LEGAL REGULATION OF VENTURE FUNDS IN UZBEKISTAN: TOWARD A GENDER-SENSITIVE INVESTMENT POLICY

International Law, Business and Political Science Journal ISSN-L 3235-9799 E-ISSN 3235-9799 IF(Impact Factor) 13.24 https://journallaw.totalh.net/ Volume: 11. Issue 12 November 2025 1 LEGAL REGULATION OF VENTURE FUNDS IN UZBEKISTAN: TOWARD A GENDER-SENSITIVE INVESTMENT POLICY Markhabo Nazarova British Management University, Tashkent Email: [email protected] ORCID: 0009-0006-4667-706X Annotation The article examines the legal regulation of venture funds in Uzbekistan in the context of developing a gender-sensitive investment policy. Against the backdrop of rapid institutional reforms in the financial sector and the state’s declared commitment to innovation-driven economic growth, the study investigates how far the national legal framework for venture financing incorporates gender equality objectives. Drawing on a formal, systemic, and teleological legal analysis, the research explores the interplay between investment legislation — notably the Laws “On Investments and Investment Activity” (2019) and “On Investment and Mutual Funds” (2015, as amended 2024) — and gender-equality legislation, including the Law “On Guarantees of Equal Rights and Opportunities for Women and Men” (2019) and related government resolutions. The study identifies structural gaps between economic liberalization and social policy, highlighting the need to integrate gender-lens investing within the emerging venturecapital ecosystem. By aligning venture-finance regulation with national and international commitments to gender equality and sustainable development, the paper offers recommendations for the inclusive evolution of Uzbekistan’s investment framework. Keywords: venture funds, Uzbekistan, investment law, gender equality, gender-lens investing, financial regulation, sustainable development, inclusive growth, innovation policy, legal framework. I. Introduction In view of the swift institutional transformation of the financial market in Uzbekistan and the declared national course for innovative economic development, the question of how far the current legal framework of venture financing integrates objectives related to gender equality becomes especially relevant for both practitioners of law and makers of policy. Within the period from 2020 to 2025, the government adopted a series of acts that shaped the basics of the venture-capital ecosystem, including establishing and further reorganizing the national venture fund UzVC, allowing commercial banks and enterprises with state participation to create venture funds, and creating the National Investment Fund. Alongside this process, a sound International Law, Business and Political Science Journal ISSN-L 3235-9799 E-ISSN 3235-9799 IF(Impact Factor) 13.24 https://journallaw.totalh.net/ Volume: 11. Issue 12 November 2025 2 gender-equality framework has been set up, including the Law on Guarantees of Equal Rights and Opportunities for Women and Men, the obligation for gender-legal expertise of draft legislation, and the National Strategy for Gender Equality until 2030. This is the juncture where investment reform and social policy create a chance for legal analysis of the regulatory interface between venture-capital law and gender equality, aiming at the elaboration of mechanisms to include gender-lens investing into the emerging venture ecosystem of Uzbekistan. II. Methodology The given research relies exclusively on official and primary legal sources, ensuring the reliability and verifiability of its findings. The analysis is based on the Law “On Investments and Investment Activity” (adopted 14 December 2019, No. 598) [1], the Law “On Investment and Mutual Funds” No. 392 (25 August 2015, as amended 16 January 2024) [2], as well as Presidential Decrees and Cabinet resolutions establishing the National Venture Fund UzVC and the National Investment Fund (NIF). Further support for the research was found in the Law “On Guarantees of Equal Rights and Opportunities for Women and Men” (No.562, 2019) and the Resolution of the Cabinet of Ministers No. 192 (2020) on obligatory gender-legal expertise. All statistical and factual data are taken from official publications of the Ministry of Economy and Finance of the Republic of Uzbekistan (July 2025) [3] and serve as an authoritative empirical basis in providing the legal assessment. Methodologically, the article applies a tri-level doctrinal and interpretive framework. Formal-legal approach: This approach is used to interpret the hierarchical interaction of legal norms regulating investment and gender policy. It makes possible the precise differentiation between lex generalis-the Law on Investments-and lex specialis-the Law on Investment and Mutual Funds-and at what point subsidiary regulations, presidential decrees, and ministerial acts may or may not be accommodated within the legal hierarchy of Uzbekistan. Systemic approach: The study applies systemic reasoning to connect investment regulation with equality legislation, placing venture-fund governance within the greater normative framework of social policy. This approach identifies, through the analysis of horizontal coherence between investment, financial, and gender norms, the structural disjunction between Uzbekistan's economic-liberal model and its gender-equality commitments. Teleological interpretation: A purposive or goal-oriented interpretation is one that aligns the intent of the legislature to constitutional objectives relating to sustainable and inclusive development, largely as expressed in Sustainable Development s 5 (Gender Equality) and 8 (Decent Work and Economic Growth)[4]. This interpretive prism emphasizes how statutory neutrality towards gender concerns is at odds with nationaldevelopment strategies and international obligations of Uzbekistan. Complementarily, the research design will be of an analytical-descriptive type, International Law, Business and Political Science Journal ISSN-L 3235-9799 E-ISSN 3235-9799 IF(Impact Factor) 13.24 https://journallaw.totalh.net/ Volume: 11. Issue 12 November 2025 3 where the evolving venture-capital regulation of Uzbekistan will be put in a comparative perspective with selected international models-only for the purpose of explanatory context and without importing any normative standards from abroad (EU, OECD, and regional post-transition jurisdictions). By integrating these three methods-formal, systemic, and teleological-the paper ensures doctrinal precision as well as policy relevance for a nuanced assessment of how the country's legal framework for venture funds can be reconciled with its international commitments to gender equality. III. Results 1. Core Investment Regulation The Law “On Investments and Investment Activity” (adopted on 14 December 2019) provides the general guarantees of investors and regulates the general regime of investment activity for both domestic and foreign participants. It establishes the basic guarantees of investors, such as protection against illegal expropriation, assurance of nondiscrimination, and the right to free repatriation of profits. It enshrines the principles of investment freedom and equality of investors regardless of the ownership form or nationality, thereby approximating Uzbekistan's regulatory approach to international standards of investment protection. Importantly, it also consolidates previously fragmented norms into a single, coherent framework consistent with the strategic course taken by the government toward liberalization and attraction of private capital. While the Law “On Investment and Mutual Funds” No.392 (August 25, 2015, last amended January 16, 2024) sets forth the legal status, organizational structure, and operational principles of investment and mutual funds. It represents the lex specialis for collective investment mechanisms, providing a legal basis for establishing venture funds as a particular category of investment vehicles. The changes introduced in 2024 concerned new provisions on fund management, transparency, and risk diversification; these allowed the institutionalization of venture financing as an alternative form of investment within the capital market of Uzbekistan. 2. Establishment of Venture Infrastructure The Resolution of the Cabinet of Ministers No. 684 (3 November 2020) [5] systematized the activities of the national venture fund UzVC and provided for its charter capital of 15 billion UZS from the state budget through the Ministry of Innovative Development. Management was entrusted via competitive trust management. Presidential Decree No. 303 [6] of 27 August 2024 issued instructions on the creation of the National Investment Fund as a systemic investor in support of privatization and market reforms. On 14 October 2024, UzVC was transformed into a “fund of funds” under the Ministry of Economy and Finance. Commercial banks and enterprises with more than 50 % state participation were endowed with the right to create venture funds, carry out venture investments, and to place resources under trust-management agreements. In addition, a separate venture fund was created within IT Park with a International Law, Business and Political Science Journal ISSN-L 3235-9799 E-ISSN 3235-9799 IF(Impact Factor) 13.24 https://journallaw.totalh.net/ Volume: 11. Issue 12 November 2025 4 budget of USD 10 million, while financing mechanisms were established through the Reconstruction and Development Fund. 3. Official Market Data (First Half of 2025) According to the official press release of the Ministry of Economy and Finance of the Republic of Uzbekistan (18 July 2025)[7], the national venture-capital ecosystem demonstrates a steady process of institutional consolidation. By mid-2025, Uzbekistan had established 11 active participants in the venture-investment market: one fund-offunds (the National Venture Fund UzVC), and ten venture funds, namely Aloqa Ventures, IT Park Ventures, United Ventures, SQB Ventures, Asaka Ventures, Yoshlar Ventures, UC Ventures, Semurgʿ Ventures, Sarmo Ventures, and Imkon Ventures. The aggregate volume of venture investments reached approximately USD 145 million, reflecting both the government’s financial commitment and an emerging diversification of private-sector participation. Of these organizations, four funds (UC Ventures, Semurgʿ, Sarmo, and Imkon) operate exclusively with private capital, while the others receive full or partial public co-financing through UzVC or affiliated state mechanisms. This institutional balance between public and private capital presupposes a transitional phase, in which state participation continues to support market development, providing liquidity and risk absorption until the private ecosystem reaches full maturity. From a regulatory perspective, this hybrid structure is both beneficial and limiting. On the one hand, state support guarantees market stability and reduces systemic risk for early-stage investors; on the other hand, excessive state intervention may inadvertently delay the emergence of competitive private capital flows. Moreover, the prevalence of statebacked structures raises the regulatory question of whether such funds, financed by public resources, should be subject to enhanced transparency and social accountability requirements, including gender-sensitive reporting. 4. Legal Obligations for Gender Equality The Law of the Republic of Uzbekistan No. 562, dated 2 September 2019, “On Guarantees of Equal Rights and Opportunities for Women and Men,” codifies equal rights and obliges state institutions to actively promote gender equality. Resolution of the Cabinet of Ministers No. 192 [8], dated 30 March 2020, introduces the requirement of compulsory gender-legal expertise for all draft normative acts, irrespective of sectoral affiliation. Finally, the National Strategy for Achieving Gender Equality until 2030 consolidates the state's long-term commitment to inclusivity and institutional gender mainstreaming. IV. Legal Analysis: Gaps and Directions for Harmonization A. Venture-Fund Structure vs. Gender Objectives Although the Law on Investment and Mutual Funds (No. 392, 2015, amended 2024) and the Law on Investments and Investment Activity (No.598, 2019) together define a liberal and investor-friendly regime, none of these acts contain explicit provisions addressing gender equality, diversity of management, or the inclusion of International Law, Business and Political Science Journal ISSN-L 3235-9799 E-ISSN 3235-9799 IF(Impact Factor) 13.24 https://journallaw.totalh.net/ Volume: 11. Issue 12 November 2025 5 women entrepreneurs in venture-financing processes. Likewise, neither Resolution No. 684 (2020) establishing the UzVC nor Presidential Decree No. 303 (2024) creating the National Investment Fund (NIF) incorporates gender-specific mandates. The legal architecture of venture-capital regulation in Uzbekistan is, therefore, economically progressive but socially neutral. It aims to stimulate innovation and attract private capital through financial mechanisms, yet it omits the normative elements that would ensure equality of opportunity and diversity in participation. Unlike certain EU jurisdictions or the OECD framework on gender-responsive investment[10], Uzbekistan’s system treats investment as an ideologically neutral market tool, rather than a vector for inclusive growth. This design produces what can be termed a “vertical disjunction” between the upper layer of policy (gender equality as a national and constitutional commitment under the Law No. 562 and the Strategy 2030) [9] and the operational layer of investment law (venture governance). Gender equality thus functions “above” the investment system through overarching legal norms and expert review but not “within” it as a built-in regulatory parameter. The absence of integration reduces the internal coherence of Uzbekistan’s sustainable-development policy and may inadvertently reinforce structural barriers for women-led enterprises [10]. A critical interpretation suggests that this omission is not a legislative gap in the technical sense, but a normative silence reflecting the early stage of venture-market development. However, as the ecosystem matures, this silence becomes legally consequential: without gender-sensitive clauses in fund-governance rules, there is no statutory basis for monitoring or enforcing equitable access. The evolution toward a more inclusive model thus requires not the replacement of existing laws but their interpretive expansion and supplementation through subordinate regulations. B. Mandatory Gender Expertise as Procedural Bridge Whereas the Resolution of the Cabinet of Ministers No. 192 (30 March 2020) provided for the introduction of a system of compulsory gender-legal expertise, assuming that every draft normative legal act shall be analyzed for its compliance with the principles of equality. Within the context of venture financing, this system is an institutional bridge capable of converting gender policy into regulation with sectoral coverage. In other words, in the case of adopting new internal statutes of UzVC or NIF relating, for example, to the selection of managing companies, co-investment procedure, or to the form and content of a trust-management agreement, this form of legal review will be required. If applied substantively and not just formally, gender expertise might ensure that selection criteria for fund managers and portfolio investments lack indirect discrimination and guarantee equal access of male and female entrepreneurs to financial resources. At the same time, in practice, such expertise often has a merely procedural and declaratory character: compliance reports are issued without quantifiable metrics and follow-up commitments. Meanwhile, a comparative administrative law analysis sets the following three stages as effectively required for gender-mainstreaming: (1) ex-ante International Law, Business and Political Science Journal ISSN-L 3235-9799 E-ISSN 3235-9799 IF(Impact Factor) 13.24 https://journallaw.totalh.net/ Volume: 11. Issue 12 November 2025 6 assessment; (2) monitoring of implementation; and (3) ex-post evaluation. Currently, Uzbekistan's regulatory framework reaches only the first stage, leaving the latter two unregulated. The enhancement of this continuum would transform gender expertise from formal review into a substantive governance tool [12]. C. Public Funds and Transparency Obligations Despite elaborate provisions on governance and investment procedures, the present acts contain no uniform disclosure requirements pertaining to access from a gender perspective: there are no indications on what share of women-led start-ups are funded, the gender composition of investment committees, or diversity in fund governance. Gender accountability, therefore, remains a question of soft law, dependent on voluntary disclosure rather than regulatory compulsion. D. The Role of the National Investment Fund Although the National Investment Fund was established with an explicit mandate to channel capital in ways that could support privatization and institutional projects, its competence regarding the regulation of mechanisms for co-investment means that it bears a unique potential to function as a champion of gender-sensitive standards. As a leading state investor, the NIF is in a position to include ESG criteria and gender aspects in partnership and co-financing agreements [11]. The introduction of such provisions will not need legislation but rather be done through ministerial orders or model agreements elaborated under Presidential Decree No. 303; thus, aligning NIF activities with Uzbekistan’s obligations under Law No. 562 and the Gender Equality Strategy until 2030 with economic goals, on the one hand, and with social aims, on the other. Furthermore, by granting access to state co-investments based on complying with gender standards, the NIF could indirectly incentivize private venture funds to take parallel internal policies, thereby pushing down gender mainstreaming in the capital market. Such an approach in itself is in line with the emerging international principle of “conditional public funding,” with a broader dimension of linking the availability of state or quasi-state financial support with social impact. Inclusion of such conditionality within the framework of the National Investment Fund (NIF) would place Uzbekistan among progressive jurisdictions which see equality not as a mere political slogan but also as a criterion of action. E. Risks and Implementation Challenges A critical analysis of the current system exposes the following systemic vulnerabilities: a) Fragmented regulations: investment funds, co-investment agreements, and innovation support are governed by multiple regulations, but none of them outline one consolidated set of gender or ESG indicators. Such a nature of regulation inherently possesses the risk of inconsistency and less effectiveness in monitoring. International Law, Business and Political Science Journal ISSN-L 3235-9799 E-ISSN 3235-9799 IF(Impact Factor) 13.24 https://journallaw.totalh.net/ Volume: 11. Issue 12 November 2025 7 b) Formalism in gender assessment: at present, Resolution No. 192 seems to show a preference to procedural compliance rather than substantive assessment, with nominal rather than a transformative effect. c) Regulatory asymmetry: publicly funded funds may face stricter reporting requirements compared to purely private ones, leading to unequal enforcement and possible market distortion. d) Data deficit: Lack of collection of systematic gender-disaggregated data regarding venture capital projects remains a major obstacle to evidence-informed policymaking and the measurement of equality outcomes. e) Institutional inertia: Implementation remains fragmented and slow without interagency coordination between the Ministry of Economy and Finance, the Agency for Gender Equality, and the Central Bank; In other words, even though the legislative framework of venture capital investment is financially strong in Uzbekistan, it is not developed socially. The way forward rests on changing procedural mechanisms such as gender impact assessments and disclosure requirements into key regulatory instruments that make innovation policy consistent with the constitutional and strategic imperative of gender equality. V. Argument and Proposals Promoting gender-sensitive investment policy in the venture-fund framework of Uzbekistan is possible without significant legislative reform, through strategic use of subordinate regulation in conjunction with conditions on recipients of public funding. The following measures are proposed: 1. Introduce gender performance KPIs in UzVC and other publicly supported venture funds, with minimum disclosure requirements on the share of women-led applications, approved deals, and gender composition of investment committees. Such requirements can be based on No. 562, related to equal opportunities, and Resolution 192, regarding obligatory expertise. 2. Include gender-lens investing criteria in co-financing and trust-management agreements. Public funds must allocate resources preferentially to venture funds that maintain measurable gender-impact performance and publish annual inclusion reports. 3. Adopt a standard reporting template through a joint order of the Ministry of Economy and Finance and the Central Bank, which would oblige venture funds that receive public support to annually disclose their investment data by gender. 4. Align venture-fund regulations with the Gender Equality Strategy 2030 by inserting express mentions of the objectives in preambles and explanatory notes of normative acts, therefore, strengthening coherence between investment regulation and social-policy objectives. 5. This means providing substantive gender-legal expertise on new and changed International Law, Business and Political Science Journal ISSN-L 3235-9799 E-ISSN 3235-9799 IF(Impact Factor) 13.24 https://journallaw.totalh.net/ Volume: 11. Issue 12 November 2025 8 venture-investment rules, and making findings and corrective measures public (“duty to explain”). VI. Conclusion The reforms of 2020-2025 have set up Uzbekistan's basic framework for venture capital: comprehensive investment legislation, institutionalization of UzVC as a fund of funds, creation of the National Investment Fund, and emergence of a diversified market comprising 11 funds with total venture investments of approximately USD 145 million. Despite these developments, however, the sector-specific investment regulations are still devoid of gender-sensitive mechanisms. Currently, the gender-equality mandate can be considered to work only through the general course of law, specifically No.562, supplemented by the mandatory expertise system, Resolution 192. Therefore, it is both legal and workable to incorporate gender-lens investing principles through subordinate legislation, like regulations, contractual requirements, and transparency standards, without extensive statutory changes. This will allow Uzbekistan to align its fast-growing venture-capital market with its constitutional and strategic commitments toward gender equality and further the twin objectives of economic innovation and social justice. References 1. Law of the Republic of Uzbekistan “On Investments and Investment Activity.”, No. 598, adopted 14 December 2019. Available at: https://lex.uz/docs/4674879 2. The Law of the Republic of Uzbekistan “On Investment and Mutual Funds,” No. 392, adopted 25 August 2015 (as amended 16 January 2024). Available at: https://lex.uz/docs/2757331 3. The Law of the Republic of Uzbekistan “On Guarantees of Equal Rights and Opportunities for Women and Men”, No. 562, adopted on 2 September 2019. Available at: https://lex.uz/docs/4485970 4. Sustainable Development Goals: SDG 5 and SDG 8. United Nations Sustainable Development Agenda 2030. Available at: https://sdgs.un.org/goals 5. Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 684, “On Measures for the Organization of Activities of the National Venture Fund "UzVC."”, Adopted 3 November 2020. Available at: https://lex.uz/docs/5088348 6. Presidential Decree of the Republic of Uzbekistan No. 303, “On Establishment of the National Investment Fund of the Republic of Uzbekistan.”, Adopted 27 August 2024. Available at: https://lex.uz/docs/6790563 7. Ministry of Economy and Finance of the Republic of Uzbekistan. Press Statement on the Development of Venture Capital Ecosystem 18 July 2025, Official website: https://mef.uz 8. Resolution of the Cabinet of Ministers of the Republic of Uzbekistan No. 192, “On the Procedure for Conducting Gender-Legal Expertise of Normative Legal Acts and Their Drafts.”, Adopted 30 March 2020. Available at: https://lex.uz/docs/4780213 9. National Strategy for Gender Equality until 2030. Approved by the Cabinet of International Law, Business and Political Science Journal ISSN-L 3235-9799 E-ISSN 3235-9799 IF(Impact Factor) 13.24 https://journallaw.totalh.net/ Volume: 11. Issue 12 November 2025 9 Ministers of the Republic of Uzbekistan, 2021. Official Gazette of the Republic of Uzbekistan. Available at: https://www.gov.uz 10. Ачилова, Л. (2024). Конституционные реформы Нового Узбекистана в улучшении гарантий права собственности в туристической деятельности. Общество и инновации, 5(1), 89-95. 11. OECD, 2023. Gender-Sensitive Investment and Sustainable Finance: Policy Toolkit for Emerging Economies. Paris: Organisation for Economic Co-operation and Development. Available at: https://www.oecd.org 12. Achilova, L. (2023). Gender and anti-corruption strategy: legal aspects and challenges in the fight against corruption. Science and innovation, 2(C8), 30-35.