Who must have a statutory audit: Article 35 of Law ZRU-677

Statutory audit is a legal requirement, not a decision based only on the size of a business. Article 35 of Uzbekistan’s Law No. ZRU-677 “On Auditing Activity” identifies the organizations whose financial statements must undergo an annual independent audit. The starting point is the entity’s legal form, activities and ownership structure, followed by the reporting-year thresholds for commercial organizations.

Who is on the list

• joint-stock companies;
• banks and other credit institutions;
• insurance companies;
• agricultural cooperatives;
• investment and other funds pooling money of legal entities and individuals, and their trustees;
• charitable, public and other funds formed from contributions of legal entities and individuals (except public funds with no turnover on bank accounts during a calendar year);
• business entities with a state share in their charter capital;
• exchanges;
• commercial organisations that, for the reporting year, meet two of three criteria: total assets above 100,000 BCV; sales revenue above 200,000 BCV; average headcount above 100 employees.

Applying the thresholds

Commercial organizations apply the two-of-three test using the results of the reporting year: total assets above 100,000 BCV, sales revenue above 200,000 BCV and average headcount above 100 employees. Meeting only one threshold is not enough for this category, although another category in Article 35 may still apply. The comparison should use the entity’s documented reporting-year figures, rather than a forecast or a single month’s revenue.

Recent amendments

The current edition reflects amendments noted by LexUz: agricultural cooperatives were added by Law ZRU-995, in force from 12 February 2025; the state-share item was amended by Law ZRU-1025, in force from 8 May 2025; and the funds item was amended by Law ZRU-1083 of 21 August 2025. The exception for public funds with no bank-account turnover during the calendar year should be read alongside the complete provision.

Audit organizations have obligations too. Article 29 requires publication of information on completed statutory audits. Article 34 limits the same audit firm to auditing an entity for no more than seven consecutive years. Planning should therefore consider auditor independence, reporting readiness and agreed document-delivery dates. At a free consultation, INTERAUDIT can check whether the requirement applies to your company and discuss the engagement’s scope, timeline and fee.