An HR and hiring system in Uzbekistan: what does an organisation need?

Avada · Checked: 26.10.2026

Short answer. Employment contracts and electronic labour books are kept in the state's Single National Labour System. The employer must register each contract there on time, through my.mehnat.uz. The data of a paper contract are entered within five working days of the day it is made. The organisation does the rest itself too: it publishes vacancies, takes applications, holds interviews and competitions, asks only for the documents the law provides for and issues the hiring order. If the employer is a state body or a state organisation, it obtains the passport and labour-book data itself from the state bodies and organisations concerned (Labour Code, art. 124). For other employers, the applicant presents these documents. Our reading: obtaining the applicant's consent and deleting data no longer needed are the organisation's job as well. Since 27.03.2026, an applicant base with no biometric or genetic data may be kept abroad too, once one of three conditions is met (see below; our reading).

What happens in the state system, and what the organisation does

In the state system (the employer does this):

• registers the employment contract, changes and additions to it, and its ending, on time, through my.mehnat.uz (Labour Code, arts 25 and 109);
• if the contract is made electronically, makes it out in the system itself (art. 106).

The electronic labour book is then formed in the system automatically, when a contract is made, registered, changed or ended (art. 125).

Inside the organisation, the employer:

• publishes vacancies and takes applications;
• briefs the applicant on the job, the working conditions and the internal documents, and holds interviews and competitions (art. 123);
• asks only for the documents the Labour Code and other legislation provide for (art. 124);
• issues the hiring order and announces it to the employee against signature (art. 127);
• obtains the applicant's consent, keeps their data and destroys it.

Note: the state system is a register, not a hiring tool. Do not duplicate in your own system what the state system already holds; let your own system take the applicant from application to order (our reading).

Hiring, step by step

The Code gives the stages of hiring an article of their own (art. 122). Below are the steps in the order they follow in practice, each with its article where there is one.

1. Vacancy and application. The application form collects personal data, so consent to processing it is obtained at this step (see below).
2. Briefing, interview and competition. Before the contract is signed, the employer must acquaint the applicant with the content of the job, the working conditions, the internal labour rules, the collective agreement and other internal documents directly tied to their work. The employer may hold interviews with people applying for work. If a competition is held, the employer notifies the applicant of its date at least a week ahead. The employer may provide for a competitive hiring procedure: under a regulation or, where selection by competition and its procedure are set by legislation, under that legislation (art. 123). A competition for a teaching post at a university or college is held at this step (our reading); settle with a lawyer whether its procedure comes, in your case, from a regulation or from legislation. Art. 123 itself does not make a competition compulsory, so for posts where no other legislation requires one, an interview alone may be enough (our reading).
3. Documents. The employer asks for those of the five listed in art. 124 that apply to the applicant, and those that other articles of the Labour Code or other legislation provide for that hiring; asking for any other is prohibited (art. 124; see below).
4. Employment contract. Made in writing, on paper or electronically, in at least two copies of equal force; an electronic contract is made out in the Single National Labour System (art. 106).
5. Order. Hiring is made out by the employer's order, based on the employment contract signed with the employee. The order is announced to the employee against signature within three days of the day work actually starts (art. 127).
6. Registration. The making and ending of the contract, and changes and additions to it, must be registered in the system (art. 109); the employer must do this on time (art. 25). An electronic contract is made in the system itself; the data of a paper contract are entered in the system within five working days of the day it is made (Regulation approved by Cabinet of Ministers resolution No. 971, paras 24¹ and 25).

Which documents you may ask for, and which you may not

A person joining presents these documents (art. 124):

• a passport, a document that replaces it, or an identifying ID card (under-16s: a birth certificate or an ID card);
• a paper labour book certified at the last place of work, or an extract from the electronic labour book (not for first-time workers; part-time workers bring a certificate from their main job);
• a military card or a registration certificate, for those liable to serve or conscripts;
• for work that only people with special education or special training may be admitted to: a diploma from a higher, specialised secondary or vocational institution, a certificate of the right to do that work, or another relevant document;
• the personal identification number (PINFL).

If the employer is a state body or a state organisation, it obtains the passport and labour-book data itself from the state bodies and organisations concerned, including through inter-agency platforms in information systems (art. 124). For other employers, the applicant presents these documents. Asking for documents that the Labour Code and other legislation do not provide for is prohibited (art. 124). So beyond the five, you may ask only for what other articles of the Labour Code or other legislation provide for that hiring. For teaching posts, for example, other legislation may require more documents: check which act requires them (our reading).

In practice: for every required field on your application form, ask which provision of the Labour Code or other legislation requires it. If there is none, make the field optional or drop it. Reference letters or a statement of pay from the last job usually fail this test (our reading).

Applicants' data: consent, keeping, deletion

The Law «On Personal Data» (ZRU-547) answers three questions:

• Consent. The applicant (the data subject) may give consent in any form, as long as it can later be confirmed that consent was obtained (art. 21). Special personal data (health or criminal-record data, for example, art. 25) need consent in writing, which may be an electronic document. Let the application form keep the consent mark and the time it was given.
• How long. The data are kept until the purpose of collecting and processing them is achieved (art. 10).
• Deletion. The data are destroyed when the purpose of processing is achieved, when consent is withdrawn or the period it set ends, and when a court decision takes effect (art. 17). A rejected applicant's data were collected for the decision on that vacancy; once the decision is made, that purpose is achieved. But if a rejected applicant asks, the employer must give the written reasons for the refusal within three days (Labour Code, art. 119), and in a dispute the employer must prove the refusal was lawful (art. 120). So settle with a lawyer how long to keep the refusal record (who, which vacancy, when, on what grounds); destroy the rest. Keeping their data for later vacancies needs separate consent (our reading).

Where the data may be kept: the 2026 change

Article 27¹ of the Law «On Personal Data» now reads as worded by Law ZRU-1125 of 26.03.2026 (in force from the day of its official publication; lex.uz gives 27.03.2026). Under it, the following must be kept in the Republic of Uzbekistan:

• individuals' biometric data;
• individuals' genetic data;
• the data, held by telecom operators working in Uzbekistan, of the individuals who use their services.

Our reading: the third item concerns data that telecom companies keep on the users of their services (the official Uzbek text says «operatorlaridagi», «at the operators»). The phone number an applicant writes on a form is not covered.

If one of the three conditions below is met, other personal data may be kept and processed outside Uzbekistan too. In these conditions, the «operator» is not a telecom company but whoever processes the data; here, first of all the employer itself:

• the country is recognised as giving adequate protection (the Cabinet of Ministers sets the list of such countries: resolution No. 415 of 29.07.2026, in force 03.08.2026);
• the operator has adopted and follows standard contractual clauses or binding corporate rules that meet the authorised state body's requirements;
• the operator follows international standards from a list that the authorised state body approves.

The transfer abroad itself falls under art. 15 (cross-border transfer): to a country without adequate protection it is allowed, among other grounds, with the applicant's (the data subject's) consent.

Our reading: so, transfer abroad and keeping abroad are two different questions. The applicant's consent can be a ground for transferring the data abroad (art. 15). But keeping and processing them abroad still needs one of the three conditions above: consent does not replace them, and art. 27¹ makes no exception for consent. If the base holds no biometric or genetic data, an applicant database of CVs and contacts may now, once one of the three conditions is met, be kept abroad too (a cloud service or online spreadsheet included). The third item (telecom) does not reach an applicant base (see above). The claim, still found in publications from before 2026, that «all citizens' data must stay in Uzbekistan» is out of date.

In practice (an online form, a spreadsheet or a cloud hiring system):

• First check whether the country where the data are kept or processed (for a cloud service, each of them) is on the list in resolution No. 415 (lex.uz/docs/8371371; the act's text is in Uzbek). That is the first condition; you can check it yourself.
• If the country is not on the list, settle with a lawyer whether you meet one of the other two conditions and what ground the transfer rests on under art. 15 (the applicant's consent, for example). Until then, keep the base in Uzbekistan.
• If you already use a foreign cloud hiring service, ask the vendor in writing: in which countries the data are kept and where they are processed; which standard contractual clauses or binding corporate rules it has adopted and which international standards it follows (the second and third conditions above). Show the answer and the contract to a lawyer.
• A vendor that processes the data on its own servers may be an operator too; if it is instead a third party you have entrusted the processing to, that needs a ground of its own (art. 31; the applicant's written consent, which may be electronic, for example); a lawyer settles who must meet the second or third condition (our reading).
• Whether a passport copy, a photo and a video-interview recording count as biometric data is also one to settle with a lawyer. Until you have the answer, keep them in Uzbekistan.

More: Personal data: the law.

What an HR system should do

1. A vacancy site and application form that are easy to use on a phone, in Uzbek and Russian (and in Karakalpak where needed).
2. One applicant base: stages per vacancy, a reason required for every rejection.
3. Briefing, interviews and competitions: a record of which internal documents the applicant was shown; date, panel, scorecard; notice of a competition at least a week ahead (art. 123).
4. A document list: those of the five in art. 124 that apply to the applicant, plus those that other articles of the Labour Code or other legislation provide for that hiring; each extra document shows the act that requires it. For a state body or a state organisation, the list shows that the employer obtains the passport and labour-book data itself (art. 124; see above).
5. Applicants see their status without an account, by the application number and a code sent to their phone.
6. Consent and time limits: the time consent was given is kept; once an applicant is rejected, without waiting for the vacancy to close, their data are destroyed or separate consent is asked; the refusal record is kept apart for as long as a lawyer sets (see above: a rejected applicant's data).
7. The step to the order: a draft order based on the contract. The system reminds of two time limits: announce the order within three days of the day work starts, and enter a paper contract in the system within five working days.
8. Who sees what: role-based access and a history of changes (who, what, when); reports by applicant source, stage and department.
9. Where data sit: by default the base sits on servers in Uzbekistan; it moves to a server abroad only once one of the three conditions of art. 27¹ is met; passport copies, photos and video-interview recordings stay in Uzbekistan.

What it does not do: registering the contract and the electronic labour book stay in the Single National Labour System. Payroll, timesheets and leave are another system's job. A lawyer still reviews the contract and the organisation's internal documents.

Example: Avada's HR module

On avada.uz, the Zarmed University case page lists the module «Staff and hiring» as «live». The module does not register the contract through my.mehnat.uz; the organisation does that itself.

Questions and answers

Which documents are required when hiring? Those of the five in art. 124 of the Labour Code that apply to the applicant, and those that other articles of the Code or other legislation provide for that hiring. The five: a passport or ID card; a labour book or an extract from the electronic labour book (except for first-time workers); military papers, for those liable to serve and conscripts; for work that needs special education or training, a diploma, a certificate of the right to do it or another relevant document; the personal identification number (PINFL). A state body or a state organisation obtains the passport and labour-book data itself (art. 124). Asking for documents that the Labour Code and other legislation do not provide for is prohibited.

Where and when must the employment contract be registered? In the Single National Labour System (Labour Code, art. 109), through my.mehnat.uz; the employer must do it on time (art. 25). An electronic contract is made in the system itself; the data of a paper contract are entered within five working days of the day it is made (Regulation approved by resolution No. 971, paras 24¹ and 25).

How long may a rejected applicant's data be kept? Until the purpose of collecting and processing it is achieved (ZRU-547, art. 10); then the data are destroyed (art. 17). Keep the refusal record, though: the applicant may ask for the written reasons or challenge the refusal; settle the period with a lawyer (Labour Code, arts 119 and 120). To keep them for later vacancies, get the applicant's separate consent (our reading).

May the applicant database sit on a server abroad? It may, on two conditions:

• the base holds no biometric or genetic data and no data held by telecom companies (art. 27¹ of the Law «On Personal Data» requires these to be kept in Uzbekistan; on our reading, the phone number on an application is not among them);
• at least one of the three conditions of art. 27¹ is met. The first of them (whether every country where the data are kept or processed is on the list in resolution No. 415) you can check yourself.

The applicant's consent can be a ground for the transfer abroad (art. 15), but for keeping the data abroad it does not replace these conditions (our reading). Until it is settled whether passport copies, photos and video-interview recordings count as biometric data, keep them in Uzbekistan. More, and what to check with a lawyer, in «Where the data may be kept» above.

If a competition is held (for a university or college teaching post, say), what should the system do? Record that the applicant was told the competition date at least a week ahead (Labour Code, art. 123), the panel's scores and each applicant's status.

One step: open the HR module demo (in Russian; the demo has Uzbek and Russian only): a vacancy site, an application and a recruiter board.

This page is general information, not legal advice. Have a lawyer review your application form and internal HR documents.

Sources (lex.uz; Checked: 26.10.2026):

• Labour Code (adopted 28.10.2022, in force 30.04.2023): arts 25, 106, 109, 119, 120, 122, 123, 124, 125, 127 — lex.uz/docs/6257288
• Regulation approved by Cabinet of Ministers resolution No. 971 of 05.12.2019 (Single National Labour System): paras 24¹ and 25 — lex.uz/docs/4630020
• Law «On Personal Data» (ZRU-547 of 02.07.2019; art. 27¹ as worded by ZRU-1125 of 26.03.2026): arts 10, 15, 17, 21, 25, 27¹, 31 — lex.uz/docs/4396419
• Law ZRU-1125 of 26.03.2026 (the new wording of art. 27¹) — lex.uz/docs/8099215
• Cabinet of Ministers resolution No. 415 of 29.07.2026 (the list of foreign countries giving adequate protection of personal data; on lex.uz the act's text is in Uzbek) — lex.uz/docs/8371371