.

Article 36 also requires the resources to perform the contract, legal capacity, and no unexecuted court decisions in the database of the Bureau of Compulsory Enforcement. The system pulls this data itself from the databases of the Tax Committee, the Ministry of Economy and Finance, the Ministry of Construction and Housing and Communal Services, and the Ministry of Justice (Cabinet of Ministers Resolution No. 276, para. 19), so counting on “nobody will check” won’t work.

A forgotten tax debt of a few thousand soums (UZS) still counts as overdue debt. A day or two before you submit, check your taxpayer account.

Affiliation and conflict of interest in plain terms

An affiliated person is someone who makes or influences decisions in your company (including under a written agreement), and, the other way round, a company whose decisions you influence (ZRU-684, Art. 4). The rule is simple: a participant and its affiliated person may not take part in the same lot — not in the e-shop, an auction, a selection or a tender (ZRU-684, Art. 23).

A real-life example: a founder owns two companies, and both bid on the same lot to “double the chances”. It works the other way round: affiliation, once found, is grounds for disqualification (Art. 42), and concealing it can put you on the register of unscrupulous contractors for two years (Art. 48).

A conflict of interest is a situation where personal interest affects or may affect the proper performance of official duties (Art. 14). A company with a conflict of interest with the customer cannot be a participant (Resolution No. 276, para. 7). You also cannot take part if close relatives of the participant or its representative are the people who choose the supplier on the customer’s side (ZRU-684, Art. 46).

One more obligation: a participant must disclose its principal beneficial owner, the real owner of the company (Art. 23).

Incomplete or incorrectly prepared documents

In selections and tenders, the electronic system checks a bid automatically and rejects it, stating the reason, if (ZRU-684, Arts. 61 and 69; Resolution No. 276, paras. 90 and 145):

• the price is above the starting price;
• mandatory fields are empty;
• mandatory files are not attached.

Whether the files match the information in the bid is checked by the commission’s executive secretary (Resolution No. 276, para. 90). In a tender, the commission rejects a bid if the participant doesn’t meet the requirements of the law, the bid is not properly prepared, or it doesn’t match the documents (ZRU-684, Art. 69). How the stages of selections and tenders work is explained in our guide to etender.

Two more reasons sit in the evaluation rules. The documents may set mandatory criteria and pass marks (minimum scores): a bidder who fails a mandatory criterion or falls below the pass mark is disqualified (Resolution No. 276, paras. 68, 72, 117 and 121). So read the technical specification and the evaluation criteria to the end before you start preparing a bid. If you are going for a lot in construction or equipment, compare the requirements for experience, specialists and machinery with what you have well in advance.

Mistakes we often see in practice:

• Missed deadline. Once bidding closes, the system won’t accept your bid — don’t leave it to the last hour.
• Language. The documents require bids to be prepared in the state language, Uzbek (ZRU-684, Arts. 59 and 67).
• Wrong form. If the documents include a standard form, fill in that one, not your own. A tender is split into a technical part and a price part — put the price only in the price part.
• Expired e-signature. You can take part in electronic procurement only with an electronic digital signature (EDS) (Resolution No. 276, para. 9). Check your key’s expiry date in advance — see our guide to e-signatures and E-imzo.
• Not enough money in your account. The system admits you to a lot only when your account holds enough “advance payment” to cover the commission and the deposit (Resolution No. 276, paras. 11 and 19). In the resolution’s terms, the “advance payment” is your own money in that account, not a prepayment to anyone.

A very low price: the additional deposit and the average-price module

If, in an e-shop price request, your price is 20% or more below the price of the offer the customer selected, you must pay an additional deposit in advance. It equals the difference between the offer amount and your price. It is capped at 100 base calculation values (BCV, the unit Uzbek law uses to set amounts; ≈ 44 million soums) if the offer is up to 2,500 BCV, and at 1,000 BCV (≈ 440 million soums) if it is larger; converted at a BCV of 440,000 soums (since 1 September 2026). Without the additional deposit, the system rejects such a bid automatically (Resolution No. 276, para. 43). The same rule applies in an auction: a price 20% or more below the starting price requires an additional deposit (para. 54).

Example: a hypothetical offer of 50 million soums, and you bid 38 million — 24% lower. On top of the regular deposit, your account needs another 12 million soums, or your price won’t go through. How the deposit is calculated and when it comes back: see our guide to deposits.

In selections and tenders, neither ZRU-684 nor Resolution No. 276 has a separate rule to “reject a bid for being too cheap”. But there are two risks:

• The law prohibits bidding at artificially low prices and then refusing to sign the contract or to perform it properly (ZRU-684, Art. 46). A winner who refuses the contract doesn’t get the deposit back (Arts. 63 and 70) and may be put on the register of unscrupulous contractors (Art. 48).
• Since 1 March 2026, a module on the special information portal has been calculating the average market price of the item being purchased with the help of artificial intelligence (Presidential Decree PF-259, para. 3). If the starting price or the contract price deviates from the average by an amount that, in the decree’s wording, “exceeds 10 per cent or is less than 20 per cent”, the purchase is treated as high-risk and is checked by oversight bodies first (PF-259, para. 4(a)). In practice this is read as “more than 10% above the average or more than 20% below it” — that is an interpretation. The key point: this is a reason to check the customer, not to reject your bid.

Rejection reasons and how to avoid them: a table

TenderMax lot cards show the facts: experience or audited financials required, large bid security, short bid window. Look through tender lots with these flags.

Before you submit: a 10-point checklist

1. Check your taxpayer account for overdue debt; there must also be no unexecuted court decisions and no bankruptcy proceedings.
2. Find out whether a company affiliated with you is bidding on the same lot.
3. Read the notice, the technical specification and the draft contract; write down the requirements and mandatory criteria.
4. If anything is unclear, send the customer an official request: the answer is due within two working days (ZRU-684, Art. 41).
5. Prepare every required file on the list — in the state language and using the customer’s forms.
6. Attach a separate document, the statement on the prevention of corruption: in selections and tenders it is mandatory (ZRU-684, Arts. 59 and 67). Without it, the bid may be found non-compliant with the documents and rejected (Arts. 42 and 69).
7. Check that your price is not above the starting price; in the e-shop, if you go 20% or more lower, calculate the additional deposit.
8. Make sure your account holds enough for the deposit and the operator’s commission.
9. Check that your EDS key is still valid and that E-imzo, the program your browser uses to sign with the key, works.
10. Submit at least a day before the deadline. If you spot a mistake, you can change or withdraw the bid until bidding closes (ZRU-684, Art. 68; Resolution No. 276, para. 86).

Your bid was rejected: what to do next

1. Find out the reason. The disqualification decision and its reasons are entered in the procurement report and must be communicated to the participant immediately (ZRU-684, Art. 42). In a tender, the non-compliance decision reaches your personal account the same day (Resolution No. 276, para. 148), and the protocol (the commission’s official record of the results) states the specific reasons each bid was rejected (paras. 97 and 158).
2. In a selection: file an objection. The selection results protocol is posted for discussion for two working days. Get your objection in within that window: late objections are not considered (ZRU-684, Art. 62).
3. In a tender: request a clarification. After the protocol is published, any participant can ask for an explanation of the results; the customer answers within three working days (Art. 69).
4. Complaint. If you believe your rights have been violated, challenge the actions of the customer, the commission or the operator before the Public Procurement Complaints Commission or in court (Art. 78). Within three working days the Commission notifies the customer and suspends the procurement for up to ten working days in total, and it issues a decision within seven working days (Art. 79). If the complaint is upheld, the Commission can cancel the customer’s unlawful decision in whole or in part.

The law sets no deadline for filing a complaint: the complaint procedure is approved by the Cabinet of Ministers (Art. 78). Check the deadline and the form in that procedure in advance. Don’t delay — a complaint suspends a procurement that is still under way.

FAQ

Why was my bid rejected, and where can I find out the reason?

The reason must be communicated to you immediately (ZRU-684, Art. 42); in selections and tenders it is also stated in the lot protocol.

I own two companies — can both bid in the same tender?

If they are affiliated (one person makes or influences their decisions), not in the same lot (Art. 23).

Where do I complain about being disqualified from a public tender?

To the Public Procurement Complaints Commission or to a court (Art. 78). The Commission issues its decision within seven working days (Art. 79).