The article analyses recent developments in the regulation of digital markets in the Republic of Uzbekistan, introduced by the Law on Competition dated 2023 and subordinate regulations that came into force in August 2024. Uzbekistan is among the first CIS countries to adopt specific rules for digital platforms, establishing quantitative criteria for dominance and an exhaustive list of prohibitions for their operators. A comparative analysis shows that while Uzbekistan’s model formally follows the principles of traditional antitrust regulation, it is substantively close to the ex ante approach embodied in the European Union’s Digital Markets Act. In contrast, the Russian model (combining classic antitrust tools with targeted regulation of specific digital markets) appears more flexible and effective in the context of a rapidly evolving digital economy.
E. S. Khokhlov (2025) studied this question.