How insurers in Uzbekistan must cover their reserves
Finmind editorial team · · 8 min read
The rules behind an Uzbek insurer's investment book: allocated assets, the 70% cover list, per-bank and equity limits, cash buffers and the board's policy.
An insurer collects premiums today and pays claims later. Between the two, the money sits in its investment book, and the law decides a good deal of what that book may hold. In Uzbekistan three regulations do most of the work: one on insurance reserves, one on solvency and one on investment activity. All three were issued by the Ministry of Finance between 2008 and 2009 and are still in force, amended many times since, with the National Agency of Perspective Projects (NAPP) now named as the supervisor.
All texts were read on lex.uz on 28 September 2026. This is a summary of the rules as published, not legal advice.
The legal frame
The Law "On insurance activity" (ZRU-730 of 23 November 2021) says insurers form and place insurance reserves from premiums received, in national or foreign currency, under conditions set by the authorised state body (article 49). It adds that the assets matching an insurer's reserves may not be seized. The detail sits in three regulations:
- No. 1882 of 15 December 2008, on insurers' insurance reserves: how reserves are calculated and which assets may cover them;
- No. 1806 of 12 May 2008, on the solvency of insurers and reinsurers: the solvency margin and limits on how all of an insurer's assets are placed;
- No. 1982 of 16 July 2009, on insurers' investment activity: governance, the investment policy and the responsible person.
The numbers are registration numbers at the Ministry of Justice. Regulation 1882 was last amended by a NAPP order of 13 March 2026, and regulation 1806 by a NAPP order of 28 May 2025.
Allocated assets: a book inside the book
Regulation 1882 requires an insurer to set aside assets equal to its insurance reserves, identified clearly in its accounting records at the moment they are allocated (point 33). Their total value, measured at book value, must be at least the total of the reserves. The allocated assets must meet four tests: diversification, recoverability, profitability and liquidity (point 34).
Three further rules shape the allocated book:
- the assets may be used only for the purpose of the reserves they cover, and may not be pledged (point 35);
- reserves in a foreign currency are covered in that currency or in a freely convertible one (point 36);
- after the insurer's management checks the book on each reporting date, the allocated assets must be brought back within a band of 100% to 105% of reserves: topped up if short, and the excess moved out if above 105% (points 39 to 41).
Some assets can never count as cover (point 37), including loans to founders, shareholders and employees, receivables from related parties, premiums unpaid for more than three months, tax receivables, amounts under guarantees and assets already encumbered.
The 70% cover list
At least 70% of the allocated assets must consist of some or all of the following (point 38):
- government securities of the Republic of Uzbekistan;
- bank deposits;
- cash in the till and on settlement, currency and other bank accounts;
- government securities of foreign states, with the agreement of the Agency;
- securities admitted to issue and circulation in Uzbekistan, or foreign issuers' securities admitted to circulation, as the regulation defines.
The remaining 30% may be other eligible assets, subject to the exclusions above and to the solvency limits below. For an insurer this makes the core of the reserve book a portfolio of deposits and government bonds, which is why the rates in bank deposits vs bonds in Uzbekistan and the auctions described in government securities in Uzbekistan matter so much to insurers.
Limits on all of an insurer's assets
Regulation 1806 sets placement limits that apply to the insurer's assets as a whole, not only the reserve book (points 17 to 31):
- one bank: deposits in a single commercial bank at most 40% of the insurer's assets;
- other credit organisations: deposits with credit organisations other than commercial banks at most 10% of assets in total;
- one property: at most 50% of assets in one plot of land or other real estate object;
- one company: at most 30% of the insurer's assets in the charter capital of, or other participation in, one legal entity, and a stake of at most 30% of that entity's charter capital, with exceptions for certain subsidiaries;
- all equity stakes: at most 50% of the insurer's own funds in the charter capital of other entities, except stakes in commercial banks with a positive international audit opinion for the previous year;
- loans: loans to founders, shareholders, leasing companies, employees and life policyholders together at most 10% of the insurer's charter capital;
- related parties: at most 15% of charter capital with one related party and 100% with all of them, only with approval of the supervisory board, and none at all in the insurer's first two years;
- cash buffer: cash in the till and bank accounts of at least 3% of insurance claims accrued over the previous twelve months.
The bases differ: total assets, own funds or charter capital. Each limit needs its own denominator.
A worked example
Take an illustrative insurer with total assets of 200 billion som and insurance reserves of 80 billion som.
- Allocated assets must be between 80 and 84 billion som (100% to 105% of reserves).
- At least 56 billion of that (70% of 80 billion) must sit in the cover list: government securities, deposits, cash and admitted securities.
- No single commercial bank may hold more than 80 billion som of its deposits (40% of 200 billion). A board may set a tighter bank limit in its own investment policy.
These figures are invented to show the arithmetic and describe no real company.
Solvency and reporting
Regulation 1806 also sets a solvency margin adequacy ratio: the actual margin divided by the required margin must be at least one (point 6). If it falls below 0.5 at the end of a reporting period, the licence is suspended or annulled (point 48). Insurers report the ratio and their compliance with the placement limits every quarter, by the 25th of the month after the quarter (point 36).
The board's investment policy
Regulation 1982 turns these limits into governance. Every year the insurer drafts an investment policy for the next financial year, approved by the supervisory board or another authorised body by 20 December (point 12). The policy must cover, among other things:
- an analysis of investment risks;
- long-term allocation across asset types;
- allocation limits by asset type, region and industry;
- restrictions or bans on particular investments;
- decision limits for responsible staff;
- a contingency plan for deteriorating conditions.
Before any investment, a responsible person reviews the documents and gives a written opinion within a week (point 14). That person may not also post accounting entries or handle cash (point 18). The insurer keeps internal investment reports by asset, dates, rates and income (point 17), runs an annual internal control of its investments and reports the results to the supervisory board (points 19 and 20).
The regulator's floor and the board's own policy need the same inputs: valuation, issuer and bank exposure, and a record of every breach. The idea behind the limits is the one in diversification and risk.
Where Finmind fits
Finmind is a data and analytics platform, not a regulator's filing system. Reports to NAPP remain the insurer's own. What an organisation's Finmind account includes today, and its stated limits, is set out on the /institutions page.
Frequently asked questions
Under point 20 of regulation 1806, deposits in one commercial bank may not exceed 40% of the insurer's assets. Deposits with credit organisations that are not commercial banks are capped at 10% of assets in total.
The supervisory board or another authorised body of the insurer, every year by 20 December for the following financial year, under point 12 of regulation 1982. The board also receives the annual internal control report on investments.
Yes, as published on lex.uz on 28 September 2026. All three are in force, and NAPP itself amended regulation 1882 in March 2026 and regulation 1806 in May 2025.
This article is for education only and is not investment advice. Investing in securities involves risk, including the loss of money you invest.