ELECTRONIC COMMERCE REGULATION IN UZBEKISTAN: A COMPARATIVE ANALYSIS OF LAW NO. 792 (2022) AND THE UNITED STATES FEDERAL FRAMEWORK

Abstract

The rapid expansion of digital commerce has necessitated the development of comprehensive legal frameworks capable of governing electronic transactions, protecting consumer rights, and ensuring the integrity of online commercial relationships. This article examines the legal architecture of electronic commerce regulation in the Republic of Uzbekistan, with particular focus on Law No. 792 "On E-Commerce" adopted on September 29, 2022, which represents the most significant legislative reform of Uzbekistan's digital commerce framework since the original 2004 enactment. Through comparative analysis with the primary federal legal instruments governing electronic commerce in the United States — including the Electronic Signatures in Global and National Commerce Act (E-SIGN Act, 2000), the Uniform Electronic Transactions Act (UETA, 1999), the Uniform Commercial Code (UCC), and the Federal Trade Commission Act — this article identifies substantive convergences and divergences between the two legal systems in the areas of electronic contract formation, digital signature validity, consumer protection, payment regulation, escrow mechanisms, and platform operator liability. The analysis demonstrates that while both jurisdictions share foundational commitments to the legal equivalence of electronic and paper-based transactions, the Uzbek framework adopts a more codified, state-centric approach with explicit statutory protections — including mandatory escrow services and statutory refund penalties — that contrast significantly with the more fragmented, market-driven regulatory architecture of the United States. The article concludes with observations on the implications of Uzbekistan's 2022 reform for regional legal harmonization and the country's ongoing integration into international trade and WTO frameworks.